View Document Text
I T E M 1 – C O V E R P A G E
Prostatis Group LLC dba
Prostatis Financial Advisors Group
7580 Buckingham Blvd., Suite 180
Hanover, MD 21076
Main Telephone No. (410) 863-1040
www.prostatisfinancial.com
April 30, 2026
This brochure provides information about the qualifications and business practices of Prostatis Group, which does business
as Prostatis Financial Advisors Group (“Prostatis”). If you have any questions about the contents of this brochure, please
contact us at (410) 863-1040. The information in this brochure has not been approved or verified by the United States
Securities and Exchange Commission (“SEC”) or by any state securities authority. Prostatis is a Registered Investment
Advisor. Registration as an Investment Advisor with the United States Securities and Exchange Commission or any state
securities authority does not imply a certain level of skill or training.
Additional information about Prostatis is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site
by a unique identifying number, known as an IARD number. The IARD number for Prostatis is CRD #132662.
1
April 2026
Prostatis Financial Advisors Group
e
g
a
P
I T E M 2 - M A T E R I A L C H A N G E S
MATERIAL CHANGES SINCE THE LAST ANNUAL UPDATE
Prostatis Group is established as a Registered Investment Advisor with the Securities and Exchange Commission
(“SEC”), under the rules and regulations of the US Investment Advisers Act of 1940, as amended (the "Advisers
Act"). Prostatis will provide updates to this document annually within 120 days of the close of the fiscal year, or
more frequently in the event of material changes.
There following are material changes made since our last Annual Amendment Filing dated March 28, 2025:
•
ITEM 5: Prostatis’ annual fees are based upon a percentage of assets under management not to
exceed 2.00%. Clients are billed fixed fees for financial planning services that generally range from
$550 to $10,000 based on the range and complexity of the services provided. Fixed fees are
payable in advance and services are generally completed within 120 days of engagement.
Our Firm may charge clients an hourly fee for financial planning and consulting services. Clients
are billed at the rate of $350 an hour. Hourly fees are payable as services are performed and our
Firm will regularly invoice clients for fees that are due and payable.
•
ITEM 8: The following language was added:
USE OF INDEPENDENT MANAGER MODELS USING MACHINE LEARNING
The Firm has limited exposure to the use of artificial intelligence (“AI”) in connection with its
investment activities. The Firm does not internally develop, implement, or rely on AI-driven tools
in the management of client portfolios. To the extent AI is utilized, such use is limited to certain
third-party registered investment advisers / Managers engaged by the Firm, which may
incorporate AI or related technologies within their investment processes. The Firm conducts due
diligence on such Managers consistent with its fiduciary obligations.
Certain investment strategies recommended by the Firm are actively managed and seek to achieve
their investment objectives through the use of proprietary AI-driven models developed and
maintained by independent registered investment advisers (e.g., Ai Funds). These models analyze
a variety of data inputs, including market data, financial reports, and other quantitative and
qualitative information, to identify and evaluate potential investment opportunities. The
effectiveness of such models is dependent on the accuracy, completeness, and timeliness of the
underlying data, as well as the design and ongoing calibration of the model.
To the extent that the AI models do not perform as intended, or if the data inputs are inaccurate,
incomplete, or biased, the strategies may fail to achieve their stated investment objectives and
may experience losses. Additionally, errors in data, calculations, or model construction may occur
and may not be promptly identified or corrected by the Manager, which could adversely impact
performance.
Risks associated with AI-driven investment strategies include, but are not limited to:
o Model risk, including errors in algorithm design, assumptions, or implementation
o Data dependency risk, including reliance on inaccurate, incomplete, or outdated data inputs
o Lack of transparency or explainability of model outputs (“black box” risk)
o Overfitting or poor performance in changing market conditions
o Operational and technology risk, including system failures or processing errors
o Manager risk, including reliance on the controls, oversight, and expertise of the external manager
2
April 2026
Prostatis Financial Advisors Group
e
g
a
P
o Regulatory and compliance risk related to evolving guidance on AI use in investment management
MACHINE LEARNING AND MODEL RISK: The use of machine learning in investment strategies presents both
opportunities and risks. These strategies rely heavily on quantitative models and a wide range of data
sources to make informed decisions. However, when these models and data prove to be incorrect or
incomplete, the resulting decisions can expose clients to substantial risks. For instance, relying on such
models may lead to buying investments at inflated prices, selling them too low, or missing lucrative
opportunities altogether. Moreover, predictive models, which are often used in these strategies, carry
inherent risks, including the potential for inaccurate forecasts, leading to financial losses. Unforeseen
events or low-probability scenarios can also challenge the effectiveness of these models, potentially
resulting in portfolio losses. Machine learning typically is less transparent or interpretable. Furthermore,
because predictive models are usually constructed based on historical data, supplied by third parties or
otherwise, the success of relying on such models may depend on the accuracy and reliability of the
historical data. In all cases, the accuracy and reliability of historical data plays a pivotal role in the success
of these models, underscoring the importance of careful evaluation and risk management in the application
of machine learning to investment recommendations.
RISKS OF USING ARTIFICIAL INTELLIGENCE IN INVESTMENT ACTIVITIES: In line with advances in computing technology
and data analytics, there has been an increasing trend towards utilizing artificial generative intelligence,
large language models, machine learning, artificial neural networks, or similar tools, models and systems
generally referred to as “artificial intelligence” (collectively, “AI”) as part of portfolio management, trading,
portfolio risk management and other applications in the investment management processes used by
various market participants.
ARTIFICIAL INTELLIGENCE RISK - The Firm utilizes certain third-party service providers to support client account
services, some of which incorporate artificial intelligence (“AI”) and machine learning technologies. The use
of these technologies presents inherent risks, including potential data inaccuracies, model bias, and
cybersecurity vulnerabilities. Given the rapid evolution of AI, additional risks may emerge that are not
currently foreseeable. To mitigate these risks, the Firm conducts periodic due diligence on its service
providers to evaluate whether appropriate controls are in place to safeguard client information and
promote the accuracy and reliability of outputs where AI is utilized. In addition, our Firm leverages AI
technologies, including generative AI tools (e.g., GPTs), large language models (LLMs), and machine
learning, to enhance internal administrative efficiency. These tools are used to support functions such as
reporting, data visualization, and workflow automation. The Firm does not rely solely on AI-generated
outputs; rather, such outputs are reviewed and validated by personnel to ensure accuracy, transparency,
and compliance. Our Firm maintains oversight of its AI use to ensure alignment with applicable ethical,
regulatory, and risk management standards, including considerations related to data integrity, model bias,
information security, and privacy. AI is utilized as a supplementary tool to support, but not replace, human
judgment and expertise. To the extent that AI tools are materially incorporated into the Firm’s investment
advisory or financial planning services, the Firm provides appropriate disclosures regarding such use. These
disclosures describe the nature and scope of AI utilization, its inherent limitations, and the Firm’s
supervisory framework, including applicable human-in-the-loop (“HITL”) controls. The Firm also discloses
the risks associated with reliance on AI, including potential inaccuracies, biases, and operational risks. The
Firm may also include similar disclosures and client acknowledgements within its advisory agreements or
other client-facing documents, as appropriate.
•
ITEM 10 : The Firm has added language to reflect the following regarding IARs acting under the
capacity of Insurance agents.
As described above, many of the Firm’s IARs also serve in a separate capacity as insurance agents, and in
that capacity, they can sell you life insurance, annuities, and other insurance products. These agents
receive commissions and other compensation for the sale of insurance products and again when they
recommend the replacement of insurance products which results in surrender charges. Commissions are
3
April 2026
Prostatis Financial Advisors Group
e
g
a
P
paid by insurance carriers, vary from carrier to carrier. Additionally, agents can qualify for incentives,
bonuses, and other compensation from their insurance marketing organization, insurance companies, or
related organizations based on insurance transactions. These incentives include, but are not limited to,
gifts, meals, entertainment, participation in bonus programs, forgivable loans, reimbursement for training,
marketing assistance, educational efforts, advertising, and travel expenses to conferences and events and
override payments. Consequently, agents are incentivized to recommend the purchase and replacement
of insurance products due to the receipt of commissions and other compensation.
This creates a conflict of interest or incentive to offer or recommend insurance products instead of
investment advisory services or securities products, to recommend certain insurance products over other
insurance products, and to recommend the replacement of insurance or annuity products. We address this
conflict by disclosing it in this brochure and charging no advisory fee on insurance products, which are held
outside of the advisory relationship, in addition to commissions and other compensation earned from the
sale of those products. When acting in their capacity as an insurance agent, your IAR is not subject to the
fiduciary standards under the Investment Advisers Act of 1940, but is subject to a best interest standard
under state insurance law and regulations.
To the extent a representative is recommending both securities investments and insurance products for
clients, they are acting in the capacity of an investment adviser representative when offering securities and
as an insurance agent when offering insurance products, and those recommendations are subject to
different standards of care and different disclosure requirements under applicable law. You are under no
obligation to implement any insurance or annuity transaction through your IAR in their capacity as an
insurance agent. When you purchase insurance products, the issuing insurance carrier is responsible for
reviewing and supervising the sale of an insurance product and the suitability of the product as it relates to
your financial situation as required under state insurance laws.
