Overview

Assets Under Management: $773 million
Headquarters: DALLAS, TX
High-Net-Worth Clients: 214
Average Client Assets: $2 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (ORG PARTNERS ADV2A BROCHURE)

MinMaxMarginal Fee Rate
$0 and above 2.00%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $20,000 2.00%
$5 million $100,000 2.00%
$10 million $200,000 2.00%
$50 million $1,000,000 2.00%
$100 million $2,000,000 2.00%

Clients

Number of High-Net-Worth Clients: 214
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 68.69
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 1,747
Discretionary Accounts: 1,726
Non-Discretionary Accounts: 21

Regulatory Filings

CRD Number: 312728
Filing ID: 2001120
Last Filing Date: 2025-08-27 20:06:00
Website: https://orgpag.com

Form ADV Documents

Primary Brochure: ORG PARTNERS ADV2A BROCHURE (2025-08-27)

View Document Text
I Part 2A of Form ADV: Firm Brochure ORG Partners, LLC 5001 Spring Valley Rd, Suite 810W Dallas, TX 75244 August 2025 This brochure provides information about the qualifications and business practices of ORG Partners, LLC. If you have any questions about the contents of this brochure, please contact our Chief Compliance Officer, Matthew Reynolds, at matthew.reynolds@orgpag.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about ORG Partners is also available on the SEC’s website at www.adviserinfo.sec.gov. References herein to ORG Partners, LLC as a “registered investment adviser” or any reference to being “registered” does not imply a certain level of skill or training. Form ADV Part 2 Brochure You can obtain a current copy of the Form CRS at http://www.orgpag.com. Page 1 of 24 Item 2 Material Changes Since our amended filing with the SEC in March 2024, the following material changes have been made to this brochure: • ORG Partners has updated Item 10: ORG affiliations include Ascentis Asset Management, LLC (CRD #318126), Ascentis Wealth Management, LLC (CRD #330923) and Golden State Equity Partners, LLC (CRD #322879) through common ownership. The Firm’s ownership structure has changed, with Michael Mansur having the largest individual 0wnership position in Ascentis Operations, LLC, the holding company of ORG Partners, LLC through a private Irrevocable Trust. • The Chief Compliance Officer was updated from Justine Kidwell to Matthew Reynolds. • The firm’s home office was moved to 5001 Spring Valley Rd, 810W, Dallas, TX 75244 Form ADV Part 2 Brochure You can obtain a current copy of the Form CRS at http://www.orgpag.com. Page 2 of 24 Table of Contents Item 3 Contents Item 1 Cover Page ................................................................................................................................ 1 Item 2 Material Changes ...................................................................................................................... 2 Item 3 Table of Contents ...................................................................................................................... 3 Item 4 Advisory Business...................................................................................................................... 5 A. ORG Partners, LLC .......................................................................................................................... 5 B. Types of Advisory Services Offered ................................................................................................ 5 C. Tailored Relationships ................................................................................................................... 7 D. Participation in Wrap Fee Programs .............................................................................................. 8 E. Assets Under Management ........................................................................................................... 8 Item 5 Fees and Compensation ............................................................................................................ 8 A. ORG Compensation ....................................................................................................................... 8 B. Billing of Fees ............................................................................................................................... 11 C. Other Fees ................................................................................................................................... 11 Item 6 Performance-Based Fees and Side-By-Side Management ....................................................... 12 Item 7 Types of Clients ....................................................................................................................... 12 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................................... 12 A. Methods of Analysis and Investment Strategies .......................................................................... 12 B. Risk of Loss ................................................................................................................................... 13 C. Other Fees ................................................................................................................................... 15 Item 9 Disciplinary Information ........................................................................................................... 15 Item 10 Other Financial Industry Activities and Affiliations ............................................................... 16 A. Affiliations.................................................................................................................................... 16 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......... 16 A. ORG Partners Code of Ethics ........................................................................................................ 16 B. Participation or Interest in Client Transactions ............................................................................ 17 C. Personal Trading .......................................................................................................................... 17 Item 12 Brokerage Practices ............................................................................................................. 17 A. Broker-Dealer Selection ............................................................................................................... 17 B. Trade Errors ................................................................................................................................. 20 C. Order Aggregation, Allocation, and Rotation Practices ................................................................ 20 Form ADV Part 2 Brochure You can obtain a current copy of the Form CRS at http://www.orgpag.com. Page 3 of 24 Item 13 Review of Accounts .............................................................................................................. 21 A. Periodic Reviews .......................................................................................................................... 21 Item 14 Client Referrals and Other Compensation ............................................................................ 21 A. Other Compensation ................................................................................................................... 22 B. Referrals ...................................................................................................................................... 24 Item 15 Custody ................................................................................................................................ 24 Item 16 Investment Discretion .......................................................................................................... 24 Item 17 Voting Client Securities ........................................................................................................ 24 Item 18 Financial Information ........................................................................................................... 24 Form ADV Part 2 Brochure You can obtain a current copy of the Form CRS at http://www.orgpag.com. Page 4 of 24 Advisory Business Item 4 A. ORG Partners, LLC ORG Partners, LLC (“ORG Partners,” “ORG, “or the “Adviser”) is an Indiana limited liability company formed on January 17, 2021. The Adviser is an investment adviser registered with the Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940, as amended (the “Investment Advisers Act”). ORG affiliations include Ascentis Asset Management, LLC (CRD #318126), Ascentis Wealth Management, LLC (CRD #330923) and Golden State Equity Partners, LLC (CRD #322879) through common ownership. The Firm’s ownership structure has changed, with Michael Mansur having the largest individual Ownership position in Ascentis Operations, LLC, the holding company of ORG Partners, LLC through a private Irrevocable Trust. Our firm’s home office is located at 5001 Spring Valley Rd, 810W, Dallas, TX 75244. Our investment adviser representatives of the firm are permitted to conduct their business under a “doing business as” name, otherwise known as a “d/b/a/.” ORG Partners, LLC also conducts business under the following d/b/a names: • The Cirque Financial Group • Constance Wealth Advisors • Tinker Capital • Xartis Wealth Advisory Group • Century Wealth Advisors • Elias Financial Services • Benchmark Financial Advisors B. Types of Advisory Services Offered Financial Planning The Adviser’s financial planning process begins with an intensive fact-finding session which helps the Adviser become familiar with the client’s current financial situation (including among other things, income taxes, investments, insurance, estate affairs and family circumstances), as well as their personal goals and priorities for the next several years. Then, working from this comprehensive information, the Adviser makes specific goal-oriented recommendations. The Adviser’s specific goal-oriented recommendations are designed to educate and allow a client to coordinate his/her financial affairs more efficiently, increase cash flow, prudently reduce income taxes, and attempt to improve his/her overall net worth. Once this has been discussed with the client, the recommendations that the client feels comfortable with are scheduled for implementation with specific deadlines to be met. The Adviser continues to assist the client based on an annual review of services in all applicable areas of financial planning including estate, retirement, cash flow and tax planning. Investment Consulting The Adviser works to provide institutional retirement plans and the plan sponsors with diversified investment options for plan participants to choose from. In addition, as requested by the plan sponsor, the Adviser shall provide plan participants with general information seminars and/or educational materials that describe the various investment alternatives available under the plan, information about investing in general, including information about different types of investments, such as allocation strategies, and historical returns. Interactive materials designed to help participants identify an appropriate investment strategy are provided. Investment Management We offer discretionary and non-discretionary investment management services. Investment management services offered by the Adviser are specifically tailored to meet the needs of each client. Prior to Form ADV Part 2 Brochure You can obtain a current copy of the Form CRS at http://www.orgpag.com. Page 5 of 24 delivering investment advisory services, the Adviser will ascertain each client’s specific investment objective. The Adviser will allocate, or recommend that the client allocate, their investment assets consistent with the designated investment objective. Please note: It is always the client’s responsibility to promptly notify the Adviser if there is any change in their financial situation or investment objective. This notification of change allows the Adviser an opportunity to review, evaluate, or revise the previous recommendations or services. Managed Discretionary Assets If you engage our firm on a discretionary basis, we require you to grant us discretionary authority to manage your account. Discretionary authorization will allow our Investment Advisor Representatives (“IAR’s”) to weigh the Client’s objectives with current market conditions and act on a client’s account without further authorization. ORG Partners has engaged Ascentis Asset Management, LLC, an affiliate, as the sub-adviser for certain client accounts. As discussed further- in Item 10, ORG Partners, LLC is affiliated by common ownership with Ascentis Asset Management, LLC. Clients have the authority to impose reasonable restrictions on any of the Adviser’s investment advisory services at any time, but restrictions must be delivered to the Adviser in writing and must be signed by the client. Managed Non-Discretionary Assets In addition to providing investment management of client assets on a discretionary basis, the Adviser, for a separate and additional fee, provides certain limited services to clients with respect to “Managed Non- Discretionary Assets.” These services consist solely of the following: • The Adviser is available to consult with the client on a semi-annual basis (or more often if requested by the client) regarding Managed Non-Discretionary Assets. However, the client is solely responsible for all decisions and consequences on the client’s Managed Non-discretionary Assets, including decisions on whether to retain or sell all or a portion of the Managed Non- Discretionary Assets. This responsibility remains solely with the client regardless of whether any security is reflected on account reports prepared by the Adviser. • The Adviser is available to service Managed Non-Discretionary Assets, such as setting up and monitoring regular distributions and special one-time distribution requests. • The Adviser can process any trades on the Managed Non-Discretionary Assets, but only when requested to do so by the client. Upon receipt of any client’s request, The Adviser will endeavor, but cannot guarantee, that any such transaction will be affected on the day received or at any specific time or price. Limitations for Non-Discretionary Assets Clients that engage the Adviser on a non-discretionary investment advisory basis must be willing to accept that the Adviser cannot affect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event of a market correction during which the client is unavailable, ORG Partners will be unable to affect any account transactions (as it would for its discretionary accounts) without first obtaining the client’s consent. Third-Party Money Mangers After the Adviser has gathered information about the client’s specific investment objective, the Adviser will assist the Client in selecting a Third-Party Money Manager (“TPMM”) to deliver an investment model (“strategy”) or manage a separate account for the Client. IAR’s utilize multiple factors in selecting a prudent TPMM to recommend to a client, including but not limited to performance, investment objectives, and fees. These factors are considered in relation to the Client’s specific investment objective to help determine the suitability of the TPMM. When a Client engages a TPMM we