ANNUAL UPDATE
The Material Changes section of this brochure will be updated annually or when material changes occur since the
previous release of the Firm Brochure. Each year, we will ensure that you receive a summary of any material
changes to this and subsequent brochures by April 30th. We will further provide you with our most recent brochure
at any time at your request, without charge. You may request a brochure by contacting us at (410) 863-1040.
4
April 2026
Prostatis Financial Advisors Group
e
g
a
P
I T E M 3 - T A B L E O F C O N T E N T S
Item 1 – Cover Page ................................................................................................................................................................ 1
Item 2-Material Changes ......................................................................................................................................................... 2
Item 3- Table of Contents ........................................................................................................................................................ 5
Item 4- Advisory Business ........................................................................................................................................................ 6
Item 5- Fees and Compensation .............................................................................................................................................. 8
Item 6- Performance-Based Fees and Side-By-Side Management ........................................................................................ 11
Item 7 - Types of Clients ........................................................................................................................................................ 11
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss .................................................................................. 11
Item 9- Disciplinary Information ............................................................................................................................................ 16
Item 10- Other Financial Industry Activities and Affiliations ................................................................................................. 17
Item 11- Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...................................... 19
Item 12-Brokerage Practices................................................................................................................................................ 20
Item 13-Review of Accounts ............................................................................................................................................... 22
Item 14-Client Referrals and Other Compensation ....................................................................................................... 23
Item 15 -Custody ................................................................................................................................................................ 23
Item 16- Discretion ............................................................................................................................................................. 24
Item 17-Voting Client Securities ....................................................................................................................................... 24
Item 18- Financial Information .......................................................................................................................................... 24
5
April 2026
Prostatis Financial Advisors Group
e
g
a
P
I T E M 4 - A D V I S O R Y B U S I N E S S
This Disclosure document is being offered to you by Prostatis Group (“Firm” or “Prostatis”) about the investment
advisory services we provide. It discloses information about our services and the way those services are made
available to you, the client.
We are an investment management firm located in Hanover, Maryland. Prostatis became a registered investment
adviser in 2004. Prostatis Holdings LLC owns the registered investment adviser. Prostatis Group, LLC is majority
owned by Ryan Herbert and Michael Canet, indirect owners of the firm. Michael Canet is Chief Compliance Officer
of the firm. In certain markets, the firm does business as, McPherson Financial Group, Shepherd Wealth Solutions,
and Prostatis Management Group, and Game Changer Wealth.
We are dedicated to assisting clients to build, grow, manage, and safeguard their wealth. Our aim is to offer
guidance that enables clients to realize their financial objectives effectively. Specializing in investment for financial
independence, which includes retirement investing and income replacement strategies. We tailor our services to
meet your specific needs. We offer an initial complimentary meeting upon our discretion; however, our investment
advisory services commence only after you and Prostatis execute an Investment Management Agreement, ensuring
a clear and mutual understanding of our partnership.
INVESTMENT MANAGEMENT SERVICES
We manage advisory accounts on a discretionary and non-discretionary basis. For discretionary accounts, once we
determine a client’s profile, income need, and investment plan, we execute the day-to- day transactions with or
without prior consent. Account supervision is guided by the client’s written profile and investment plan. We may
accept accounts with certain restrictions if circumstances warrant. We primarily allocate client assets among
various mutual funds, exchange-traded funds (“ETFs”), alternatives, cash, and individual debt (bonds) and equity
securities in accordance with their stated investment objectives. In some cases, our Firm does utilize pre-built
portfolios for clients based on their risk tolerance and time horizon.
In personal discussions with clients, we determine their objectives, time horizons, risk tolerance and liquidity and
income needs. As appropriate, we also review their prior investment history, as well as family composition and
background. Based on client needs, we develop the client’s personal profile and investment plan. We then create
and manage the client’s investments based on that policy and plan. It is the client’s obligation to notify us
immediately if circumstances have changed with respect to their goals and income needs. As determined through
our Firm’s initial due diligence with the client, we will determine if clients are seeking an actively managed
investment strategy for their account(s). Our Firm will provide ongoing investment review and management
services. This approach requires us to periodically review client portfolios.
With our discretionary relationship, we will make changes to the portfolio, as we deem appropriate, to meet your
financial objectives. We trade these portfolios based on the combination of our market views and your objectives,
using our investment philosophy and strategies as described in Item 8 of this Brochure. We tailor our advisory
services to meet the needs of our clients and seek to ensure that your portfolio is managed in a manner consistent
with those needs and objectives. You will have the ability to leave standing instructions with us to refrain from
investing in particular industries or invest in limited amounts of securities.
With our non-discretionary relationship, calls will be placed presenting the recommendation made and only upon
your authorization will any action be taken on your behalf. We do have limited authority to direct the Custodian to
deduct our investment advisory fees from accounts, but only with the appropriate written authorization from
clients.
You are advised and are expected to understand that our past performance is not a guarantee of future results.
Certain market and economic risks exist that adversely affect an account’s performance. This could result in capital
losses in your account.
6
April 2026
Prostatis Financial Advisors Group
e
g
a
P
SUB-ADVISORY SERVICES
Our firm may determine that engaging the expertise of an independent sub-advisor is best suited for your account.
Our firm will have the discretion to utilize independent third-party investment advisor to aid in the implementation
of investment strategies for your portfolio. In certain circumstances, we may allocate a portion of a portfolio to an
independent third-party registered investment advisor (“Manager”) for separate account management based upon
your individual circumstances and objectives, including, but not limited to, your account size and tax circumstances.
Upon recognition of such situations, in coordination with you, we will hire a Manager for the management of those
assets. These advisors shall assist our Firm in managing the day‐to‐day investment operations of the various
allocations, shall determine the composition of the investments comprising the allocation, shall determine what
securities and other assets of the allocation will be acquired, held, disposed of or loaned in conformity with the
written investment objectives, policies and restrictions and other statements of each client comprising the
allocation, or as instructed by our Firm.
Managers selected for your investments need to meet several quantitative and qualitative criteria established by
us. Among the criteria that may be considered are the Manager’s experience, assets under management,
performance record, client retention, the level of client services provided, investment style, buy and sell disciplines,
capitalization level, and the general investment process.
You are advised and should understand that:
• A Manager’s past performance is no guarantee of future results;
• There is a certain market and/or interest rate risk which may adversely effect any Manager’s objectives
and strategies, and could cause a loss in a Client's account(s); and
• Client risk parameters or comparative index selections provided to our firm are guidelines only and there
is no guarantee that they will be met or not be exceeded.
Managers may take discretionary authority to determine the securities to be purchased and sold for the client. As
stated in the Discretionary Advisory Agreement, our Firm and its associated persons will have discretionary
authority to hire and fire the Manager. Our firm will work with the Manager to communicate any trading
restrictions or standing instructions to refrain from a particular industry requested by the Client. In all cases, trading
restrictions will depend on the Manager and their ability to accommodate such restrictions.
All performance reporting will be the responsibility of the respective Manager. Such performance reports will be
provided directly to you and our firm. Disclosures will indicate what firm is providing the reporting.
Our Firm has entered into agreements with various independent Managers. All third-party Managers to whom we
will refer clients will be licensed as registered investment advisors by their resident state and any applicable
jurisdictions or registered investment advisors with the Securities and Exchange Commission. A complete
description of the Manager’s services, fee schedules and account minimums will be disclosed in the Manager’s
Form ADV or similar Disclosure Brochure.
We review the performance of our Managers on at least a quarterly basis. More frequent reviews may be triggered
by changes in Manager’s management, performance or geopolitical and macroeconomic specific events. Our Firm
only enters into only a select number of relationships with Managers. The Client will pay a portion of the overall
advisory fee to the Manager directly from the Client account or the Manager’s fee may be paid by our Firm. In
either case, these fees are disclosed on the Client account statement.
FINANCIAL PLANNING SERVICES
Financial planning services are available and defined on a separate agreement for a separate fee. Through the
financial planning process, our team strives to engage our clients in conversations around the family’s goals,
objectives, priorities, vision, and legacy – both for the near term as well as for future generations.
The Firm provides financial planning and consulting services consistent with a client’s financial and tax status, in
addition to their risk tolerance and investment objectives. Financial planning services generally include income
allocation, education, estate, legacy, tax, business and other planning services as needed. The Firm starts the
7
April 2026
Prostatis Financial Advisors Group
e
g
a
P
comprehensive financial planning process by taking a financial inventory. This generally involves gathering enough
data to perform an analysis of client liabilities, cash flow, net worth and tax assessments. The Firm also evaluates
client insurance coverage and needs.
Access to a financial planning portal is provided in our financial planning services. This online portal provides a
current, and up-to-date overview of each client's situation.
DISCLOSURE REGARDING ROLLOVER RECOMMENDATIONS
When a client or prospect leaves an employer, they typically have five options regarding their existing retirement
plan: (i) leave the money in the former employer’s plan, if permitted; (ii) roll over the assets to the new employer’s
plan, if one is available and rollovers are permitted; (iii) rollover to a brokerage (self-directed) Individual Retirement
Account (“IRA”); (iv) roll over the assets to an advisory IRA; or (v) cash out the account value (which could,
depending upon the client’s age, result in adverse tax consequences). Clients contemplating rolling over retirement
funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney.
There is an inherent financial incentive for your IAR to recommend that you roll over your assets into one or more
accounts, because the enrollment will generate compensation based on the increase in your IAR’s total assets under
management. We address these financial compensation conflicts by including the disclosure of the conflicts in this
brochure and by requiring your IAR to recommend investment advisory programs, investment securities, and
services that are in the best interest of each client based upon the client’s investment objectives, risk tolerance,
financial situation, and cost. As fiduciaries of the Investment Advisers Act of 1940, we have to act in your best
interest and not put our interest ahead of yours. At the same time, the way Prostatis makes money creates some
conflicts with your interests. Clients are under no obligation, contractually or otherwise, to complete the rollover.
Furthermore, if the client does complete the rollover, the client is under no obligation to have the assets in an
account managed by us.
WRAP FEE PROGRAM
Prostatis does not offer a Wrap Program.
ASSETS
As of December 31, 2025, Prostatis manages $604,809,962 of discretionary assets under management and
$635,374 of non-discretionary assets under our management.
I T E M 5 - F E E S A N D C O M P E N S A T I O N
INVESTMENT MANAGEMENT SERVICES
Prostatis charges a fee as compensation for providing Investment Management services. These services include
advisory and consulting services, trade entry, investment supervision, and other account-maintenance activities.
Your custodian may charge transaction costs, custodial fees, redemption fees, retirement plan and administrative
fees or commissions. See Additional Fees and Expenses below for additional details.
Prostatis’ annual fees are based upon a percentage of assets under management not to exceed 2.00%. Investment
advisory fees of Prostatis are charged based on a percentage of assets under management, billed monthly in arrears
and calculated based on the average daily balance of the Account during the current billing period. If services
commenced in the middle of the billing period, fees are prorated for that billing period.
From
To
Up to $249,999
$500,000
$1,500,000
$2,500,000
$3,500,000
$250,000
$500,001
$1,500,001
$2,500,001
Over $3,500,000
Per Year
2.00%
1.50%
1.00%
0.90%
0.80%
0.75%
8
April 2026
Prostatis Financial Advisors Group
e
g
a
P
Although Prostatis has established a maximum annual fee as stated above, we retain the discretion to negotiate
alternative fees on a client-by-client basis. Client facts, circumstances and needs are considered in determining the
fee schedule. These factors include the complexity of the client, assets to be placed under management, anticipated
future additional assets, related accounts, portfolio style, account composition, reports, among others. The specific
annual fee schedule is identified in the contract between the adviser and the client. Fees are assessed on all assets
under management, including securities, cash and money market balances. When invested in a managed model
there is typically a small percentage invested in cash as part of that model. That “cash” will be included in the AUM
fee. Cash held in other types of accounts, such as a stand‐alone money market, a “contribution distribution sleeve”
or “non‐managed” account (used for purposes of scheduled distributions or flexibility of withdrawals) is “not”
included in the fee.
At our discretion, we may aggregate asset amounts in accounts from your same household together to determine
the advisory fee for all your accounts. We may do this, for example, where we also service accounts on behalf of
your minor children, individual and joint accounts for a spouse, and/or other types of related accounts. This
consolidation practice is designed to allow the client the benefit of an increased asset total, which could potentially
cause your account(s) to be assessed a lower advisory fee based on the asset levels under management with
Prostatis.
The independent qualified custodian holding your funds and securities will debit your account directly for the
advisory fee and pay that fee to us. The client will provide written authorization permitting the fees to be paid
directly from the account held by the qualified custodian. Further, the qualified custodian agrees to deliver an
account statement at least quarterly directly to client indicating all the amounts deducted from the account
including our advisory fees. Refer to Item 15 for details. Clients are encouraged to review your account statements
for accuracy.
Either Prostatis or the client may terminate the management agreement immediately upon written notice to the
other party. The management fee will be pro-rated to the date of termination. Upon termination, the client is
responsible for monitoring the securities in your account, and we will have no further obligation to act or advise
with respect to those assets.
Fees for our financial planning portal and services can be paid via credit card. Credit cards will be invoiced and
processed through an unaffiliated, third-party vendor. Clients will be asked to set up their credit card at the third-
party entity to enable credit card payments. While the third-party entity allows firms like Prostatis to receive
payments directly from the client’s credit card, it does not give Prostatis access to the credit card account itself.
Prostatis is not able to initiate any additional payments via third-party vendor as agreed upon and outlined in the
Agreement.
SUB-ADVISOR FEES
As discussed in Item 4 above, there will be occasions where an independent Registered Investment Advisory firm
acts as a sub-advisor / Manager to our Firm. In those circumstances, the other investment advisor manages the
assets based upon the parameters provided by our Firm. The independent sub-advisor / Manager will charge an
asset-based fee that is in addition to the advisory fee listed above and not to exceed 0.50%. The Client, prior to
entering into an agreement with the Manager, will be provided with the Manager’s Form ADV Part 2A (or a brochure
that makes the appropriate disclosures). The independent sub-advisor / Manager will collect the fee and give
Prostatis their portion. In the event that a client should wish to terminate their relationship with Manager, the
terms for the termination will be set forth in the respective agreements between the Client and that Independent
Manager. Prostatis will assist the Client with the termination and transition as appropriate.
In no case are our fees based on, or related to, the performance of your funds or investments.
FINANCIAL PLANNING SERVICE FEES
Our Firm charges a separate fee for financial planning services. This financial planning fee is in addition to the
investment management fees described above. Fees vary based on the extent and complexity of your individual or
family circumstances and the amount of your assets under our management. Our fee will be agreed in advance of
9
April 2026
Prostatis Financial Advisors Group
e
g
a
P
services being performed and negotiated with you. Financial planning fees may be paid via check to Prostatis or
can be a direct fee deduction from a designated account held at the Custodian.
Clients are billed fixed fees that generally range from $550 to $10,000 based on the range and complexity of the
services provided. Fixed fees are payable in advance and services are generally completed within 120 days of
engagement.
Our Firm may charge clients an hourly fee for financial planning and consulting services. Clients are billed at the
rate of $350 an hour. Hourly fees are payable as services are performed and our Firm will regularly invoice clients
for fees that are due and payable.
Either party may terminate the agreement prior to delivery of any plan or completion of any services or with a 30-
day notice by phone or email. Upon termination, fees will be prorated to the date of termination and any
unearned portion of the fee will be refunded to the Client. Financial planning fees will be prorated based upon
the amount of time in which actual services were performed.
Advisory clients should note that fees are negotiable and that the fees for comparable services vary and lower or
higher fees for comparable services may be available from other sources.
ADMINISTRATIVE SERVICES
We have contracted with various non-affiliated, third-party entities to utilize their technology platforms to support
data reconciliation, performance reporting, fee calculation and billing, research, client database maintenance,
quarterly performance evaluations, payable reports, web site administration, models, trading platforms, and other
functions related to the administrative tasks of managing client accounts. Due to this arrangement, the third-party
entity will have access to information on the client accounts, but the third-party entity will not serve as an
investment advisor to our clients. Prostatis and the third-party entities are non-affiliated companies. The third-party
entities charge our Firm an annual fee for each account administered by each third-party entity. Please note that
the fee charged to the client will not increase due to the annual fee Prostatis pays to the third-party entity, the
annual fee is paid from the portion of the management fee retained by Prostatis.
OTHER ADDITIONAL FEES
Advisory Fees in General: Clients should note that similar advisory services may (or may not) be available from other
registered (or unregistered) investment advisers for similar or lower fees.
Mutual Fund Fees: Mutual funds often offer multiple share classes with differing internal fee and expense
structures. Prostatis endeavors to identify and utilize the share class with the lowest internal fee and expense
structure for each mutual fund. However, instances occur in which the lowest cost share class is not used. These
instances include but are not limited to: Instances in which a certain custodian has a share class available that has
a lower internal fee and expense structure than is available for the same mutual fund at other custodians. In such
instances, Prostatis will select the lowest cost share class available at the custodian that holds your account even
though a lower cost share class is available at another custodian. Instances in which the custodian that holds your
account offers others a share class with a lower internal fee and expense structure than what is available to Prostatis
at the same custodian. In such instances, Prostatis will select the lowest cost share class that the custodian makes
available. This situation sometimes occurs because the custodian places conditions on the availability of the lower
cost share class that Prostatis has determined are not appropriate to accept due to additional costs imposed by
said conditions. Instances in which a share class with a lower internal fee and expense structure becomes available
after the share class you hold was purchased. Prostatis periodically monitors this circumstance. However, a share
class with a lower internal fee may become available between the time of your purchase and Prostatis’ next review.
Instances in which a share class with a lower internal fee and expense structure than the share class you currently
hold is available at your custodian, but where Prostatis is prevented by either the custodian or the fund sponsor
from converting to the lower cost share class. Additionally, Prostatis does not convert to a share class with a lower
internal fee and expense structure if the conversion will cause a taxable event or other expense/cost to you that
negates the advantage of the lower cost share class.
0
1
April 2026
Prostatis Financial Advisors Group
e
g
a
P
Non-Transaction Fee (NTF) Mutual Funds When selecting investments for our clients’ portfolios we might choose
mutual funds on your account custodian’s Non-Transaction Fee (NTF) list. This means that your account custodian
will not charge a transaction fee or commission associated with the purchase or sale of the mutual fund. The mutual
fund companies that choose to participate in your custodian’s NTF fund program pay a fee to be included in the
NTF program. The fee that a mutual fund company pays to participate in the program is ultimately borne by the
owners of the mutual fund including clients of our Firm. When we decide whether to choose a fund from your
custodian’s NTF list or not, we consider our expected holding period of the fund, the position size and the expense
ratio of the fund versus alternative funds. Depending on our analysis and future events, NTF funds might not always
be in your best interest.