recommend, we do not directly Form ADV Part 2 Brochure You can obtain a current copy of the Form CRS at http://www.orgpag.com. Page 6 of 24 manage that portion of the Client’s portfolio assets and are not involved in selecting the securities to be bought and sold, or the timing of the same. The day-to-day portfolio management decisions are provided by the TPMM and then executed by us at the Client’s custodian or executed directly by the TPMM if managed in a separate account. In the event that the use of multiple TPMMs is recommended to a client, each TPMM has differing minimum account requirements as well as a variety of fee ranges. If a client uses a TPMM in a separate account, we periodically review the Client’s financial situation, objectives, and restrictions; and communicate relevant information to the TPMM and assist the client in understanding and evaluating the services provided by the TPMM. Some TPPMs maintain their own separate execution, clearing, and custodial relationships. If we determine that a selected TPMM is not managing the Client’s portfolio in a manner consistent with the Client’s IPS and investment objectives, or if the financial situation of the Client changes, we recommend a new TPPM. Additional Services The Adviser is authorized to furnish advice on matters not involving securities, such as: Insurance Review & Planning Corporate Retirement Plan Guidance • Retirement Income Planning Withdrawal Rate Analysis • • Estate & Charitable Gift Planning • Business Successions • Personal Financial Planning • Education Planning • Cash Flow & Budgeting • Employee Benefits & 401(k) Guidance • Tax Planning C. Tailored Relationships At the Adviser, advisory services are tailored to the specific needs of each Client. Prior to providing advisory services, the Adviser will ascertain each Client’s investment goals and objectives. The Adviser then allocates and/or recommends that the client allocate investment assets consistent with the designated investment objective. The client has the authority to, at any time, impose reasonable restrictions on the Adviser’s services, but restrictions must be delivered to the Adviser in writing and must be signed by the Client. In performing services for the Client, the Adviser is not required to verify any information it received from the client or from the Client’s other professionals and the Adviser is expressly authorized by the Client to rely on this information. Each client is advised that it remains the Client’s responsibility to promptly notify the Adviser if there is ever any change in the Client’s financial situation or investment objectives for the purpose of reviewing, evaluating, or revising the Adviser’s previous recommendations or services to the Client. D. Participation in Wrap Fee Programs The Adviser offers services through both wrap fee programs and non-wrap fee programs. Certain other fees are not included in the wrap fee and are paid for separately by the client. These fees include custodial fees, charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), mark- ups and mark-downs, spreads paid to market makers, fees for trades executed away from the custodian, wire Form ADV Part 2 Brochure You can obtain a current copy of the Form CRS at http://www.orgpag.com. Page 7 of 24 transfer fees and other fees and taxes on brokerage accounts and securities transactions. These fees are not included within the wrap-fee you are charged by our firm, and the client would be charged these fees if appliable. Please refer to the Adviser’s Wrap Fee Brochure for additional information. Generally, we consider wrap fee programs through which investment advisory services and execution of your transactions are provided for specified fees that are not based directly upon transactions in your account. Our firm and our investment team do not manage wrap fee accounts differently from other programs. E. Assets Under Management The Adviser Manages a total of $983,937,880 in client assets. $962,359,847 is managed in a discretionary fashion, and the remainder is managed in a non- discretionary manner. Item 5 Fees and Compensation The information below provides an overview of the fees and compensation we generally receive for the services we provide. Please refer to your agreement with ORG for information about the specific fees to be imposed with respect to your account and the other terms and conditions that will govern your relationship with ORG. Our fees are generally negotiable. Fees vary because of negotiations, discussions and/or factors that include, but are not limited to, the circumstances of the client, the size and scope of the overall client relationship, client investment guidelines, additional or differing levels of servicing, or as otherwise agreed with specific clients. A. ORG Compensation Financial Planning Fees ORG Partners offers either hourly or fixed fee arrangements to all clients for its financial planning services. Fixed fees are computed based upon a good faith estimate of the hours required to perform services. ORG attempts to maintain parity with hourly and fixed charges while allowing some flexibility in estimation, considering case complexity and client-specific circumstances. Financial planning fees are negotiated on an individual basis at the time of the engagement for such services. Factors considered in determining the fees charged generally include, without limitation, the type of financial planning services provided such as retirement planning, legacy planning, tax planning, insurance, and special needs planning. An initial meeting is scheduled with a prospective client at no cost or obligation. The purpose of the meeting is to inform the prospective client of the types of services the Adviser provides and to generally discuss what the client desires from such a financial planning relationship. If the prospective client is interested in exploring the Adviser’s services in more detail, the Adviser will review the prospective client’s recent income tax returns and make a listing of his/her assets and liabilities. At a subsequent session, the prospective client is given an idea of the specific value of pursuing this financial planning process and is quoted a fee for the financial planning services to be provided. The financial planning fee is quoted on a project basis and covers projected time and expense associated with working with this client for a twelve-month period. This includes gathering data, developing the written plan, reviewing the plan with appropriate advisers, discussing the plan with the client, implementation, and continuing to review, monitor and update the client’s affairs throughout the ensuing twelve months. The financial planning fee is based upon several factors, including net worth, gross income, complexity of one’s financial affairs, and the time necessary to meet each individual client’s goals and priorities. Certain unforeseen expenses could perhaps not be included in the financial planning fee and would be billed directly. Form ADV Part 2 Brochure You can obtain a current copy of the Form CRS at http://www.orgpag.com. Page 8 of 24 Once the client verbally agrees to the personal financial planning process, the process to develop the written documents begins. Once the financial plan is completed and the appropriate advisers have reviewed the plan, a meeting is scheduled to discuss the plan and the specific items to be implemented with the client. The client takes from this meeting the written plan. The client will be invoiced for the services provided. Payments are expected within 30 days of the invoice date through an approved payment method offered by ORG Partners as outlined on the invoice. The financial planning fee shall be mutually agreed upon in advance by and between the client and ORG. Any such fee shall be separate from the asset-based investment management fee. The Adviser reserves the right to waive a portion of or the entire financial planning fee. The client can terminate the financial planning and/advisory relationship at any time within 10 days’ written notice. Investment Consulting Fees The Adviser bases its annual investment consulting fee for retirement plan assets upon a percentage (%) of the market value of the assets and the specific types of investment consulting services provided. The Adviser charges an annual fee of up to 2.00% of assets under management. The Adviser can choose to charge a lower asset-based fee at its sole discretion. Platform Fees When a client is invested with the Mercato platform, the Adviser receives compensation in the form of a fee, this fee is not shared with the advisor. Investment Management Fees The Adviser bases its annual investment management fee upon a percentage of assets under management. The Adviser charges an annual fee of up to 2.00% of assets under management. The Adviser can choose to charge a lower asset-based fee at its sole discretion. Fee Schedule The client agrees to pay the following fees: • The management fee is in the amount of 200 basis points, at maximum, deducted on a quarterly basis. • Platform fees (e.g., Liberty Fi, Envestnet, etc.) • Investment management fees payable to third parties. Model portfolio advisors could include affiliates of ORG. o ORG Partners can invest client assets in models that are created by affiliates of ORG Partners and the affiliates could be compensated on models used by ORG Partners clients. Fee Calculation Basis The value used to calculate the investment management fee will be based on the average daily balance computed at the close of business each trading day or the value of the assets on the last day of the prior quarter. Your specific billing will be referenced above and is detailed in your investment management agreement. Average Daily Balance Billing The figure used in the fee calculation is the average daily balance of the previous quarter computed at the close of business each trading day. In computing Average Daily Balance in the account, shares of any Form ADV Part 2 Brochure You can obtain a current copy of the Form CRS at http://www.orgpag.com. Page 9 of 24 mutual funds are valued at their respective net asset value as calculated on the valuation date in accordance with each fund’s prospectus. The value of stocks, bonds, options, and other securities is the closing price provided by custodians and/or reputable pricing services. You should not deem valuation, for fee calculation purposes, as a guarantee with respect to marketability/liquidation value of those assets. Last Day of the Previous Quarter Billing The figure used in the fee calculation is the value of assets on the last day of the previous quarter, as valued by the custodian. Payment of Fees The fees listed above are payable by the client to ORG Partners Quarterly- in advance, based upon the fee calculation method detailed in the client’s investment management agreement for the previous quarter. Third-Party Money Manager Fees Fees charged by Third-Party Money Managers are often similar to, more, or less than fees assessed by ORG Partners. The Client will pay any TPMM engaged pursuant to the foregoing fees charged by the managers, which are separate from and in addition to the Adviser’s fees. Clients referred to a TPMM for the management of a separate account are directed to the disclosure documents. Negotiated Fees The Adviser, in its sole discretion, can reduce its investment management fee based upon certain factors, like anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, negotiations with client and other considerations. Other Fees Clients not participating in a wrap fee program will incur transaction charges for trades executed in their accounts. These transaction charges are separate from our fees and will generally be disclosed in the brokerage or custodian agreement in place with respect to your account. Clients can incur certain charges imposed by custodians, brokers, and other third parties such as custodial fees, deferred sales charges, odd- lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Also, clients will pay the following separately incurred expenses: charges imposed directly by an investment model, mutual fund, index fund, or ETF, which expenses and charges are generally disclosed in the fund's prospectus (e.g., fund management fees, distribution fees and other fund expenses). Clients could be responsible for paying fees charged by sub-advisers, money managers, Platforms, and/or Platform managers that have been engaged to manage their account as described in the investment management agreement. Such charges, fees, and commissions are exclusive of, and in addition to, our fee. ORG, or our affiliate, receives a portion of fees charged by Platforms and for certain investment models. Item 10 further describes this arrangement, and the conflicts of interest presented. This brochure describes our non-wrap fee advisory services; clients utilizing our wrap fee portfolio management should see the separate Wrap Fee Program Brochure for additional details regarding third party fees. Item 12 further describes the factors that we consider in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). Form ADV Part 2 Brochure You can obtain a current copy of the Form CRS at http://www.orgpag.com. Page 10 of 24 B. Billing of Fees ORG Partners ’s investment management fees shall be assessed quarterly, in advance, based upon the fee calculation method detailed in the client’s investment management agreement for the prior quarter. New accounts will be assessed a prorated fee depending upon the number of days remaining in the quarter. The Adviser clients must provide their consent in advance to direct debiting of investment management fees from their custodial account. The Investment Advisory Agreement and the custodial/ clearing agreement authorize the custodian to debit the client account for the amount of the Adviser’s investment management fee, and to directly remit that investment management fee to the Adviser in compliance with regulatory procedures. The Adviser can send each client an itemized fee invoice each quarter – please see Item 15 for additional information. In the limited event that the Adviser bills the client directly, payment in full is expected upon presentation of the invoice. In the event an agreement is terminated, the client will receive a prorated refund for fees paid in advance. C. Other Fees Unless clients direct otherwise or an individual client’s circumstances require, the Adviser generally recommends one of several unaffiliated custodians (e.g., Charles Schwab & Co., Sanders Morris Harris. etc.) serve as the broker-dealer/custodian for client investment accounts. Broker dealers such as those listed above can charge brokerage commissions and/or transaction fees for effecting certain securities transactions. For example, these custodians can charge commissions for individual equity and fixed income securities transactions, or fees can be charged for certain no-load mutual fund transactions. In addition to the Adviser’s investment management fee, custodial brokerage commissions and/or transaction fees, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Advisor Credit Exchange ORG Partners participates on the Advisor Credit Exchange platform (“ACx”) presented by the Advisor Credit Exchange, LLC (“ACE”). The