Regulatory Fees To facilitate the execution of trades, regulatory Trading Activity Fees (TAF) are added to applicable
sales transactions. The Securities and Exchange Commission (SEC) regulatory fee is assessed on client accounts for
sell transactions, and a FINRA fee is assessed on client accounts for sell transactions, for certain covered securities.
This fee is not charged by our Firm but is accessed and collected by the custodian. The Custodian that our Firm
uses, is a FINRA member firm. These fees recover the costs incurred by the SEC and FINRA, for supervising and
regulating the securities markets and securities professionals. The fee rates vary depending on the type of
transaction and the size of that transaction. For more information on the SEC and FINRA fees, please visit their
websites: www.sec.gov/fast-answers/answerssec31htm.html or www.finra.org/industry/trading-activity-fee.
I T E M 6 - P E R F O R M A N C E - B A S E D F E E S A N D S I D E - B Y - S I D E
M A N A G E M E N T
Prostatis does not engage in performance-based fees. No supervised person is compensated by performance-based
fees. Performance-based fees may create an incentive for the advisor to recommend an investment that may carry
a higher degree of risk.
I T E M 7 - T Y P E S O F C L I E N T S
Prostatis works with the following types of clients: individuals, high net-worth individuals, foundations, trusts,
estates, corporations, and charitable organizations.
Our Firm does not impose an account minimum account to initiate the advisory and asset management services.
I N V E S T M E N T
I T E M 8 - M E T H O D S O F A N A L Y S I S ,
S T R A T E G I E S A N D R I S K O F L O S S
Prostatis takes a macro-environmental approach to tactical asset allocation with sector rotation and uses a relative
growth/value framework in determining sub-asset classes. This top-down method allows Prostatis to assess the
investing landscape and provide recommendations as to when and where it may be advantageous to modify
exposures within the asset classes, market segments, and sectors.
GROWTH STRATEGIES: Prostatis’ growth strategies consist of investments spanning a broad range of asset classes
that are selected for their long-term risk/return characteristics as well as their correlation to the overall markets
and appropriateness for each client’s portfolio. The resulting blended allocation is used as the foundation for the
client's growth portfolio. Portfolio rebalancing is discretionary and will be based on individual portfolio
considerations. There is no guarantee as to the number of times a portfolio is rebalanced each year. Other asset
classes and opportunistic investments are added to the growth portfolio to create a customized allocation that is
appropriate for client’s investment objectives, time horizon, and risk tolerance. Examples of investments which may
be included as part of Prostatis’ growth strategies include individual equities and exchange traded funds (ETFs).
FIXED INCOME STRATEGIES: Fixed income investments such as bonds, notes, and certificates of deposit are
intended to provide diversification, generate income, and to preserve and protect assets. Generally, the stabilizing
influence of fixed income comes at the cost of lower returns relative to growth investments. Prostatis’ fixed income
portfolios generally consist of high quality domestically issued bonds, both taxable and tax-free. Examples of
1
1
April 2026
Prostatis Financial Advisors Group
e
g
a
P
investments which may be included as part of Prostatis’ fixed income strategies include individual government,
municipal, and corporate bonds, certificates of deposits, exchange traded funds (ETFs), and money markets.
METHODS OF ANALYSIS
While there may be some similarities in the portfolios created by our Firm, we understand that every client has
their own unique planning needs. We have the ability and flexibility to create portfolios to help our client achieve
their goals. We may utilize the following forms of analysis:
Fundamental Analysis: We attempt to measure the intrinsic value of a security by looking at economic and
financial factors (including the overall economy, industry conditions, and the financial condition and
management of the company itself) to determine if the company is underpriced (indicating it may be a
good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt
to anticipate market movements. This presents a potential risk, as the price of a security can move up or
down along with the overall market regardless of the economic and financial factors considered in
evaluating the stock.
Quantitative Analysis: We use mathematical ratios and other performance appraisal methods in an attempt
to obtain more accurate measurements of a model manager’s investment acumen, idea generation,
consistency of purpose and overall ability to outperform their stated benchmark throughout a full market
cycle. Additionally, we perform periodic measurements to assess the authenticity of returns. A risk in using
quantitative analysis is that the models used may be based on assumptions that prove to be incorrect.
Technical Analysis: We use this 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. Technical
analysts believe that the historical performance of stocks and markets are indications of future
performance. Technical analysis is even more subjective than fundamental analysis in that it relies on
proper interpretation of a given security's price and trading volume data. A decision might be made based
on a historical move in a certain direction that was accompanied by heavy volume; however, that heavy
volume may only be heavy relative to past volume for the security in question, but not compared to the
future trading volume. Therefore, there is the risk of a trading decision being made incorrectly, since future
trading volume is unknown. Technical analysis is also done through observation of various market
sentiment readings, many of which are quantitative. Market sentiment gauges the relative degree of
bullishness and bearishness in a given security, and a contrarian investor utilizes such sentiment
advantageously. When most traders are bullish, then there are very few traders left in a position to buy the
security in question, so it becomes advantageous to sell it ahead of the crowd. When most traders are
bearish, then there are very few traders left in a position to sell the security in question, so it becomes
advantageous to buy it ahead of the crowd. The risk in utilization of such sentiment technical measures is
that a very bullish reading can always become more bullish, resulting in lost opportunity if the money
manager chooses to act upon the bullish signal by selling out of a position. The reverse is also true in that
a bearish reading of sentiment can always become more bearish, which may result in a premature purchase
of a security.
Asset Allocation: Rather than focusing primarily on securities selection, we attempt to identify an
appropriate ratio of securities, fixed income, and cash suitable to the client’s investment goals and risk
tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a particular
security, industry or market sector. Another risk is that the ratio of securities, fixed income, and cash will
change over time due to stock and market movements and, if not corrected, will no longer be appropriate
for the client’s goals.
MUTUAL FUND SHARE CLASS
Generally, our Firm does not recommend mutual funds holdings in our client portfolios/investment strategies,
however, some clients may hold mutual funds in their accounts for various reasons including tax strategies or legacy
assets. If we need to render advice on mutual fund holdings, our Firm will purchase institutional share classes of
2
1
April 2026
Prostatis Financial Advisors Group
e
g
a
P
those mutual funds. The institutional share class generally has the lowest expense ratio. The expense ratio is the
annual fee that all mutual funds or ETFs charge their shareholders. It expresses the percentage of assets deducted
each fiscal year for a fund’s expenses, including 12b-1 fees, management fees, administrative fees, operating costs,
and all other asset-based costs incurred by the fund. Some fund families offer different classes of the same fund,
and one share class may have a lower expense ratio than another share class. These expenses come from client
assets which could impact the client’s account performance. Mutual fund expense ratios are in addition to our fee,
and we do not receive any portion of these charges. If an institutional share class is not available for the mutual
fund selected, the adviser will purchase the least expensive share class available for the mutual fund. As share
classes with lower expense ratios become available, we may use them in the client’s portfolio, and/or convert the
existing mutual fund position to the lower cost share class. Clients who transfer mutual funds into their accounts
with our Firm would bear the expense of any contingent or deferred sales loads incurred upon selling the product.
If a mutual fund has a frequent trading policy, the policy can limit a client’s transactions in shares of the fund (e.g.,
for rebalancing, liquidations, deposits, or tax harvesting). All mutual fund expenses and fees are disclosed in the
respective mutual fund prospectus.
USE OF INDEPENDENT MANAGER MODELS USING MACHINE LEARNING
The Firm has limited exposure to the use of artificial intelligence (“AI”) in connection with its investment activities.
The Firm does not internally develop, implement, or rely on AI-driven tools in the management of client portfolios.
To the extent AI is utilized, such use is limited to certain third-party registered investment advisers / Managers
engaged by the Firm, which may incorporate AI or related technologies within their investment processes. The Firm
conducts due diligence on such Managers consistent with its fiduciary obligations.
Certain investment strategies recommended by the Firm are actively managed and seek to achieve their investment
objectives through the use of proprietary AI-driven models developed and maintained by independent registered
investment advisers (e.g., Ai Funds). These models analyze a variety of data inputs, including market data, financial
reports, and other quantitative and qualitative information, to identify and evaluate potential investment
opportunities. The effectiveness of such models is dependent on the accuracy, completeness, and timeliness of the
underlying data, as well as the design and ongoing calibration of the model.
To the extent that the AI models do not perform as intended, or if the data inputs are inaccurate, incomplete, or
biased, the strategies may fail to achieve their stated investment objectives and may experience losses. Additionally,
errors in data, calculations, or model construction may occur and may not be promptly identified or corrected by
the Manager, which could adversely impact performance.
Risks associated with AI-driven investment strategies include, but are not limited to:
Lack of transparency or explainability of model outputs (“black box” risk)
• Model risk, including errors in algorithm design, assumptions, or implementation
• Data dependency risk, including reliance on inaccurate, incomplete, or outdated data inputs
•
• Overfitting or poor performance in changing market conditions
• Operational and technology risk, including system failures or processing errors
• Manager risk, including reliance on the controls, oversight, and expertise of the external manager
• Regulatory and compliance risk related to evolving guidance on AI use in investment management
MACHINE LEARNING AND MODEL RISK: The use of machine learning in investment strategies presents both opportunities
and risks. These strategies rely heavily on quantitative models and a wide range of data sources to make informed
decisions. However, when these models and data prove to be incorrect or incomplete, the resulting decisions can
expose clients to substantial risks. For instance, relying on such models may lead to buying investments at inflated
prices, selling them too low, or missing lucrative opportunities altogether. Moreover, predictive models, which are
often used in these strategies, carry inherent risks, including the potential for inaccurate forecasts, leading to
financial losses. Unforeseen events or low-probability scenarios can also challenge the effectiveness of these
3
1
April 2026
Prostatis Financial Advisors Group
e
g
a
P
models, potentially resulting in portfolio losses. Machine learning typically is less transparent or interpretable.