ACx platform is made available by ACE to certain Advisors, and Participating Lenders and their respective authorized users to enable matching and pre-qualification of Advisor Clients with Participating Lenders based on Participating Lenders’ credit criteria, along with such other features and functionality as offered by ACE from time to time. This presents a conflict of interest because ACE agrees to pay the Advisor a fee for each loan referred through ACx; this arrangement presents a conflict of interest and gives the Advisor an incentive to recommended participating lenders based on the compensation received. Clients have the option to search for participating lenders through other channels not affiliated with us. Performance-Based Fees and Side-By-Side Management Item 6 ORG Partners does not advise any client accounts that are subject to performance-based fee arrangements. Types of Clients Item 7 The Adviser predominantly offers its services to individuals, high net worth individuals, pension and profit-sharing plans and participants, trusts, estates, charitable organizations, corporations, or business entities. ORG Partners generally requires an account minimum of $25,000 for investment management services. When a consolidated client account value in this program falls below $25,000 in value, the minimum quarterly fee of $100.00 will be charged. ORG Partners Clients with assets at or below the minimum Form ADV Part 2 Brochure You can obtain a current copy of the Form CRS at http://www.orgpag.com. Page 11 of 24 account size can pay a higher percentage rate on their annual advisory fees than the fees paid by clients with significantly greater assets under management. The Adviser can reduce or waive its minimum asset requirement based upon certain factors, like anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, negotiations with client and other considerations. Other exceptions can apply to employees of the Adviser and their relatives, or relatives of existing clients. Methods of Analysis, Investment Strategies and Risk of Loss Item 8 A. Methods of Analysis and Investment Strategies The Adviser’s security analysis methods can include fundamental analysis, technical analysis, charting and cyclical analysis. The main sources of information for analysis include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Additional research tools and sources of information that the Adviser can use include mutual fund and stock information provided by unaffiliated third parties (e.g., Morningstar, etc.) and many other reports located on the Internet using the World Wide Web. The Adviser is permitted to utilize the following investment strategies when implementing investment advice given to clients: Long Term Purchases: (securities held at least a year) Short Term Purchases: (securities sold within a year) Trading: (securities sold within thirty (30) days) • • • • Options (contract for the purchase or sale of a security at a predetermined price during a specific period of time) Strategic and Tactical Asset Allocation can be utilized with domestic mutual funds, exchange-traded funds, or stocks and bonds as the core investments. Global mutual funds, sector funds and specialty exchange-traded funds can be added as satellite positions. Portfolios can be further diversified among large, medium, and small sized investments in an effort to control the risk associated with traditional markets. Investment strategies designed for each client are based upon specific objectives stated by the client during consultations. Clients can change their specific objectives at any time. Each client executes an Investment Policy Statement that documents their specific objectives and their desired investment strategy. Please Note: Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy recommended or undertaken by the Adviser will be profitable or equal any specific performance level. Investing in securities involves risk of loss that clients should be prepared to bear. B. Risk of Loss Risk is inherent in any investment in securities and the Adviser does not guarantee any level of return on a client’s investments. There is no assurance that a client’s investment objectives will be achieved. A client is subject to certain risks, including, but not limited to, the risks described below. The risks Form ADV Part 2 Brochure You can obtain a current copy of the Form CRS at http://www.orgpag.com. Page 12 of 24 discussed below vary by investment style or strategy. These risks do not always apply to a client. A client should also review the prospectuses or other disclosure documents for the securities purchased for the client’s account, as they will contain important information about the risks associated with investing in such securities. Investment strategies recommended by the Adviser can be subject to some or all of the following types of risk: • Interest-rate Risk: Fluctuations in interest rates can cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • • Market Risk: The price of a security, bond, ETF, or mutual fund can drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions trigger market events. Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments could have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. • • Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They can carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many investors are interested in buying or selling a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations can result in bankruptcy and/or a declining market value. • Risks of Investments in ETFs, Mutual Funds, and Other Investment Pools: ORG Partners can invest client portfolios in ETFs, mutual funds, and other investment pools (“Funds”). Investments in Funds are generally less risky than investing in individual securities because of their diversified portfolios; however, these investments are still subject to risks associated with the markets in which they invest. In addition, Funds’ success will be related to the skills of their managers and their performance in managing their Funds. Registered Funds are also subject to risks due to regulatory restrictions applicable to registered investment companies under the Investment Company Act of 1940, as amended. • Fixed Income Risks: ORG Partners can invest portions of client assets directly in fixed income instruments, such as bonds and notes, or invest in Funds that invest in bonds and notes. While investing in fixed income instruments, either directly or through Funds, is generally less volatile than investing in stock (equity) markets, fixed income investments nevertheless are subject to risks. These risks include, without limitation, interest rate risks (risks that changes in interest rates will devalue the investments), credit risks (risks of default by borrowers), or maturity risk (risks that bonds or notes will change value from the time of issuance to maturity). ORG Partners can invest portions of client assets into securities that are rated below investment grade Form ADV Part 2 Brochure You can obtain a current copy of the Form CRS at http://www.orgpag.com. Page 13 of 24 (commonly known as “high yield” or “junk bonds”). Securities which are in the lower-grade categories generally offer a higher current yield than is offered by higher-grade securities of similar maturities, but they also generally involve greater risks, such as greater credit risk, greater market risk and volatility, and greater liquidity concerns. These investments are generally considered to be speculative based on the issuer’s capacity or incapacity to pay interest and repay principal. • Financial Planning Risks: Financial planning is inherently speculative, and ORG Partners makes no guarantee regarding the success or feasibility of any financial plan. The information forming the basis of any financial plan will be derived from sources that ORG Partners believes are reliable, including information provided by the client, and the accuracy of such information is not guaranteed or independently verified by the Advisor. Certain financial planning services include educational information regarding the effect of taxes or recommendations with respect to insurance coverage types and amounts. Clients should understand that this tax and insurance information is general in nature. Nothing recommended or outlined by ORG Partners should be used by a client as a substitute for competent legal, accounting, or tax counsel provided by the client’s personal attorney, accountant, and/or tax advisor. Additionally, ORG Partners strongly recommends that each client review each area of potential and/or actual insurance coverage need with the client’s insurance agent to ensure that adequate coverage exists. • Cybersecurity Risk: As technology becomes more integrated into ORG Partners operations, ORG Partners will face greater operational risks through breaches in cybersecurity. A breach in cybersecurity refers to both intentional and unintentional events that cause ORG Partners to lose proprietary information, suffer data corruption, or lose operational capacity. This in turn could cause ORG Partners to incur regulatory penalties, reputational damage, additional compliance costs associated with corrective measures, and/or financial loss. Cybersecurity threats can result from unauthorized access to ORG Partners’ digital information systems (e.g., through “hacking” or malicious software coding), but can also result from outside attacks such as denial-of-service attacks (i.e., efforts to make network services unavailable to intended users). In addition, because ORG Partners works closely with third-party service providers (e.g., administrators, transfer agents, and custodians), cybersecurity breaches at such third-party service providers can subject ORG Partners to many of the same risks associated with direct cybersecurity breaches. The same is true for cybersecurity breaches at any of the issuers in which ORG Partners invest. While ORG Partners and their third-party service providers have established information technology and data security programs and have in place business continuity plans and other systems designed to prevent losses and mitigate cybersecurity risk, there are inherent limitations in such plans and systems, including the possibility that certain risks have not been identified or that cyber-attacks can be highly sophisticated. • Private Equity (PE) Funds and Private placement Securities Risks are inherently illiquid; they cannot be easily sold or exchanged for cash without a substantial loss in value. Investors are usually required to commit their capital for extended periods. Private equity funds typically charge high fees, including management fees and performance fees (carried interest). These fees can erode returns, especially if the fund's performance does not meet expectations. Private Equity funds are subject to higher degrees of risk and are not suitable for all investors. Their performance is heavily dependent on the skill and experience of the management team. Private equity funds commonly use leverage (borrowed funds) to enhance returns, which can increase the potential for significant losses, especially in downturns. In addition, Private Equity investments often lack transparency. Detailed information about the fund's operations and investments is not readily available, making it challenging to evaluate the valuations of private companies. • Private Placement Securities have similar characteristics and carry risks akin to those of Private Form ADV Part 2 Brochure You can obtain a current copy of the Form CRS at http://www.orgpag.com. Page 14 of 24 Equity Funds. However, Private Placements are typically offered to institutional clients or accredited investors. Please Note: In light of these risks of loss and potentially enhanced volatility, clients can direct the Adviser, in writing at any time, not to employ any or all of the investment strategies recommended by ORG Partners for their account. C. Other Fees Unless clients direct otherwise or an individual client’s circumstances require, the Adviser generally recommends one of several unaffiliated custodians (e.g., Charles Schwab & Co., Saunder Morris Harris etc.) serve as the broker-dealer/custodian for client investment accounts. Broker dealers such as those listed above can charge brokerage commissions and/or transaction fees for effecting certain securities transactions. For example, these custodians can charge commissions for individual equity and fixed income securities transactions, or fees can be charged for certain no-load mutual fund transactions. In addition to the Adviser’s investment management fee, custodial brokerage commissions and/or transaction fees, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Disciplinary Information Item 9 Investment Advisors are required to disclose legal or disciplinary events that are material to a client’s or prospective client’s evaluation of the Advisor’s business or the integrity of the Advisor’s management. ORG Partners has no such disclosures to provide. Other Financial Industry Activities and Affiliation Item 10 The Adviser is not registered as a securities broker-dealer, futures commission merchant, commodity pool operator or commodity trading advisor. Some representatives of the firms are also registered representatives of Broker Dealers. Advisors that are also registered representatives of a broker dealer can offer securities and receive normal and customary commissions as a result of securities transactions. Therefore, a conflict of interest would arise as these commissionable securities sales could create an incentive to recommend products based on the compensation they would earn and not necessarily be in the best interests of the clients. Many of the financial professionals at our firm are licensed insurance agents. ORG Partners, at times, recommends the use of various insurance products where we believe it is in your best interest. You should be aware that these services pay a commission or other compensation and present a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. ORG Partners always seeks to act in the best interest of the client; including the sale of commissionable products to advisory clients, and we will disclose the commission prior to the sale. You are in no way required to implement the plan through any representative of ORG Partners in such an individual’s capacity as an insurance agent. A. Affiliations ORG affiliations include Ascentis Asset Management, LLC (CRD #318126), Ascentis Wealth Management, LLC (CRD #330923) and Golden State Equity Partners, LLC (CRD #322879) through common ownership. The Firm’s ownership structure has changed, with Michael Mansur having the largest individual 0wnership position in Ascentis Operations, LLC, the holding company of ORG Partners, LLC through a private Irrevocable Trust. Form ADV Part 2 Brochure You can obtain a current copy of the Form CRS at http://www.orgpag.com. Page 15 of 24 Code of Ethics, Participation or Interest in Client Transactions and Personal Item 11 Trading A. ORG Partners Code of Ethics We have adopted a Code of Ethics pursuant to Advisers Act Rule 204A-1. A basic tenet of our Code of Ethics is that the interests of clients are always placed first. The Code