Furthermore, because predictive models are usually constructed based on historical data, supplied by third parties
or otherwise, the success of relying on such models may depend on the accuracy and reliability of the historical
data. In all cases, the accuracy and reliability of historical data plays a pivotal role in the success of these models,
underscoring the importance of careful evaluation and risk management in the application of machine learning to
investment recommendations.
RISKS OF USING ARTIFICIAL INTELLIGENCE IN INVESTMENT ACTIVITIES: In line with advances in computing technology and data
analytics, there has been an increasing trend towards utilizing artificial generative intelligence, large language
models, machine learning, artificial neural networks, or similar tools, models and systems generally referred to as
“artificial intelligence” (collectively, “AI”) as part of portfolio management, trading, portfolio risk management and
other applications in the investment management processes used by various market participants.
RISK OF LOSS
A client’s investment portfolio is affected by general economic and market conditions, such as interest rates,
availability of credit, inflation rates, economic conditions, changes in laws and national and international political
circumstances.
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. Prostatis will assist Clients in determining an appropriate
strategy based on their tolerance for risk.
Each Client engagement will entail a review of the Client’s investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client’s account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client’s account(s). Prostatis shall rely on the financial and other information provided by the Client
or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform Prostatis of any changes in financial condition, goals or
other factors that may affect this analysis.
Our methods rely on the assumption that the underlying companies within our security allocations are accurately
reviewed by the rating agencies and other publicly available sources of information about these securities, are
providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always
a risk that our analysis may be compromised by inaccurate or misleading information.
Investors should be aware that accounts are subject to the following risks:
MARKET RISK - Even a long-term investment approach cannot guarantee a profit. Economic, political, and issuer-
specific events will cause the value of securities to rise or fall. Because the value of investment portfolios will
fluctuate, there is the risk that you will lose money and your investment may be worth more or less upon
liquidation.
FOREIGN SECURITIES AND CURRENCY RISK - Investments in international and emerging-market securities include exposure
to risks such as currency fluctuations, foreign taxes and regulations, and the potential for illiquid markets and
political instability.
CAPITALIZATION RISK - Small-cap and mid-cap companies may be hindered as a result of limited resources or less
diverse products or services. These stocks have historically been more volatile than the stocks of larger, more
established companies.
INTEREST RATE RISK - In a rising rate environment, the value of fixed-income securities generally declines, and the
value of equity securities may be adversely affected.
CREDIT RISK - Credit risk is the risk that the issuer of a security may be unable to make interest payments and/or
repay principal when due. A downgrade to an issuer’s credit rating or a perceived change in an issuer’s financial
strength may affect a security’s value and thus, impact the fund’s performance.
4
1
April 2026
Prostatis Financial Advisors Group
e
g
a
P
LIQUIDITY RISK: Liquidity risk is the risk that there may be limited buyers for a security when an investor wants to sell.
Typically, this results in a discounted sale price in order to attract a buyer.
DEFAULT RISK - A default occurs when an issuer fails to make payment on a principal or interest payment.
EVENT RISK - Event risk is difficult to predict because it may involve natural disasters such as earthquakes or
hurricanes, as well as changes in circumstance from regulators or political bodies.
POLITICAL RISK - Political risk is the risk associated with the laws of the country, or to events that may occur there.
Particular political events such as a government’s change in policy could restrict the flow of capital.
DURATION RISK - Duration is a way to measure a bond's price sensitivity to changes in interest rates. The duration of
a bond is determined by its maturity date, coupon rate, and call feature. Duration is a method to compare how
different bonds will react to interest rate changes. If a bond has a duration of five (5) years it means that the value
of that security will decline by approximately five percent (5%) for every one percent (1%) increase in interest rates.
REINVESTMENT RISK: Reinvestment risk is the risk that future interest and principal payments may be reinvested at
lower yields due to declining interest rates.
TAX RISK: For municipal bonds, depending on the client’s state of residence, the interest earned on certain bonds
may not be tax-exempt at the state level. Also, changes in federal tax policy may impact the tax treatment of interest
and capital gains of an investment.
REGULATORY RISK: Market participants are subject to rules and regulations imposed by one or more regulators.
Changes to these rules and regulations could have an adverse effect on the value of an investment.
CONCENTRATION RISK: The risk of amplified losses that may occur from having a large portion of your holdings in a
particular investment, asset class or market segment relative to your overall portfolio.
SECURITIES LENDING RISK - Securities lending involves the risk that the fund loses money because the borrower fails to
return the securities in a timely manner or at all. The fund could also lose money if the value of the collateral
provided for loaned securities, or the value of the investments made with the cash collateral, falls. These events
could also trigger adverse tax consequences for the fund.
EXCHANGE-TRADED FUNDS - ETFs face market-trading risks, including the potential lack of an active market for shares,
losses from trading in the secondary markets, and disruption in the creation/redemption process of the ETF. Any of
these factors may lead to the fund’s shares trading at either a premium or a discount to its “net asset value.”
CYBERSECURITY RISK - In addition to the Material Investment Risks listed above, investing involves various operational
and “cybersecurity” risks. These risks include both intentional and unintentional events at our Firm or one of its
third-party counterparties or service providers, that may result in a loss or corruption of data, result in the
unauthorized release or other misuse of confidential information, and generally compromise our firm’s ability to
conduct its business. A cybersecurity breach may also result in a third-party obtaining unauthorized access to our
clients’ information, including social security numbers, home addresses, account numbers, account balances, and
account holdings. Our Firm has established business continuity plans and risk management systems designed to
reduce the risks associated with cybersecurity breaches. However, there are inherent limitations in these plans and
systems, including that certain risks may not have been identified, in large part because different or unknown
threats may emerge in the future. As such, there is no guarantee that such efforts will succeed, especially because
our Firm does not directly control the cybersecurity systems of our third-party service providers. There is also a risk
that cybersecurity breaches may not be detected.
COMMODITIES RISK - Exposure to commodities in Adviser Clients accounts is in non-physical form, such as ETFs or
mutual funds, there are risks associated with the movement in gold prices and the ability of the fund or trust
manager to respond or deal with those price movements. There also may be initial charges as well as annual
management fees associated with the fund or trust.
5
1
April 2026
Prostatis Financial Advisors Group
e
g
a
P
EXCHANGE-TRADED FUND (“ETF”) AND MUTUAL FUND RISK - Investments in ETFs and mutual funds have unique
characteristics, including, but not limited to, the ETF or mutual fund’s expense structure. Investors of ETFs and
mutual funds held within Prostatis client accounts bear both their Prostatis portfolio’s advisory expenses and,
indirectly, the ETF’s or mutual fund’s expenses. Because the expenses and costs of an underlying ETF or mutual
fund are shared by its investors, redemptions by other investors in the ETF or mutual fund could result in decreased
economies of scale and increased operating expenses for such ETF or mutual fund. Additionally, the ETF or mutual
fund may not achieve its investment objective. Actively managed ETFs or mutual funds may experience significant
drift from their stated benchmark.
STRUCTURED NOTES RISK - Structured products are designed to facilitate highly customized risk- return objectives.
While structured products come in many different forms, they typically consist of a debt security that is structured
to make interest and principal payments based upon various assets, rates, or formulas. Many structured products
include an embedded derivative component. Structured products may be structured in the form of a security, in
which case these products may receive benefits provided under federal securities law, or they may be cast as
derivatives, in which case they are offered in the over-the-counter market and are subject to no regulation.
Investment in structured products includes significant risks, including valuation, liquidity, price, credit, and market
risks. One common risk associated with structured products is a relative lack of liquidity due to the highly
customized nature of the investment. Moreover, the full extent of returns from the complex performance features
is often not realized until maturity. As such, structured products tend to be more of a buy-and-hold investment
decision rather than a means of getting in and out of a position with speed and efficiency. Another risk with
structured products is the credit quality of the issuer. Although the cash flows are derived from other sources, the
products themselves are legally considered to be the issuing financial institution’s liabilities. The vast majority of
structured products are from high-investment- grade issuers only. Also, there is a lack of pricing transparency. There
is no uniform standard for pricing, making it harder to compare the net-of-pricing attractiveness of alternative
structured product offerings than it is, for instance, to compare the net expense ratios of different mutual funds or
commissions among broker-dealers.