of Ethics includes standards of business conduct requiring Access Persons to comply with the federal securities laws and the fiduciary duties an investment adviser owes to its clients. The Code of Ethics also requires that all Access Persons comply with ethical restraints relating to clients and their accounts, including restrictions on gifts and provisions intended to prevent violations of laws prohibiting insider trading. The goal of our Code of Ethics is to ensure that personal investing activities by our employees are consistent with our fiduciary duty to its clients. The Code of Ethics includes standards of business conduct requiring Access Persons to comply with the federal securities laws and the fiduciary duties an investment adviser owes to its clients. The Code applies to all Access persons that are considered to be supervised by ORG Partners. Personnel are considered to be Access Persons under the Code including the following: • Directors, officers, and partners of the Firm (or other persons occupying a similar status or performing similar functions). • Employees of the Firm; • Any other person who provides advice on behalf of the Firm and is subject to the Firm’s supervision and control. Our Code of Ethics is available to you upon request. You can obtain a copy of our Code of Ethics by contacting our Chief Compliance Officer, Justine Kidwell, at justine.kidwell@orgpag.com. B. Participation or Interest in Client Transactions ORG Partners and/or its representatives are permitted to engage in securities transactions for their own accounts, including the same or related securities that are recommended to or owned by clients of the Adviser. Because Advisors can invest in the same securities as clients, there is a possibility that an Advisor will benefit from a client’s trading activity in a security held by the Advisor. C. Personal Trading To address the potential for conflict of interests, the Adviser has adopted a Code that applies to its representatives who have access to non-public information relating to advisory client accounts (“Access Persons”). The Code prohibits Access Persons from using knowledge about advisory client account transactions to profit personally, directly, or indirectly, by trading in his/her personal accounts. To help monitor any conflict of interest, all Access Persons are required to submit quarterly personal securities transactions and annual holdings reports for review by the Chief Compliance Officer. Brokerage Practices Item 12 A. Broker-Dealer Selection We seek to recommend a custodian/broker who will hold your assets and execute transactions on terms that are overall most advantageous when compared with other available providers and their services. We consider a wide range of factors, including these: • Combination of transaction execution services along with asset custody services (generally without a separate fee for custody) • Capability to execute, clear, and settle trades (buy and sell securities for your account) • Capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) Form ADV Part 2 Brochure You can obtain a current copy of the Form CRS at http://www.orgpag.com. Page 16 of 24 • Breadth of investment products made available (stocks, bonds, mutual funds, exchange traded funds (ETFs), etc.) • Availability of investment research and tools that assist us in making investment decisions • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate them • Reputation, financial strength, and stability of the provider • Their prior service to us and our other clients • Availability of other products and services that benefit us ORG Partners does not maintain custody of your assets that we manage, although we can be deemed to have custody of your assets if you give us authority to withdraw assets from your account (see Item 14 – Custody, below). Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. We recommend that our clients use Charles Schwab & Co., Inc. (Schwab), a registered broker-dealer, member SIPC, as the qualified custodian. We are independently owned and operated and are not affiliated with Schwab. We also recommend the brokerage and custodial services of Sanders Morris Harris (“SMH”), member FINRA/SIPC. SMH is an unaffiliated SEC-registered broker-dealer and FINRA member. Research and Other Soft Dollar Benefits Our firm has an arrangement with Charles Schwab & Co., Inc. (“Schwab”), registered broker dealer, Members SIPC which provides our firm with Schwab “platform” services. The platform services include, among others, brokerage, custodial, administrative support, record keeping and related services that are intended to support our firm in conducting business and in serving the best interests of our clients but that can benefit our firm. However, the receipt of those materials is not tied to the execution of client transactions. The Adviser seeks to select broker-dealers based upon the broker’s or dealer’s ability to provide best execution, and the Adviser will not cause clients to pay commissions (or markups or markdowns) higher than those charged by other broker-dealers for the purpose of obtaining soft dollar benefits. Some of the products and services that qualify as “brokerage or research services” under Section 28(e) of the Securities Exchange Act of 1934 (“Exchange Act”). This is commonly referred to as a “soft dollar” arrangement. The Adviser could from time to time receive generic market commentaries, market research, or transition support from broker-dealer firms. Brokerage for Client Referrals We receive no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. Your Brokerage and Custody Costs We recommend the brokerage and custodial services of Schwab Advisor Services division of Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. The final decision to custody assets with Schwab is at the discretion of our clients, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. We are independently owned and operated and not affiliated with Schwab. Schwab provides us with access to its institutional Form ADV Part 2 Brochure You can obtain a current copy of the Form CRS at http://www.orgpag.com. Page 17 of 24 trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to advisors. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. Our firm and/or our supervised persons receive benefits. Schwab also makes available to ORG other products and services that benefit us but on occasion do not benefit our clients’ accounts. These benefits can include national, regional or ORG specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits can include occasional business entertainment of personnel of ORG by Schwab Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which can accompany educational opportunities. Other of these products and services assist us in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of ORG’s fees from its clients’ accounts, and assist with back- office training and support functions, recordkeeping, and client reporting. Many of these services generally, can be used to service all or some substantial number of ORG’s accounts, including accounts not maintained at Schwab Advisor Services. Schwab Advisor Services also makes available to ORG other services intended to help ORG manage and further develop its business enterprise. These services include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance, and marketing. In addition, Schwab makes available, arranges and/or pays vendors for these types of services rendered to ORG by independent third parties. Schwab Advisor Services can discount or waive fees they would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to ORG. Sanders Morris Harris: Our firm recommends that clients establish brokerage accounts with the Sanders Morris Harris (“SMH”), a registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. The final decision to custody assets with SMH is at the discretion of the client, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. ORG is independently owned and operated and not affiliated with SMH. SMH provides ORG with access to trading and custody services, which are typically not available to SMH retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to advisors. SMH’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. SMH also makes available to ORG other products and services that benefit ORG but do not always benefit its clients’ accounts. These benefits can include national, regional or ORG specific educational Form ADV Part 2 Brochure You can obtain a current copy of the Form CRS at http://www.orgpag.com. Page 18 of 24 events organized and/or sponsored by SMH. Other potential benefits can include occasional business entertainment of personnel of ORG by SMH personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which can accompany educational opportunities. While, as a fiduciary, we endeavor to act in our clients’ best interests, our recommendation that clients maintain their assets in accounts at Schwab/SMH can be based in part on the benefit to ORG of the availability of some of the foregoing products and services and other arrangements and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab/SMH, which creates a potential conflict of interest. Brokerage for Client Referrals We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. Our affiliate, Ascentis Asset Management, does have a fee sharing agreement with SMH that allows that entity to receive a share of the revenue that SMH earns from margin loan spreads and remarketing fees from money market-sweep products generated by clients referred to SMH. Although ORG does not receive compensation directly, this fee sharing agreement does benefit our affiliate and as such creates a conflict when we refer to clients to SMH. Directed Brokerage The Adviser will comply with any guidelines and/or limitations reasonably requested by a client relating to brokerage for the client’s account that are contained in the client’s investment management agreement. When possible, the Adviser will also observe any non-binding statement of client preferences with respect to brokerage direction. If a client directs the Adviser to use a particular broker-dealer for execution of the client’s trade orders (a “directed brokerage arrangement”), and the Adviser agrees to the arrangement, a client should understand that the Adviser could be unable to achieve best execution for the client’s transactions. Any costs related to the directed brokerage arrangement are not included in the Adviser’s fee, and the client is solely responsible for monitoring, evaluating, and reviewing the arrangement with the directed broker- dealer and paying any commissions or markups or markdowns or other costs imposed by the directed broker-dealer. Additionally, the Adviser generally will not aggregate the client’s directed brokerage trade orders with orders for other clients of the Adviser or include such orders in its trade rotation process. If the Adviser aggregates a client’s directed brokerage trade orders with trade orders for other clients of the Adviser, the Adviser can employ the use of “step-outs” to satisfy the client’s directed brokerage arrangement. A “step-out” occurs when an executing broker executes the trade and then “steps out” the trade to a clearing broker (which would be the directed broker-dealer in a directed brokerage arrangement) that confirms and settles the trade. In such a case, a client will bear the costs of any commissions, markups or markdowns imposed by the executing broker-dealer in addition to the costs of any commissions, markups or markdowns imposed by the directed broker-dealer. If a client directs the Adviser to use a particular broker-dealer, and if the particular broker-dealer referred the client to the Adviser or if the particular broker-deal refers other clients to the Adviser in the future, the Adviser can benefit from the client’s directed brokerage arrangement. Because of these potential benefits, the Adviser will have an economic interest in having the client continue the directed brokerage arrangement. The benefits that the Adviser receives can conflict with the client’s interest in having the Form ADV Part 2 Brochure You can obtain a current copy of the Form CRS at http://www.orgpag.com. Page 19 of 24 Adviser recommend that the client utilize another broker-dealer to execute some or all transactions for the client’s account. Before directing the Adviser to use a particular broker-dealer, a client should carefully consider the possible costs or disadvantages of directed brokerage arrangements. B. Trade Errors The Firm nor its Advisors will share in any gains resulting from the trade error. The Custodians Charles Schwab is in the practice of donating trade error gains to a charity of their choice. Should the trade error result in a loss, the Firm will charge back the losses to the Advisor. C. Order Aggregation, Allocation, and Rotation Practices In order to seek best execution for clients, the Adviser can aggregate contemporaneous buy and sell orders for the accounts over which it has discretionary authority. This practice of bunching trades enables the Adviser to obtain more favorable execution, including better pricing and enhanced investment opportunities, than would otherwise be available if orders were not aggregated. Bunching transactions cal also assist the Adviser in potentially avoiding an adverse effect on the price of a security that could result from simultaneously placing a number of separate, successive, or competing, client orders. It is within the Adviser’s sole discretion to bunch transactions and its decision is subject to its duty to seek best execution. The Adviser will aggregate a client’s trade orders only when the Adviser deems it to be appropriate and in the best interests of the client and permitted by regulatory requirements. All advisory clients participating in a bunched transaction will receive the same execution price for the security bought or sold. Average prices can be used when allocating purchases and sales to a client’s accounts because such securities are be purchased and sold at different prices in a series of bunched transactions. As a result, the average price received by a client could be higher or lower than the price the client would have received had the transaction been affected for the client independently from the bunched transaction. In addition, a client’s transaction costs can vary depending upon, among other things, the type of security bought or sold, and the commission or markup or markdown charged by the executing broker-dealer. The number of securities available in the marketplace, at a particular price at a particular time, on occasion, will not satisfy the needs of all clients participating in a bunched transaction and can be insufficient to provide full allocation across all client accounts. To address this possibility, the Adviser has adopted trade allocation policies and procedures that are designed to make securities allocations to discretionary client accounts in a manner such that all such clients receive fair and equitable treatment. If a bunched transaction cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day will generally be allocated pro rata among the clients participating in the bunched transaction. Adjustments to this pro rata