ARTIFICIAL INTELLIGENCE RISK - The Firm utilizes certain third-party service providers to support client account services,
some of which incorporate artificial intelligence (“AI”) and machine learning technologies. The use of these
technologies presents inherent risks, including potential data inaccuracies, model bias, and cybersecurity
vulnerabilities. Given the rapid evolution of AI, additional risks may emerge that are not currently foreseeable. To
mitigate these risks, the Firm conducts periodic due diligence on its service providers to evaluate whether
appropriate controls are in place to safeguard client information and promote the accuracy and reliability of outputs
where AI is utilized. In addition, our Firm leverages AI technologies, including generative AI tools (e.g., GPTs), large
language models (LLMs), and machine learning, to enhance internal administrative efficiency. These tools are used
to support functions such as reporting, data visualization, and workflow automation. The Firm does not rely solely
on AI-generated outputs; rather, such outputs are reviewed and validated by personnel to ensure accuracy,
transparency, and compliance. Our Firm maintains oversight of its AI use to ensure alignment with applicable
ethical, regulatory, and risk management standards, including considerations related to data integrity, model bias,
information security, and privacy. AI is utilized as a supplementary tool to support, but not replace, human
judgment and expertise. To the extent that AI tools are materially incorporated into the Firm’s investment advisory
or financial planning services, the Firm provides appropriate disclosures regarding such use. These disclosures
describe the nature and scope of AI utilization, its inherent limitations, and the Firm’s supervisory framework,
including applicable human-in-the-loop (“HITL”) controls. The Firm also discloses the risks associated with reliance
on AI, including potential inaccuracies, biases, and operational risks. The Firm may also include similar disclosures
and client acknowledgements within its advisory agreements or other client-facing documents, as appropriate.
I T E M 9 - D I S C I P L I N A R Y
I N F O R M A T I O N
We are required to disclose any legal or disciplinary events that are material to a client's or prospective client's
evaluation of our advisory business or the integrity of our management. Our Firm and our management personnel
have no material reportable disciplinary events to disclose. You may visit http://www.advisorinfo.sec.gov to review
each investment advisors’ individual disclosures or Prostatis’ disclosures.
6
1
April 2026
Prostatis Financial Advisors Group
e
g
a
P
I N D U S T R Y A C T I V I T I E S A N D
I T E M 1 0 - O T H E R F I N A N C I A L
A F F I L I A T I O N S
Licensed Insurance Agents
Ryan Herbert and Michael Canet, who have ownership of the Firm, are also Members of Prostatis Insurance LLC and act as
an independent insurance agents. In this capacity, the Members / Owners of the Firm or other insurance representatives
affiliated with Prostatis Insurance LLC may affect transactions in insurance products for clients and Prostatis Insurance LLC
or its representatives may earn commissions for these activities. Representatives will offer clients advice or products from
this activity. Clients should be aware that these services incur a fee or commission and involve a conflict of interest, as fee-
based and commissionable products can conflict with the fiduciary duties of a registered investment advisor. Mr. Herbert
and Mr. Canet, in the capacity as the owners of Prostatis Insurance LLC or its representatives, may receive economic benefits
from third party insurance companies.
As described above, many of the Firm’s IARs also serve in a separate capacity as insurance agents, and in that capacity, they
can sell you life insurance, annuities, and other insurance products. These agents receive commissions and other
compensation for the sale of insurance products and again when they recommend the replacement of insurance products
which results in surrender charges. Commissions are paid by insurance carriers, vary from carrier to carrier, and disclosed
to Clients at the time of sale. Additionally, agents can qualify for incentives, bonuses, and other compensation from their
insurance marketing organization, insurance companies, or related organizations based on insurance transactions. These
incentives include, but are not limited to, gifts, meals, entertainment, participation in bonus programs, forgivable loans,
reimbursement for training, marketing assistance, educational efforts, advertising, and travel expenses to conferences and
events and override payments. Consequently, agents are incentivized to recommend the purchase and replacement of
insurance products due to the receipt of commissions and other compensation.
This creates a conflict of interest or incentive to offer or recommend insurance products instead of investment advisory
services or securities products, to recommend certain insurance products over other insurance products, and to
recommend the replacement of insurance or annuity products. We address this conflict by disclosing it in this brochure and
charging no advisory fee on insurance products, which are held outside of the advisory relationship, in addition to
commissions and other compensation earned from the sale of those products. When acting in their capacity as an
insurance agent, your IAR is not subject to the fiduciary standards under the Investment Advisers Act of 1940, but is subject
to a best interest standard under state insurance law and regulations.
To the extent a representative is recommending both securities investments and insurance products for clients, they are
acting in the capacity of an investment adviser representative when offering securities and as an insurance agent when
offering insurance products, and those recommendations are subject to different standards of care and different disclosure
requirements under applicable law. You are under no obligation to implement any insurance or annuity transaction through
your IAR in their capacity as an insurance agent. When you purchase insurance products, the issuing insurance carrier is
responsible for reviewing and supervising the sale of an insurance product and the suitability of the product as it relates to
your financial situation as required under state insurance laws.
Estate Planning Services
The Firm has an affiliated entity under common ownership, Law Office of Michael Canet. This entity provides estate
planning document services. Michael Canet, indirect owner of the firm, is an estate attorney. The Firm recommends these
estate services to financial planning clients. This service is included as part of the firm’s financial planning services. No
additional fees are required for this service. Clients should note they have the right to decide whether to act on the
recommendations and the right to choose any professional for estate services through our IAR or any agent not affiliated
with our Firm. We recognize the fiduciary responsibility to place your interests first and have established policies in this
regard to avoid any conflicts of interest.
Tax & Accounting Services
The Firm has an affiliated entity under common ownership, Prostatis Tax, LLC. This entity provides tax preparation and
planning services. The Firm recommends its services to financial planning clients. This service is included as part of the firm’s
7
1
April 2026
Prostatis Financial Advisors Group
e
g
a
P
financial planning services. No additional fees are required for this service. Clients should note they have the right to
decide whether to act on the recommendations and the right to choose any professional for tax preparation services
through our IAR or any agent not affiliated with our Firm. We recognize the fiduciary responsibility to place your interests
first and have established policies in this regard to avoid any conflicts of interest.
Registration as a Broker/Dealer or Broker/Dealer Representative
Prostatis is not a broker/dealer, but some of our Investment Adviser Representatives (“IAR”) are registered representatives
of World Equity Group, Inc (“World Equity”), a full-service broker-dealer, member FINRA/SIPC, which compensates them
for effecting securities transactions. When placing securities transactions through World Equity in their capacity as
registered representatives, they will earn sales commissions. Investment advisory services and advisory fees are offered
separately through Prostatis. Because the IARs are dually registered with World Equity and Prostatis, World Equity has
certain supervisory and administrative duties pursuant to the requirements of FINRA Conduct Rule 3040. World Equity and
Prostatis are not affiliated companies. Certain IARs of Prostatis spend a portion their time in connection with broker/dealer
activities.
As a broker-dealer, World Equity engages in a broad range of activities normally associated with securities brokerage firms.
Pursuant to the investment advice given by Prostatis or its IARs, investments in securities may be recommended for clients.
If World Equity is selected as the broker- dealer, World Equity and its registered representatives, including IARs of Prostatis,
will receive commissions for executing securities transactions.
You are advised that if World Equity is selected as the broker-dealer, the transaction charges may be higher or lower than
the charges you may pay if the transactions were executed at other broker/dealers. You should note, however, that you are
under no obligation to purchase securities through IARs of Prostatis or World Equity.
Moreover, you should note that under the rules and regulations of FINRA, World Equity has an obligation to maintain certain
client records and perform other functions regarding certain aspects of the investment advisory activities of its registered
representatives. These obligations require World Equity to coordinate with and have the cooperation of its registered
representatives that operate as, or are otherwise associated with, investment advisers other than World Equity.
Accordingly, World Equity may limit the use of certain custodial and brokerage arrangements available to clients of Prostatis
and World Equity may collect, as paying agent of Prostatis, the investment advisory fee remitted to Prostatis by the account
custodian. World Equity may charge an administrative Fee to the Firm. This charge will not increase the advisory fee you
have agreed to pay Prostatis.
IARs of Prostatis, in their capacity as registered representatives of World Equity, or as agents appointed with various life,
disability or other insurance companies, receive commissions, 12(b)-1 fees, fee trails, or other compensation from the
respective product sponsors and/or as a result of effecting securities transactions for clients. However, clients should note
that they have the right to decide whether or not to purchase any investment products through Prostatis’ representatives.
Registration as a Futures Commission Merchant, Commodity Pool Operator
The Firm and its management persons are not registered and do not have an application pending to register as a futures
commission merchant, commodity pool operator/advisor.
Selection of Other Advisors
Prostatis may direct clients to third-party investment advisers to manage all or a portion of the client's assets. Clients will
pay Prostatis its standard fee in addition to the standard fee for the advisers to which it directs those clients. This
relationship will be memorialized in each contract between Prostatis and each third-party advisor. The fees will not exceed
any limit imposed by any regulatory agency. Prostatis will always act in the best interests of the client, including when
determining which third-party investment adviser to recommend to clients. Prostatis will ensure that all recommended
advisers are licensed or notice filed in the states in which Prostatis is recommending them to clients.
Disclosure of Conflicts of Interest
Our management personnel and investment advisor representatives may engage in outside business activities. As such,
these individuals can receive separate, yet customary commission compensation resulting from implementing product
8
1
April 2026
Prostatis Financial Advisors Group
e
g
a
P
transactions on behalf of investment advisory Clients. Clients are not under any obligation to engage these individuals when
considering the implementation of these outside recommendations. The implementation of any or all recommendations is
solely at the discretion of the Client. Clients should be aware that the ability to receive additional compensation by our Firm
and its management persons or employees creates inherent conflicts of interest in the objectivity of the Firm and these
individuals when making advisory recommendations. Our Firm endeavors at all times to put the interest of its clients first
as part of our fiduciary duty as a registered investment adviser; we take the following steps, among others to address this
conflict:
• we disclose to clients the existence of all material conflicts of interest, including the potential for the Firm,
investment advisors, and our employees to earn compensation from advisory clients in addition to the Firm's
advisory fees.