allocation can be made, at the discretion of the Adviser, to take into consideration account specific investment restrictions, undesirable position size, account portfolio weightings, client tax status, client cash positions and client preferences. Adjustments can also be made to avoid a nominal allocation to client accounts. When the Adviser is not able to aggregate trades, the Adviser generally uses a trade rotation process that is designed to be fair and equitable to its clients. Form ADV Part 2 Brochure You can obtain a current copy of the Form CRS at http://www.orgpag.com. Page 20 of 24 Item 13 Review of Accounts A. Periodic Reviews IARs are required to conduct quarterly reviews of client statements to ensure 1) the statement is alignment with the Investor Advisory Agreement and agreed contractual fee schedule, 2) the clients’ accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. On an annual basis, ORG monitors client accounts to ensure IARs are adhering to the requirements noted above. ORG does not provide written reports to clients, however, IARs can create consolidated-performance statements. It is important to note the custodian’s statements supersede any reports generated by your IAR. We can review client accounts more frequently than described above. Among the factors that will trigger an off-cycle review include major market or economic events, the client’s life events, or requests by the client. Investment Consulting clients receive reviews of their pension plans for the duration of the pension consulting service. We also provide ongoing services to Consulting clients where we meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. Retirement and Pension Consulting clients do not receive written or verbal updated reports regarding their pension plans unless they choose to contract with us for ongoing Pension Consulting services. Financial Planning clients do not receive reviews of their written plans unless they take action to schedule a financial consultation with us. We do not provide ongoing services to financial planning clients, but are willing to meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. Financial Planning clients do not receive written or verbal updated reports regarding their financial plans unless they separately contract with us for a post-financial plan meeting or update to their initial written financial plan. Client Referrals and Other Compensation Item 14 A. Other Compensation Charles Schwab & Co., Inc. As stated above, we recommend that clients establish brokerage accounts with the Schwab Advisor Services division of Charles Schwab & Co., Inc. (“Schwab”), to maintain custody of clients’ assets and to effect trades for their accounts. The final decision to custody assets with Schwab is at the discretion of our clients, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. Schwab provides us with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to advisors. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. Schwab also makes available to ORG other products and services that benefit us but on occasion do not benefit our clients’ accounts. These benefits can include national, regional or ORG specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits can include occasional business entertainment of personnel of ORG by Schwab Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which can accompany educational opportunities. Form ADV Part 2 Brochure You can obtain a current copy of the Form CRS at http://www.orgpag.com. Page 21 of 24 Other of these products and services assist us in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of ORG’s fees from its clients’ accounts, and assist with back office training and support functions, recordkeeping and client reporting. Many of these services generally can be used to service all or some substantial number of ORG’s accounts, including accounts not maintained at Schwab Advisor Services. Schwab Advisor Services also makes available to ORG other services intended to help ORG manage and further develop its business enterprise. These services can include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance, and marketing. In addition, Schwab can make available, arrange and/or pay vendors for these types of services rendered to ORG by independent third parties. Schwab Advisor Services can reserve the right to discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third- party providing these services to ORG. While, as a fiduciary, we endeavor to act in our clients’ best interests, our recommendation that clients maintain their assets in accounts at Schwab can be based in part on the benefit to ORG of the availability of some of the foregoing products and services and other arrangements and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which creates a potential conflict of interest. Sanders Morris Harris As stated above, we recommend that clients establish brokerage accounts with Sanders Morris Harris. (“SMH”), a registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to affect trades for their accounts. The final decision to custody assets with SMH is at the discretion of our clients, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. We are independently owned and operated and not affiliated with SMH. SMH provides us with access to its trading and custody services, which are typically not available to retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to advisors. SMH’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. SMH also makes available to ORG other products and services that benefit us but on occasion do not benefit our clients’ accounts. These benefits can include national, regional or ORG specific educational events organized and/or sponsored by SMH Services. Other potential benefits can include occasional business entertainment of personnel of ORG by SMH, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which can accompany educational opportunities. Other of these products and services assist us in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and Form ADV Part 2 Brochure You can obtain a current copy of the Form CRS at http://www.orgpag.com. Page 22 of 24 allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of ORG’s fees from its clients’ accounts, and assist with back office training and support functions, recordkeeping and client reporting. Many of these services generally can be used to service all or some substantial number of ORG’s accounts, including accounts not maintained at SMH. SMH also makes available to ORG other services intended to help ORG manage and further develop its business enterprise. These services can include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance, and marketing. In addition, SMH can make available, arrange and/or pay vendors for these types of services rendered to ORG by independent third parties. SMH reserves the right to discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third- party providing these services to ORG. While, as a fiduciary, we endeavor to act in our clients’ best interests, our recommendation that clients maintain their assets in accounts at SMH can be based in part on the benefit to ORG of the availability of some of the foregoing products and services and other arrangements and not solely on the nature, cost or quality of custody and brokerage services provided by SMH, which creates a potential conflict of interest. Platforms Client accounts are generally managed via third-party investment management platforms (“Platforms”). Platforms are paid a fee based on the amount of client assets on the Platform (“Platform Fee”). ORG, or our affiliates, receives a portion of the Platform Fee. The Platform Fee is higher as a result of our receipt of a portion of the Platform Fee and clients are able to access Platforms through other investment advisers at a lower fee. Clients can be responsible for paying the Platform Fee as described in the investment management agreement. Clients should review the investment management agreement to determine if they are responsible for paying the Platform Fee. This fee is in addition to the compensation we receive for our advisory services described in Item 5. Fees reduce returns over time. This creates a conflict of interest as we have an incentive to recommend Platforms based on our receipt of a portion of the Platform Fee rather than the best interests of the client. We have reviewed and periodically review Platforms that we recommend and believe that the use of such Platforms is in the best interest of clients. As of the date of this Brochure, we utilize Envestnet and Liberty Fi as Platforms. Advisor Credit Exchange Platform (“ACx”) ORG Partners participates on the Advisor Credit Exchange platform (“ACx”) presented by the Advisor Credit Exchange, LLC (“ACE”). The ACx platform is made available by ACE to certain Advisors, and Participating Lenders and their respective authorized users to enable matching and pre-qualification of Advisor Clients with Participating Lenders based on Participating Lenders’ credit criteria, along with such other features and functionality as are be offered by ACE from time to time. This presents a conflict of interest because ACE agrees to pay the Advisor a fee for each loan referred through ACx; this arrangement presents a conflict of interest and gives the Advisor an incentive to recommended participating lenders based on the compensation received. Clients have the option to search for participating lenders through other channels not affiliated with us. B. Referrals ORG Partners can provides compensation to individuals who refer clients in some instances. When applicable, the compensation paid is a percentage of the client’s fee payments or the value of the client’s Form ADV Part 2 Brochure You can obtain a current copy of the Form CRS at http://www.orgpag.com. Page 23 of 24 account. The amount of compensation will vary, with the specific level determined based upon consideration of various factors. ORG Partners can pay these fees to unaffiliated solicitors with which they have entered into a written agreement. Custody Item 15 Pursuant to Rule 206(4)-2 under the Advisers Act, because we can directly deduct advisory fees from client accounts as part of our billing process, we are deemed to have limited custody of client funds. The qualified custodian you hold your assets with maintains actual custody of your assets. You will receive account statements directly from the custodian at least Quarterly. They will be sent to the email or postal mailing address you provided to the custodian. You should carefully review those statements promptly when you receive them. Investment Discretion Item 16 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, we are authorized to execute securities transactions including the selection and amount of securities to be purchased or sold for your account(s) without obtaining your consent or approval prior to each transaction. Limitations can be imposed by the client in the form of specific constraints on any of these areas of discretion with our firm's written acknowledgment. If a client enters into non-discretionary arrangements with ORG, we will obtain your approval prior to the execution of any transactions for your account(s). Clients have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. Voting Client Securities Item 17 We do not and will not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, we will forward them on to you and ask the party who sent them to mail them directly to you in the future. Clients can call, write, or email us to discuss questions they have about particular proxy votes or other solicitations. Financial Information Item 18 ORG Partners does not require the prepayment of more than $1,200 in fees and for more than six months in advance, does not take custody of client funds or securities and does not have a financial condition that is likely to impair our ability to meet our commitments to our clients. Form ADV Part 2 Brochure You can obtain a current copy of the Form CRS at http://www.orgpag.com. Page 24 of 24

Additional Brochure: ORG PARTNERS WRAP BROCHURE (2025-08-27)

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Item 1 Cover Page Wrap Fee Program Brochure ORG Partners, LLC 5001 Spring Valley Rd, Suite 810W Dallas, TX 75244 August 2025 This wrap fee program provides information about the qualifications and business practices of ORG Partners, LLC. If you have any questions about the contents of this brochure, please contact our Chief Compliance Officer, Matthew Reynolds, at matthew.reynolds@orgpag.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about ORG Partners is also available on the SEC’s website at www.adviserinfo.sec.gov. References herein to ORG Partners, LLC as a “registered investment adviser” or any reference to being “registered” does not imply a certain level of skill or training. Page 1 of 16 Wrap Fee Program Brochure You may obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. Item 2 Material Changes Since our amended filing with the SEC in March 2025, the following material changes have been made to this brochure: • ORG affiliations include Ascentis Asset Management, LLC (CRD #318126), Ascentis Wealth Management, LLC (CRD #330923) and Golden State Equity Partners, LLC (CRD #322879) through common ownership. The Firm’s ownership structure has changed, with Michael Mansur having the largest individual Ownership position in Ascentis Operations, LLC, the holding company of ORG Partners, LLC through a private Irrevocable Trust. • The Chief Compliance Officer was updated from Justine Kidwell to Matthew Reynolds. • The firm’s home office was moved to 5001 Spring Valley Rd, 810W, Dallas, TX 75244 Page 2 of 16 Wrap Fee Program Brochure You may obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. Table of Contents Item 3 Contents Item 1 Cover Page ................................................................................................................................. 1 Item 2 Material Changes ....................................................................................................................... 2 Item 3 Table of Contents ....................................................................................................................... 3 Item 4 Services, Fees and Compensation ............................................................................................... 4 A. Description of Services .................................................................................................................... 4 B. Contribution Cost Factors ................................................................................................................ 4 C. Additional Fees ................................................................................................................................ 5 D. Compensation of Client Participation .............................................................................................. 5 Item 5 Account Requirements and Types of Clients ............................................................................... 5 Item 6 Performance-Based Fees and Side-By-Side Management ........................................................... 