• we disclose to clients that they have the right to decide to purchase recommended investment products from our
employees.
• we collect, maintain and document accurate, complete and relevant client background information, including the
•
client’s financial goals, objectives, and liquidity needs.
the Firm conducts regular reviews of each client advisory account to verify that all recommendations made to a
client are in the best interest of the client’s needs and circumstances.
• we require that our investment advisors and employees seek prior approval of any outside employment activity so
that we may ensure that any conflicts of interests in such activities are properly addressed.
• we periodically review these outside employment activities of the investment advisor to verify that any conflicts of
interest continue to be properly disclosed by the investment advisor; and
• we educate our investment advisors regarding the responsibilities of a fiduciary, including the need for having a
reasonable and independent basis for the investment advice provided to clients.
P A R T I C I P A T I O N O R I N T E R E S T
I T E M 1 1 - C O D E O F E T H I C S ,
I N C L I E N T T R A N S A C T I O N S A N D P E R S O N A L T R A D I N G
Prostatis has adopted a Code of Ethics which sets forth high ethical standards of business conduct that we
require of our investment advisors and employees, including compliance with applicable federal securities
laws. Prostatis and its investment advisors owe a duty of loyalty, fairness and good faith towards our clients,
and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general
principles that guide the Code. Our Code of Ethics includes policies and procedures for the reporting and review
of personal securities transactions reports by our Firm’s investment advisors and employees. In addition, our Code
of Ethics also requires the prior approval of any acquisition of securities in a limited offering (e.g., private placement)
or an initial public offering. Our code also provides for oversight, enforcement, and recordkeeping provisions.
Prostatis’ Code of Ethics further includes the Firm's policy prohibiting the use of material non-public
information. While we do not believe that we have any access to non-public information, all investment
advisors are reminded that such information may not be used in a personal or professional capacity.
Prostatis and its investment advisors are prohibited from engaging in principal transactions and agency cross
transactions.
Our Code of Ethics is designed to assure that the personal securities transactions, activities, and interests of our
investment advisors will not interfere with (i) making decisions in the best interest of advisory clients and (ii)
implementing such decisions while, at the same time, allowing investment advisors to invest for their own accounts.
Our Firm and/or investment advisors or employees may buy or sell for their personal accounts securities
that are identical to or different from those recommended to our clients. In addition, any related person(s)
may have an interest or position in a certain security(ies) which may also be recommended to a client. It is
the expressed policy of our Firm that no investment advisor may purchase or sell any security prior to a
transaction(s) being implemented for an advisory account, thereby preventing such investment advisor(s)
from benefiting from transactions placed on behalf of advisory accounts.
9
1
April 2026
Prostatis Financial Advisors Group
e
g
a
P
A copy of our Code of Ethics is available to our advisory clients and prospective clients. Clients may request a
copy by calling us at (410) 863-1040.
I T E M 1 2 - B R O K E R A G E P R A C T I C E S
THE CUSTODIAN AND BROKERS WE USE
Clients must maintain assets in an account at a “qualified custodian,” generally a broker-dealer or bank. We
recommend that our clients use Charles Schwab & Co., Inc. (“Schwab”) or Fidelity Brokerage Services LLC (“Fidelity”)
(collectively referred to as “the Custodian”), which are Member FINRA/SIPC, registered broker-dealers, and
qualified custodians. We are independently owned and operated, and unaffiliated with the Custodian. The
Custodian will hold client assets in a brokerage account and buy and sell securities when we instruct them to.
While we recommend that clients use our recommended Custodian, clients must decide whether to do so and open
accounts with the Custodian by entering into account agreements directly with the Custodian. The accounts will
always be held in the name of the client and never in our firm’s name. Even though clients maintain accounts at
the Custodian, we can still use other brokers to execute trades for client accounts (see Client Brokerage and Custody
Costs, below).
HOW WE SELECT BROKERS/CUSTODIAN
We seek to recommend a custodian/broker who will hold client assets and execute transactions on terms that are,
overall, most advantageous when compared to other available providers and their services. We consider a wide
range of factors, including:
1. Combination of transaction execution services and asset custody services (generally without a separate fee
for custody)
2. Capability to buy and sell securities for client accounts.
3. Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill
payment, etc.)
4. Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds, etc.)
5. Availability of investment research and tools that assist us in making investment decisions.
6. Quality of services
7. Competitiveness of the price of those services (commission rates, other fees, etc.) and willingness to
negotiate the prices.
8. Reputation, financial strength, and stability
9. Prior service to our Firm and our other clients
10. Availability of other products and services that benefit us, as discussed below (see Products and Services
Available to Us from the Custodian)
CLIENT BROKERAGE AND CUSTODY COSTS
For client accounts that the Custodian maintains, the Custodian generally does not charge separately for custody
services. However, the Custodian receives compensation by charging ticket charges or other fees on trades that it
executes or that settle into clients’ Custodian accounts. In addition to commissions, the Custodian charge a flat
dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different custodian
but where the securities bought or the funds from the securities sold are deposited (settled) into a client’s
Custodian account. These fees are in addition to the ticket charges or other compensation the client pays the
executing custodian. To minimize these trading costs, we have the Custodian execute most trades for client
accounts. We have determined that having Custodian execute most trades is consistent with our duty to seek “best
execution” of client trades. Best execution means the most favorable terms for a transaction based on all relevant
factors, including those listed above (see How We Select Brokers/Custodian).
PRODUCTS AND SERVICES AVAILABLE TO US FROM CUSTODIAN
The Custodian will provide our Firm and our clients with access to institutional brokerage, trading, custody,
reporting, and related services. The Custodian also makes available various support services which help us manage
or administer our clients’ accounts and help us manage and grow our business. The Custodian’s support services
0
2
April 2026
Prostatis Financial Advisors Group
e
g
a
P
generally are available on an unsolicited basis (we do not have to request them) and at no charge to us. Following
is a more detailed description of the Custodian’s support services:
SERVICES THAT BENEFIT OUR CLIENTS
Custodian’s institutional brokerage services include access to a broad range of investment products, execution of
securities transactions, and custody of client assets. The investment products available through include some to
which we might not otherwise have access or that would require a significantly higher minimum initial investment
by our clients. Custodian’s services described in this paragraph generally benefit our clients and their accounts.
SERVICES THAT MAY NOT DIRECTLY BENEFIT OUR CLIENTS
The Custodian also makes available to us other products and services that benefit us but may not directly benefit
our clients or their accounts. These products and services assist us in managing and administering our clients’
accounts. They include investment research, both the Custodian’s own and that of third parties. We may use this
research to service all or a substantial number of our clients’ accounts, including accounts not maintained at the
Custodian. In addition to investment research, the Custodian also makes available software and other technology
that:
1. Provides access to client account data (positions, trades, statements, cost basis, etc).
2. Facilitates trade execution and allocates aggregated trade orders for multiple client accounts.
3. Provides pricing and other market data.
4. Facilitates payment of our fees from our clients’ accounts.
5. Assists with back-office functions, recordkeeping, and client reporting.
SERVICES THAT GENERALLY BENEFIT ONLY US
The Custodian also offers other services intended to help us manage and further develop our business enterprise.
These services include:
1. Educational conferences and events
2. Consulting on technology, compliance, legal, and business needs
3. Publications or conferences on practice management & business succession
4. Access to employee benefits providers, human capital consultants, and insurance providers
The Custodian may provide some of these services itself. In other cases, it will arrange for third-party vendors
to provide the services to us. The Custodian may also discount or waive its fees for some of these services or
pay all or part of a third party’s fees. The Custodian may also provide us with other benefits, such as occasional
business entertainment for our personnel. The Custodian provides these additional services and support to
the Advisor in its sole discretion and at its own expense, and Advisor does not pay any fees to the Custodian for
this. As part of our fiduciary duties to clients, we always endeavor to put the interests of our clients first. Clients
should be aware, however, that the receipt of economic benefits by our Firm or our related persons in and of
itself creates a potential conflict of interest and may indirectly influence our choice of the Custodian for custody
and brokerage services. The Custodian may discount or waive fees it would otherwise charge for some of these
services or pay all or a part of the fees of a third-party providing these services to us.
OUR INTEREST IN SCHWAB’S SERVICES
The availability of these services from the Custodian benefits us because we do not have to produce or purchase
them. These services are not contingent upon us committing any specific amount of business to the Custodian. We
believe that our selection of the Custodian as Custodian and brokers is in the best interest of our clients.
Some of the products, services and other benefits provided by the Custodian benefit our Firm and may not benefit
our client accounts. Our recommendation or requirement that clients place assets in the Custodian's custody may
be based in part on benefits Custodian provides to us, or our agreement to maintain certain Assets Under
Management at the Custodian, and not solely on the nature, cost or quality of custody and execution services
provided by the Custodian.
1
2
April 2026
Prostatis Financial Advisors Group
e
g
a
P
BROKERAGE FOR CLIENT REFERRALS
Our Firm does not receive client referrals from any custodian or third party in exchange for using that custodian or
third party.