5 A. Selecting/Reviewing Portfolio Managers .......................................................................................... 5 B. Related Persons .............................................................................................................................. 6 C. Advisory Business ........................................................................................................................... 6 Item 7 Client Information Provided to Portfolio Managers.................................................................. 11 Item 8 Client Contact with Portfolio Manager ...................................................................................... 11 Item 9 Additional Information ............................................................................................................. 12 A. Disciplinary Action and Other Financial Industry Activities ............................................................ 12 B. Code of Ethics, Client Referrals, and Financial Information ........................................................... 13 Page 3 of 16 Wrap Fee Program Brochure You may obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. Services, Fees, and Compensation Item 4 A. Description of Services ORG Partners, LLC (“ORG”) participates in, and sponsors wrap fee programs, which means ORG will wrap transaction fees for wrap fee portfolio management accounts. ORG will charge clients one fee and pay all transaction fees using the fee collected from the client. Accounts participating in the wrap fee program are not charged higher advisory fees based on trading activity, but clients should be aware that ORG has an incentive not to place transaction orders in those accounts since doing so increases its transaction costs. Thus, an incentive exists to place trades less frequently in a wrap fee arrangement. Certain other fees are not included in the wrap fee and are paid for separately by the client. These fees include but are not limited to custodial fees, charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), mark-ups, mark- downs, spreads paid to market makers, fees for trades executed away from the custodian, wire transfer fees, other fees and taxes on brokerage accounts and securities transactions. These fees are not included in the wrap fee you are charged by our firm. The fee schedule is set forth below: Total Assets Under Management All Assets Annual Fees Up to 2.00% These fees are negotiable depending upon the needs of the client and complexity of the situation, the final fee schedule will be reflected in the advisory contract. Advisory fees are either based off the market value on the last day of the previous quarter or assessed quarterly based on the average daily value of the Portfolio assets over the previous calendar quarter. Refer to specific client agreement for agreed calculation details. After ORG pays transaction fees, ORG generally receives around 90% of the advisory fee. Advisory fees are withdrawn directly from the client’s accounts with client written authorization. Fees are paid quarterly in advance. Refunds are given on a prorated basis, based on the number of days remaining in the billing period on the effective date of termination. The fee refunded will be the balance of the fees collected in advance minus the daily rate* times the number of days in the billing period up to and including the effective date of termination. (*The daily rate is calculated by dividing the annual fee by 365.) Clients can terminate the contract without penalty, for a full refund, within five business days of signing the contract. Thereafter, clients can terminate the contract with thirty days’ written notice. B. Contribution Cost Factors The program can cost the client more or less than purchasing such services separately. There are several factors that bear upon the relative cost of the program, including the trading activity in the client’s account, the adviser’s ability to aggregate trades, and the cost of the services if provided separately (which in turn depends on the prices and specific services offered by different providers). C. Additional Fees Clients who participate in the wrap fee program will not have to pay for transaction or trading fees. However, clients are still responsible for all other account fees, such as certain charges imposed by custodians, brokers, and other third parties such as custodial fees, annual IRA fees, transition fees if the account is moved to another broker, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Also, clients will pay the following separately incurred expenses: charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund's prospectus (i.e., fund management fees and other fund expenses). Clients Wrap Fee Program Brochure Page 4 of 16 You can obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. are sometimes responsible for paying fees charged by sub-advisers, money managers, platforms, and/or platform managers that have been engaged to manage their account as described in the investment management agreement. Such charges, fees, and commissions are exclusive of, and in addition to, our fee. ORG, or our affiliate, receives a portion of fees charged by Platforms. D. Compensation of Client Participation ORG does not receive any additional compensation beyond advisory fees for the participation of clients in the wrap fee program. However, compensation received can be more than what would have been received if client paid separately for investment advice, brokerage, and other services. Therefore, ORG sometimes has a financial incentive to recommend the wrap fee program to clients. Some affiliates of ORG are also associated with ORG in the capacity of investment advisor representative. ORG does receive fees beyond participation in a Wrap Fee Program. ORG receives a portion of the platform fee paid for clients on the platform. Item 5 Account Requirements and Types of Clients ORG generally provides its wrap fee program services to the following types of clients: Individuals • • High-Net-Worth Individuals • Pension and Profit-Sharing Plans • Trusts, Estates, or Charitable Organizations ORG Partners does not impose an account minimum. Performance-Based Fees and Side-By-Side Management Item 6 A. Selecting/Reviewing Portfolio Managers ORG is the only manager and sponsor in its wrap fee program. Accounts in the wrap fee program are managed by the Advisor. ORG will sometimes select outside portfolio managers for management of this wrap fee program by hiring sub-advisers. ORG has the ability to hire and fire any sub-advisers. As part of ORG’s asset management services, ORG will often invest your assets or recommend the investment of your assets according to one or more model portfolios developed by Ascentis Asset Management, LLC, an affiliate. In some cases, ORG will deviate or recommend a deviation from Ascentis Asset Management, LLC. models depending on individual client circumstances. With respect to discretionary accounts, ORG will monitor your portfolio's performance on an ongoing basis and attempt to rebalance the portfolio as required by changes in market conditions and in your financial circumstances. Standards Used to Calculate Portfolio Manager Performance: ORG reviews the performance information to determine and verify its accuracy and compliance with industry standards. The performance information is reviewed quarterly and is reviewed by ORG. B. Related Persons ORG and its personnel serve as the portfolio managers for all wrap fee program accounts. This is a conflict of interest in that no outside adviser assesses ORG’s management of the wrap fee program. However, ORG addresses this conflict by acting in its clients’ best interest consistent with its fiduciary duty as sponsor and portfolio manager of the wrap fee program. ORG will sometimes hire sub-advisers for portfolio management services. ORG has engaged Ascentis Asset Management, an affiliate, as the sub- adviser for certain accounts. Ascentis Asset receives a management fee as a result of the sub-advisory services provided to clients. This fee can be paid for by the client as outlined in the investment advisory agreement. ORG only recommends Ascentis Asset to clients when ORG believes it is in the best interest of the client. Additionally, as of the date of this Brochure, Ascentis Asset does not receive a management or sub advisory fee Wrap Fee Program Brochure Page 5 of 16 You can obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. with respect to the sub advisory services it provides to ORG. You are not obligated, contractually or otherwise, to utilize any Ascentis Asset service or invest in any Ascentis Asset product. C. Advisory Business ORG offers portfolio management services to its wrap fee program participants as discussed in Section 4 above. Wrap Fee Portfolio Management: ORG offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. ORG advisors collect information from each client regarding their investment objectives, goals, and guidelines and then construct a plan to aid in the selection of a portfolio that matches each client’s specific situation. ORG manages the client’s assets with the goal of meeting the objectives set by the client. Portfolio management accounts participating in the wrap fee program will not have to pay for transaction or trading fees. ORG will charge clients one fee and pay transaction fees using the advisory fee collected from the client. However, clients are still responsible for all other account fees, such as certain charges imposed by custodians, brokers, and other third parties such as custodial fees, annual IRA fees, transition fees if the account is moved to another broker, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Also, clients will pay the following separately incurred expenses: charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund's prospectus (i.e., fund management fees and other fund expenses). Clients, in certain instances, will be responsible for paying fees charged by sub-advisers, money managers, platforms, and/or platform managers that have been engaged to manage their account as described in the investment management agreement. Such charges, fees, and commissions are exclusive of, and in addition to, our fee. ORG, or our affiliate, receives a portion of the fees charged by Platforms. Accounts participating in the wrap fee program are not charged higher advisory fees based on trading activity, but clients should be aware that ORG has an incentive to limit trading activities for those accounts since the firm absorbs those transaction costs. To address this conflict, ORG will always act in the best interest of its clients consistent with its fiduciary duty as an investment adviser. Performance-Based Fees and Side-By-Side Management: ORG does not accept performance-based fees or other fees based on a share of capital gains or capital appreciation of the assets of a client. Services Limited to Specific Types of Investments: We primarily offer advice on a variety of investment options including mutual funds, exchange traded funds, and other securities, we also recommend private equity funds or private placements securities, and will sometimes utilize sub-advisers, however we do not limit our advice to any particular investment strategies or securities. You can request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing. Restrictions on investments in certain securities or types of securities are not always possible due to the level of difficulty this would entail in managing the account. Client Tailored Services and Client Imposed Restrictions: ORG offers the same suite of services to all its clients. However, specific client financial plans and their implementation are dependent upon each client’s current situation (income, tax levels, and risk tolerance levels). Clients can impose restrictions on investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent ORG from properly servicing the client account, or if the Wrap Fee Program Brochure Page 6 of 16 You can obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. restrictions would require ORG to deviate from its standard suite of services, ORG reserves the right to end the relationship. Wrap Fee Programs: ORG is the only manager and sponsor in its wrap fee program. Accounts in the wrap fee program are managed by ORG’s portfolio management team. These individuals also manage other accounts of ORG. ORG will sometimes select outside portfolio managers for management of this wrap fee program by hiring sub-advisers. ORG has the ability to hire and fire any sub-advisers. ORG has engaged Ascentis Asset Management, an affiliate, as the sub-adviser for wrap fee program accounts. Some accounts can be managed differently than non-wrap fee accounts. The fees paid to the wrap account program will be given to ORG and/or sub-advisers as a management fee depending on the client’s investment management agreement. Methods of Analysis and Investment Strategies: This section provides an overview of methods of analysis and investment strategies we utilize in providing services to you and certain material risks relating that you sometimes face in connection with these services. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. It is not possible to identify all of the risks associated with investing, and this section does not attempt to discuss all the risks that can affect your investments with ORG. Rather, this section discusses certain material risks of ORG’s investment activities. Different risks will impact different investment strategies to different degrees, and the degree to which a particular risk is applicable to you will depend on a variety of factors, including which investment strategy(ies) are employed with respect to your account and your investment guidelines. We do not guarantee that an investment objective or planning goal will be achieved or that any of the investment strategies will create their intended results. As an investor, each client must be able to bear the risk of loss that is associated with their account, which can include the loss of some, or all principal invested. No single investment strategy, or combination thereof, is necessarily diversified or intended to provide a complete investment program. Clients are responsible for appropriately diversifying their assets to guard against the risk of loss. You are responsible for your overall financial situation, and we urge you to consult legal, tax and other financial advisors regarding your specific or overall financial situation as needed. In particular, our strategies and investments can have unique and significant tax implications. We will generally attempt to structure your portfolio in the most tax efficient manner possible based on your accounts under our management. However, unless we specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the management of your assets. Regardless of your account size or any other factors, we strongly recommend that you continuously consult with a tax professional prior to and throughout the investing of your assets. Our investment strategies and advice will vary depending upon each client’s specific financial situation. As such, we determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial horizon, financial information, liquidity needs, and other various suitability factors. Your restrictions and guidelines will affect the composition and performance of your portfolio. The following methods of analysis or investment strategies when providing investment advice to you can include but are not limited to: Fundamental analysis is a method of evaluating a company that has issued a security by attempting to measure the value of its underlying assets. It entails studying overall economic and industry conditions, as well as the financial condition and the quality of the company’s management. ORG considers earnings, expenses, assets, and liabilities important in determining the value of a company. We then compare the value of the company to the current price of the issuing company's security to determine whether to purchase, sell or hold the security. Wrap Fee Program Brochure Page 7 of 16 You can obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. One of the primary risks of fundamental analysis is that information obtained can be incorrect and the analysis does not always provide an accurate estimate of earnings, which can be the basis for ORG’s valuation of a security. If securities prices adjust rapidly to new information, utilizing fundamental analysis does not always result in favorable performance. Cyclical analysis is a form of fundamental analysis that involves the process of making investment decisions based on the different stages of an industry at a given point in time. One of the primary risks of cyclical analysis is the lengths of economic cycles can be difficult to predict with accuracy, which leads to difficulty in predicting economic trends and consequently the changing value of securities that would be affected by these changing trends. Quantitative Analysis is a method of determining the value of a security by examining its numerical, measurable characteristics such as revenues, earnings, margins, and market share. One of the primary risks of quantitative analysis is that empirical data is not always the best indicator of the value of certain investments, and purely mathematical approaches sometimes do not reveal significant security specific developments. Charting involves identifying patterns that can suggest future activity in price movements. A chart pattern is a distinct formation on a stock chart that creates a trading signal or a sign of future price movements. Chartists use these patterns to identify current trends and trend reversals to trigger buy and sell signals. Some of the chart types that ORG utilizes are Line Charts, Bar Charts, Candlestick, Point and Figure, etc. One of the primary risks of charting analysis is that it does not always accurately detect anomalies or predict future price movements. Current prices of securities can reflect all the information known about the security and day-to-day changes in market prices of securities can follow random patterns and are not predictable with any reliable degree of accuracy. Technical analysis is a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security's intrinsic value, but instead use charts and other tools to identify patterns that can suggest future activity. One of the primary risks of market timing based on technical analysis is that our analysis will not always accurately detect anomalies or predict future price movements. Current prices of securities can reflect all the information known about the security and day-to-day changes in market prices of securities can follow random patterns and are not predictable with any reliable degree of accuracy. Long-Term Purchases – securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which is not always the case. There is also the risk that the segment of the market that you are invested in or perhaps just your particular investment will go down over time even if the overall financial markets advance. Purchasing investments long-term can create an opportunity cost - “locking-up” assets that are sometimes better utilized in the short-term in other investments. Short-Term Purchases – securities purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of short-term price fluctuations. Using a short-term purchase strategy generally assumes that one can predict how financial markets will perform in the short-term, Wrap Fee Program Brochure Page 8 of 16 You can obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. which is often very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. There are many factors that can affect financial market performance in the short term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but sometimes have a smaller impact over longer periods of times. Short Sales – securities transactions in which securities are sold that were borrowed in anticipation of a price decline. The seller is then required to return an equal number of shares at some point in the future. The primary risk of short selling is that client assets invested through a short sale will profit if the stock goes down in price, but if the price of the shares increase, the potential losses are unlimited. We sometimes use short-term trading (in general, selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Short-term trading is not a fundamental part of our overall investment strategy, but we do use this strategy occasionally when we determine that it is suitable given your stated investment objectives and tolerance for risk. This can include buying and selling securities frequently in an effort to capture significant market gains and avoid significant losses. However, there is a risk that frequent trading can negatively affect investment performance, particularly through increased brokerage and other transactional costs and taxes. Margin Transactions – a securities transaction in which an investor borrows money to purchase a security, in which case the security serves as collateral on the loan. The primary risk of trading on margin is that if the value of the shares drops sufficiently, the client will be required to either deposit more cash into the account or sell a portion of the stock in order to maintain the margin requirements of the account. This is known as a "margin call." This could result in a client account losing more money than was invested in the margin transaction. Options Trading - a securities transaction that involves buying or selling (writing) an option. If you write an option, and the buyer exercises the option, you are obligated to purchase or deliver a specified number of shares at a specified price at the expiration of the option regardless of the market value of the security at expiration of the option. Buying an option gives you the right to purchase or sell a specified number of shares at a specified price until the date of expiration of the option regardless of the market value of the security at expiration of the option. Trading of options can be highly speculative and often entails more risk than those present when investing in other types of securities. Prices of options are generally more volatile than prices of other types of securities. When trading in options, you run the risk of losing the entire investment in a relatively short period of time. In more risky options strategies, an investor could theoretically have an unlimited risk of loss. Management Risk: Judgements about the value and potential appreciation of a particular security can be wrong and there is no guarantee that securities will perform as anticipated. The value of a security can be more volatile than the market as a whole or our approach can fail to produce the intended results, which can result in losses for a client. Market Risk: There is a possibility that the value of securities decline due to daily fluctuations in the markets. Stock prices change daily as a result of many factors, including developments affecting the condition of both individual companies and the market in general. In a declining stock market, prices for all companies can decline regardless of their long-term prospects. Business, Terrorism and Catastrophe Risks: Investments are subject to the risk of loss arising from the occurrence of various events, including hurricanes, earthquakes, and other natural disasters, terrorism, and other catastrophic events such as a pandemic. These catastrophic risks of loss can be substantial and could have a material adverse effect on our business and clients’ portfolios. Wrap Fee Program Brochure Page 9 of 16 You can obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. Risk of Loss: Investing in securities involves a risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market peaks or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past performance is in no way an indication of future performance. Recommendation of Particular Types of Securities: Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus investors can lose money investing in mutual funds. All mutual funds have cost that lower investment returns. Mutual funds are also subject to extensive regulatory regimes, which can restrict their investments and result in lower investment returns than less-regulated investments. Equity: investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed Income Securities: Investments in fixed income securities are subject to credit, liquidity, prepayment, and interest rate risks, any of which can adversely impact the price of the security and result in a loss. The municipal market can be significantly affected by adverse tax, legislative or political changes and the financial condition of the issuers of municipal securities. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks, and their price can fluctuate during the day. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically can be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. The returns on ETFs can be reduced by the costs of managing the funds. During a time of extreme market volatility ETF pricing can lag vs. the actual underlying asset values. This lag usually resolves itself in a short period of time (usually less than one day) however there is no guarantee this relationship will always occur. In addition, for certain ETFs recommended by us, there is sometimes little public market due to trading volumes or other factors. Accordingly, clients are not always able to sell the ETFs as desired. Real estate: funds (including REITs) face several kinds of risks that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows can be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Wrap Fee Program Brochure Page 10 of 16 You can obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. Private Equity (PE) Funds and Private placement Securities Risks are inherently illiquid; they cannot be easily sold or exchanged for cash without a substantial loss in value. Investors are usually required to commit their capital for extended periods. Private equity funds typically charge high fees, including management fees and performance fees (carried interest). These fees can erode returns, especially if the fund's performance does not meet expectations. Private Equity funds are subject to higher degrees of risk and are not be suitable for all investors. Their performance is heavily dependent on the skill and experience of the management team. Private equity funds commonly use leverage (borrowed funds) to enhance returns, which can increase the potential for significant losses, especially in downturns. In addition, Private Equity investments often lack transparency. Detailed information about the fund's operations and investments is not readily available, making it challenging to evaluate the valuations of private companies. Private Placement Securities have similar characteristics and carry risks akin to those of Private Equity Funds. However, Private Placements are typically offered to institutional clients or accredited investors. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you should be prepared to bear. Voting Client Proxies: ORG does not and will 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 ORG’s office, ORG will forward them to the client and ask the party who sent them to mail them directly to the client in the future. Clients can call, write, or email ORG to discuss questions they have about particular proxy votes or other solicitations. Client Information Provided to Portfolio Managers Item 7 ORG gathers information such as guidelines, restrictions, and suitability as part of the account opening process. This information (including basic information, risk tolerance, sophistication level, and income level) is provided to the portfolio manager. The portfolio manager will also have access to that information as it changes and is updated. Client Contact with Portfolio Manager Item 8 ORG places no restrictions on a client’s ability to contact its portfolio managers. Clients can contact ORG to arrange for a consultation regarding the management of their account. ORG portfolio managers are available at reasonable times to participate in consultations that clients request. Additional Information Item 9 A. Disciplinary Action and Other Financial Industry Activities Criminal or Civil Actions: There are no criminal or civil actions to report. Administrative Proceedings: There are no administrative proceedings to report. Self-regulatory Organization Proceedings: There are no self-regulatory organization proceedings to report. Registration as a Broker/Dealer or Broker/Dealer Representative: Some supervised persons of our firm are registered representatives of a broker dealer. These supervised persons offer securities and receive normal and customary commissions as a result of securities transactions. However, supervised persons do not receive any commissions as a result of securities transactions for ORG client accounts. Wrap Fee Program Brochure Page 11 of 16 You can obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. Registration as a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor: Neither ORG nor its representatives are registered as or have pending applications to become a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests through common ownership by Ascentis Operations, LLC has an affiliation with Ascentis Asset Management, an investment advisory firm that is registered with the SEC. Ascentis Asset Management primarily provides outsourced chief investment services to other investment advisers. Supervised persons of ORG are supervised persons of Ascentis Asset Management and will offer clients advice or products from those activities and clients should be aware that these services involve a conflict of interest. Supervised persons must determine the amount of time to dedicate to ORG and Ascentis Asset Management. We have engaged Ascentis Asset Management as the sub-adviser for client accounts. This creates a conflict of interest because we have an incentive to recommend Ascentis Asset Management as the sub-adviser for client accounts. We only recommend Ascentis Asset Management to clients when we believe it is in the best interest of the client. Additionally, as of the date of this Brochure, Ascentis Asset Management does not receive a management or sub advisory fee with respect to the sub advisory services it provides to ORG. You are not obligated, contractually or otherwise, to utilize any