AGGREGATION AND ALLOCATION OF TRANSACTIONS
Transactions for each client will be affected independently unless we decide to purchase or sell the same securities
for several clients at approximately the same time. We may, but are not obligated to, combine multiple orders for
shares of the same securities purchased for advisory accounts we manage (this practice is commonly referred to as
"aggregated trading"). We will then distribute a portion of the shares to participating accounts in a fair and equitable
manner. In the event an order is only partially filled, the shares will be allocated to participating accounts in a fair
and equitable manner, typically in proportion to the size of each client's order. Accounts owned by our firm or
people associated with our firm may participate in aggregated trading with your accounts; however, they will not
be given preferential treatment. We combine multiple orders for shares of the same securities purchased for
discretionary accounts.
TRADE ERRORS
We have implemented procedures designed to prevent trade errors; however, trade errors in client accounts
cannot always be avoided. Consistent with our fiduciary duty, it is our policy to correct trade errors in a manner
that is in the best interest of the client. In cases where the client causes a trade error, the client will be responsible
for any loss resulting from the correction. Depending on the specific circumstances of the trade error, the client
may not be able to receive any gains generated as a result of the error correction. In all situations where the client
does not cause the trade error, the client will be made whole, and we will absorb any loss resulting from the trade
error if the error was caused by the firm. If the error is caused by the custodian, the Custodian will be responsible
for covering all trade error costs. We will never benefit or profit from trade errors.
DIRECTED BROKERAGE
Prostatis does not routinely require that clients direct us to execute transactions through a specified broker dealer.
Additionally, we typically do not permit clients to direct brokerage. We place trades for your account subject to
our duty to seek best execution and other fiduciary duties.
I T E M 1 3 - R E V I E W O F A C C O U N T S
ACCOUNT REVIEWS AND REVIEWERS
Our Investment Adviser Representatives will monitor investment management client accounts on a regular basis
and perform annual reviews with each client. All accounts are reviewed for consistency with client investment
strategy, asset allocation, risk tolerance, and performance relative to the appropriate benchmark. More frequent
reviews may be triggered by changes in an account holder’s personal, tax, or financial status. Geopolitical and
macroeconomic specific events may also trigger reviews. Clients are urged to notify us of any changes in your
personal circumstances.
While reviews may occur at different stages depending on the nature and terms of the specific engagement,
typically no formal reviews will be conducted for Financial Planning clients unless otherwise contracted for.
Ongoing management of the financial planning portal is maintained by our Firm.
STATEMENTS AND REPORTS
Performance reports from our Firm are generated for clients during annual reviews or as requested.
The Custodian for the individual client’s account will also provide clients with an account statement at least
quarterly. Clients are urged to compare the reports provided by Prostatis against the account statements the clients
receive directly from your account custodian.
All clients will receive access to an online financial planning portal. Additional reports will not typically be provided
unless otherwise contracted for.
2
2
April 2026
Prostatis Financial Advisors Group
e
g
a
P
I T E M 1 4 - C L I E N T R E F E R R A L S A N D O T H E R
C O M P E N S A T I O N
Lead Generation Provider
The Firm pays a fee to participate in an online matching program that seeks to match prospective advisory clients
with investment advisers. The program provides information about investment advisory firms to persons who have
expressed an interest in such firms. The program also provides the name and contact information of such persons
to the advisory firms as potential leads. The fee we pay for being provided with potential leads varies based on
certain factors, including the size of the person’s portfolio, and the fee is payable regardless of whether the prospect
becomes our advisory client.
Expense Reimbursements
At times, we will receive expense reimbursement for travel and/or marketing expenses from distributors of
investment and/or insurance products. Travel expense reimbursements are a result of attendance at due diligence
and/or investment training events hosted by product sponsors. Marketing expense reimbursements are the result
of informal expense sharing arrangements in which product sponsors will underwrite costs incurred for marketing
such as client appreciation events, advertising, publishing, and seminar expenses. Receipt of these travel and
marketing expense reimbursements are dependent upon specific sales quotas, the product sponsor
reimbursements are made by those sponsors for which sales have been made or for which it is anticipated sales
will be made. This creates a conflict of interest in that there is an incentive to recommend certain products and
investments based on the receipt of this compensation instead of what is in the best interest of our clients. We
attempt to control this conflict by always basing investment decisions on the individual needs of our clients. Our
Firm and our supervised persons do not accept or receive compensation based on the sale of securities. Supervised
people can be compensated for obtaining prospective clients through marketing initiatives.
Financial Professional Recommendations
Prostatis may be asked to recommend a financial professional, such as an attorney, accountant or mortgage
broker. In such cases, our Firm does not receive any direct compensation in return for any referrals made to
individuals or firms in our professional network. Clients must independently evaluate these firms or individuals
before engaging in business with them and clients have the right to choose any financial professional to conduct
business. Individuals and firms in our financial professional network may refer clients to our Firm. Again, our Firm
does not pay any direct compensation in return for any referrals made to our firm. Our Firm does recognize the
fiduciary responsibility to place your interests first and have established policies in this regard to mitigate any
conflicts of interest.
It is Prostatis' policy not to accept or allow our related persons to accept any form of compensation, including cash,
sales awards, or other prizes, from a non-client in conjunction with the advisory services we provide to our clients.
I T E M 1 5 - C U S T O D Y
Prostatis does not have physical custody of any client funds and/or securities and does not take custody of client
accounts at any time. Client funds and securities will be held with a bank, broker dealer, or other independent
qualified custodian.
DEDUCTION OF ADVISORY FEES
Prostatis is deemed to have limited custody of client funds and securities whenever Prostatis is given the authority
to have fees deducted directly from client accounts. It should be noted that authorization to trade in client accounts
is not deemed by regulators to be custody. Account statements are delivered directly from the qualified custodian
to each client, or the client’s independent representative, at least quarterly. Clients should carefully review those
statements and are urged to compare the statements against reports received from Prostatis. When the client has
questions about their account statements, the client should contact Prostatis or the qualified custodian preparing
the statement.
3
2
April 2026
Prostatis Financial Advisors Group
e
g
a
P
STANDING LETTERS OF AUTHORIZATION TO 3RD PARTIES
Our authority to direct client requests, utilizing standing instructions, for wire transfer of funds for first-party money
movement and third-party money movement (checks and/or journals, ACH, Fed-wires). The SEC issued a no‐action
letter (“Letter”) with respect to the Rule 206(4)‐2 (“Custody Rule”) under the Investment Advisors Act of 1940
(“Advisors Act”). The letter provided guidance on the Custody Rule as well as clarified that an Advisor who has the
power to disburse client funds to a third party under a standing letter of instruction (“SLOA”) is deemed to have
custody. As such, our Firm has adopted the following safeguards in conjunction with our custodians. The firm has
elected to meet the SEC’s seven conditions to avoid the surprise custody exam, as outlined below:
1. The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature,
the third party’s name, and either the third party’s address or the third party’s account number at a custodian
to which the transfer should be directed.
2. The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately,
to direct transfers to the third party either on a specified schedule or from time to time.
3. The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review
or other method to verify the client’s authorization, and provides a transfer of funds notice to the client
promptly after each transfer.
4. The client has the ability to terminate or change the instruction to the client’s qualified custodian.
5. The investment adviser has no authority or ability to designate or change the identity of the third party, the
address, or any other information about the third party contained in the client’s instruction.
6. The investment adviser maintains records showing that the third party is not a related party of the investment
adviser or located at the same address as the investment adviser.
7. The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an
annual notice reconfirming the instruction.
I T E M 1 6 - D I S C R E T I O N
Before Prostatis can buy or sell securities on your behalf, the client must first sign our discretionary management
agreement, a limited power of attorney, and/or trading authorization forms. By choosing to do so, the client may
grant the Firm discretion over the selection and number of securities to be purchased or sold for the client’s
account(s) without obtaining your consent or approval prior to each transaction. Clients may impose limitations on
discretionary authority for investing in certain securities or types of securities (such as a product type, specific
companies, specific sectors, etc.), as well as other limitations as expressed by the client. Limitations on discretionary
authority are required to be provided to the IAR in writing. Please refer to the “Advisory Business” section of this
Brochure for more information on our discretionary management services.
In some instances, Prostatis may not have discretion. Prostatis will discuss all transactions with the client prior to
execution or the client will be required to make the trades in an employer sponsored account.
I T E M 1 7 - V O T I N G C L I E N T S E C U R I T I E S
As a matter of Prostatis policy, Prostatis does not vote proxies on behalf of clients. Therefore, it is your responsibility
to vote for all proxies for securities held in your Account. The client will receive proxies directly from the qualified
custodian or transfer agent; we will not provide the client with the proxies. Although we do not vote client proxies,
if the client does have a question about a particular proxy feel free to contact the custodian directly.
I T E M 1 8 - F I N A N C I A L
I N F O R M A T I O N
As an advisory firm that maintains discretionary authority for client accounts, Prostatis is also required to disclose
any financial condition that is reasonably likely to impair our ability to meet our contractual obligations. Prostatis
has no such financial circumstances to report. Under no circumstances do we require or solicit payment of fees in
4
2
April 2026
Prostatis Financial Advisors Group
e
g
a
P
excess of $1,200 per client more than six (6) months in advance of services rendered. Therefore, we are not required
to include a financial statement. Prostatis has not been the subject of a bankruptcy petition at any time during the
past ten (10) years.
5
2
April 2026
Prostatis Financial Advisors Group
e
g
a
P