Ascentis Asset Management service or invest in any Ascentis Asset Management product. Client accounts are generally managed via third-party investment management platforms (“Platforms”). Platforms are paid a fee based on the amount of client assets on the Platform (“Platform Fee”). ORG, or our affiliates, receives a portion of the Platform Fee. The Platform Fee is higher as a result of our receipt of a portion of the Platform Fee and clients can sometimes access Platforms through other investment advisers at a lower fee. Clients could be responsible for paying the Platform Fee as described in the investment management agreement. Clients should review the investment management agreement to determine if they are responsible for paying the Platform Fee. This fee is in addition to the compensation we receive for our advisory services described in Item 5. Fees reduce returns over time. This creates a conflict of interest as we have an incentive to recommend Platforms based on our receipt of a portion of the Platform Fee rather than the best interests of the client. We have reviewed and periodically review Platforms that we recommend and believe that the use of such Platforms is in the best interest of clients. As of the date of this Brochure, we utilize Envestnet as a Platform. Insurance Agent: Some Representatives of our firm are insurance agents/brokers. A conflict of interest arises as these insurance sales create an incentive to recommend products based on the compensation our supervised persons earn. You are not obligated, contractually or otherwise, to purchase insurance from any representative of ORG. Selection of Other Advisors or Managers and How This Adviser is Compensated for Those Selections. Some supervised persons of our firm recommend other investment advisers for clients and receive compensation from those advisers for the recommendation. This creates a conflict of interest as the supervised person has an incentive to recommend the investment adviser based on compensation received rather than the best interests of the client. All supervised persons receive training regarding, among other things, their fiduciary duty to clients and obligation to make recommendations taking into account only the client’s best interest. Supervised persons are also required to deliver a disclosure document to the client containing the following information: the supervised person’s and recommended investment adviser’s names; the nature of the relationship between the supervised person and the recommended investment adviser, including any affiliation; a statement that the supervised person is compensated by the recommended investment adviser and the terms and description of compensation; and the amount, if any, which will be charged to the client in addition to the advisory fee, as well as other fee information, if applicable. In addition, we sometimes recommend other investment advisers for clients through the selection of sub-advisers, mutual funds, ETFs, Wrap Fee Program Brochure Page 12 of 16 You can obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. and separate account strategies. We do not generally receive compensation related to these recommendations with the exception of Model ETFs and Model Products, as described above. B. Code of Ethics, Client Referrals, and Financial Information Code of Ethics We have adopted a Code of Ethics pursuant to Advisers Act Rule 204A-1. A basic tenet of our Code of Ethics is that the interests of clients are always placed first. The Code of Ethics includes standards of business conduct requiring Access Persons to comply with the federal securities laws and the fiduciary duties an investment adviser owes to its clients. The Code of Ethics also requires that all Access Persons comply with ethical restraints relating to clients and their accounts, including restrictions on gifts and provisions intended to prevent violations of laws prohibiting insider trading. The goal of our Code of Ethics is to ensure personal investing activities by our employees are consistent with our fiduciary duty to our clients. The Code of Ethics includes standards of business conduct requiring Access Persons to comply with the federal securities laws and the fiduciary duties an investment adviser owes to its clients. For purposes of the Code of Ethics, we have determined that all employees are Access Persons. In order to avoid potential conflicts of interest that could be created by personal trading among our Access Persons, the Code of Ethics restricts the purchase and sale by Access Persons for their own accounts of any covered security before the execution of a transaction in any such security for clients. All Access Persons are required to notify our Chief Compliance Officer or his designee of their personal transactions. All Access Persons are required to submit quarterly personal securities transactions and annual holdings reports for review by the Chief Compliance Officer. Access Persons are also required to have copies of all brokerage statements sent to the Chief Compliance Officer, directly from the custodian(s), on, at least, a quarterly basis. The Chief Compliance Officer will maintain documentation of personal securities transactions, including any violations that occur and their resulting actions. The Code of Ethics also requires that all Access Persons comply with ethical restraints relating to clients and their accounts, including restrictions on gifts and provisions intended to prevent violations of laws prohibiting insider trading. Our Code of Ethics is available to you upon request. You can obtain a copy of our Code of Ethics by contacting us at the number on the cover page of this Brochure. As a matter of policy, we do not engage in principal transactions, cross trading, or agency cross transactions. Any exceptions to this policy must be approved in advance by the Chief Compliance Officer or by his designee. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews: IARs are required to conduct quarterly reviews of client statements to ensure 1) the statement is alignment with the Investor Advisory Agreement and agreed contractual fee schedule, 2) the clients’ accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. On an annual basis, ORG monitors client accounts to ensure IARs are adhering to the requirements noted above. ORG does not provide written reports to clients, however, IARs will sometimes create consolidated-performance statements. It is important to note the custodian’s statements supersede any reports generated by your IAR. Factors That Will Trigger a Non-Periodic Review of Client Accounts: We monitor Asset Management accounts on an ongoing basis and conduct an internal review of accounts as part of the firm 206-4 inspection. The nature of our internal reviews is to find out whether clients’ accounts are in line with their investment objectives, appropriately positioned based on market conditions, and Wrap Fee Program Brochure Page 13 of 16 You can obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. investment policies, if applicable. We do not provide written reports to clients, unless asked to do so. Verbal reports to clients take place on at least an annual basis when we contact clients who subscribe to our Asset Management services. We can review client accounts more frequently than described above. Among the factors which can trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. Financial Planning clients do not receive reviews of their written plans unless they take action to schedule a financial consultation with us. We do not provide ongoing services to financial planning clients, but are willing to meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. Financial Planning clients do not receive written or verbally updated reports regarding their financial plans unless they separately contract with us for a post-financial plan meeting or update to their initial written financial plan. Content and Frequency of Regular Reports Provided to Clients: Each client will receive, at least quarterly, from the custodian a written report that details the client’s account including assets held and asset value which will come from the custodian. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) Charles Schwab & Co., Inc.: Our firm recommends that clients establish brokerage accounts with the Schwab Advisor Services division of Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. The final decision to custody assets with Schwab is at the discretion of ORG’s clients, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. ORG is independently owned and operated and not affiliated with Schwab. Schwab provides ORG with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to advisors. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. Schwab has eliminated commissions for online trades of equities, ETFs, and options (subject to $.065 per contract fee). This means that, in most cases, when we buy and sell these types of securities, we will not have to pay any commissions to Schwab. We encourage you to review Schwab’s pricing to compare the total costs of entering a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory services separately. To see what you would pay for transactions in a non-wrap account please refer to Schwab’s most recent pricing schedule available at schwab.com/pricing guide. Schwab also makes available to ORG other products and services that benefit ORG but do not always benefit its clients’ accounts. These benefits can include national, regional or ORG specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits can include occasional business entertainment of personnel of ORG by Schwab Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which sometimes accompany educational opportunities. Other of these products and services assist ORG in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data Wrap Fee Program Brochure Page 14 of 16 You can obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of ORG’s fees from its clients’ accounts, and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally can be used to service all or some substantial number of ORG’s accounts, including accounts not maintained at Schwab Advisor Services. Schwab Advisor Services also makes available to ORG other services intended to help ORG manage and further develop its business enterprise. These services can include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance, and marketing. In addition, Schwab makes available, arranges and/or pays vendors for these types of services rendered to ORG by independent third parties. Schwab Advisor Services will sometimes discount or waive fees if it would otherwise charge for some of these services or pay all or a part of the fees of a third- party providing these services to ORG. While, as a fiduciary, ORG endeavors to act in its clients’ best interests, ORG’s recommendation that clients maintain their assets in accounts at Schwab can be based in part on the benefit to ORG of the availability of some of the foregoing products and services and other arrangements and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which creates a potential conflict of interest. Sanders Morris Harris: Our firm recommends that clients establish brokerage accounts with the Sanders Morris Harris (“SMH”), a registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. The final decision to custody assets with SMH is at the discretion of the client, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. ORG is independently owned and operated and not affiliated with SMH. SMH provides ORG with access to its institutional trading and custody services, which are typically not available to SMH retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to advisors. SMH’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. SMH also makes available to ORG other products and services that benefit ORG but do not always benefit its clients’ accounts. These benefits can include national, regional or ORG specific educational events organized and/or sponsored by SMH. Other potential benefits can include occasional business entertainment of personnel of ORG by SMH personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which can accompany educational opportunities. In addition, our affiliate, Ascentis Asset Management, does have a fee sharing agreement with SMH that allows that entity to receive a share of the revenue that SMH earns from margin loan spreads and remarketing fees from money market-sweep products generated by clients referred to SMH. Although Ascentis does not receive compensation directly, this fee sharing agreement does benefit our affiliate and as such creates a conflict when we refer to clients to SMH. Platforms: Client accounts are generally managed via third-party investment management platforms (“Platforms”). Platforms are paid a fee based on the amount of client assets on the Platform (“Platform Fee”). ORG, or our affiliates, receives a portion of the Platform Fee. The Platform Fee is higher as a result of our receipt of a portion of the Platform Fee and clients are sometimes able to access Platforms through other investment advisers at a lower fee. Clients can be responsible for paying the Platform Fee as described in the investment management Wrap Fee Program Brochure Page 15 of 16 You can obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com. agreement. Clients should review the investment management agreement to determine if they are responsible for paying the Platform Fee. This fee is in addition to the compensation we receive for our advisory services described in Item 5. Fees reduce returns over time. This creates a conflict of interest as we have an incentive to recommend Platforms based on our receipt of a portion of the Platform Fee rather than the best interests of the client. We have reviewed and periodically review Platforms that we recommend and believe that the use of such Platforms is in the best interest of clients. As of the date of this Brochure, we utilize Envestnet as a Platform. Compensation to Non – Advisory Personnel for Client Referrals: ORG has entered an arrangement with Ascentis Asset Management where ORG refers prospective investment adviser representatives to Ascentis Asset Management and Ascentis Asset Management pays ORG a referral fee. The referral fee is equal to a percentage of the asset management fees received from Ascentis Asset Management clients serviced by investment adviser representatives referred by ORG, minus certain expenses that ORG has agreed to share with Ascentis Asset Management. The referral fee paid to ORG does not result in any increase in the advisory fee paid by clients. Balance Sheet: ORG does not require nor solicit prepayment of more than $1,200 in fees per client, six months or more in advance and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither ORG nor its management have any financial conditions that are likely to reasonably impair our ability to meet contractual commitments to clients. Bankruptcy Petitions in Previous Ten Years: ORG has not been the subject of a bankruptcy petition in the last ten years. Wrap Fee Program Brochure Page 16 of 16 You can obtain a current copy of the Form CRS and our Form ADV Part 2 brochure at http://www.orgpag.com.