Overview

Assets Under Management: $464 million
Headquarters: ATLANTA, GA
High-Net-Worth Clients: 155
Average Client Assets: $2 million

Frequently Asked Questions

SARD WEALTH MANAGMENT GROUP, LLC charges 1.00% on the first $1 million, 0.75% on the next $2 million, 0.50% on all assets according to their SEC Form ADV filing. See complete fee breakdown ↓

Yes. As an SEC-registered investment advisor (CRD #123457), SARD WEALTH MANAGMENT GROUP, LLC is subject to fiduciary duty under federal law.

SARD WEALTH MANAGMENT GROUP, LLC is headquartered in ATLANTA, GA.

SARD WEALTH MANAGMENT GROUP, LLC serves 155 high-net-worth clients according to their SEC filing dated February 10, 2026. View client details ↓

According to their SEC Form ADV, SARD WEALTH MANAGMENT GROUP, LLC offers financial planning, portfolio management for individuals, and pension consulting services. View all service details ↓

SARD WEALTH MANAGMENT GROUP, LLC manages $464 million in client assets according to their SEC filing dated February 10, 2026.

According to their SEC Form ADV, SARD WEALTH MANAGMENT GROUP, LLC serves high-net-worth individuals and pension and profit-sharing plans. View client details ↓

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting

Fee Structure

Primary Fee Schedule (SWMG FORM ADV 2A-2B DISCLOSURE BROCHURE AND BROCHURE SUPPLEMENT)

MinMaxMarginal Fee Rate
$0 $1,000,000 1.00%
$1,000,001 $2,000,000 0.75%
$2,000,001 and above 0.50%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,000 1.00%
$5 million $32,500 0.65%
$10 million $57,500 0.58%
$50 million $257,500 0.52%
$100 million $507,500 0.51%

Clients

Number of High-Net-Worth Clients: 155
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 82.23
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 1,127
Discretionary Accounts: 1,114
Non-Discretionary Accounts: 13
Minimum Account Size: $1,000,000
Note on Minimum Client Size: $1,000,000

Regulatory Filings

CRD Number: 123457
Filing ID: 2049219
Last Filing Date: 2026-02-10 13:48:34

Form ADV Documents

Primary Brochure: SWMG FORM ADV 2A-2B DISCLOSURE BROCHURE AND BROCHURE SUPPLEMENT (2026-02-10)

View Document Text
Sard Wealth Management Group, LLC Form ADV Part 2A – Disclosure Brochure Effective: February 10, 2026 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Sard Wealth Management Group, LLC (“SWMG” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (404) 843-4483 or by email at ethruston@sardwealth.com. SWMG is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about SWMG to assist you in determining whether to retain the Advisor. Additional information about SWMG and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 123457. Sard Wealth Management Group, LLC 5607 Glenridge Drive, Suite 275, Building II Atlanta, GA 30342 Phone: (404) 843-4483 | Fax: (404) 236-7310 www.sardwealth.com Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the “Disclosure Brochure”) and Part 2B (the “Brochure Supplement”). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of SWMG. For convenience, the Advisor has combined these documents into a single disclosure document. SWMG believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. SWMG encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes There have been no material changes made to this Disclosure Brochure since the last annual amendment filing on February 6, 2025. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations, or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure online at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 123457. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (404) 843-4483 or by email at ethruston@sardwealth.com. Sard Wealth Management Group, LLC 5607 Glenridge Drive, Suite 275, Building II, Atlanta, GA 30342 Phone: (404) 843-4483 | Fax: (404) 236-7310 www.sardwealth.com Page 2 Item 3 – Table of Contents Item 1 – Cover Page ...................................................................................................................................... 1 Item 2 – Material Changes ............................................................................................................................ 2 Item 3 – Table of Contents ........................................................................................................................... 3 Item 4 – Advisory Services .......................................................................................................................... 4 A. Firm Information ................................................................................................................................................ 4 B. Advisory Services Offered ................................................................................................................................. 4 C. Client Account Management ............................................................................................................................. 6 D. Wrap Fee Programs .......................................................................................................................................... 6 E. Assets Under Management ............................................................................................................................... 6 Item 5 – Fees and Compensation ................................................................................................................ 7 A. Fees for Advisory Services ................................................................................................................................ 7 B. Fee Billing .......................................................................................................................................................... 8 C. Other Fees and Expenses ................................................................................................................................ 8 D. Advance Payment of Fees and Termination ..................................................................................................... 9 E. Compensation for Sales of Securities ............................................................................................................... 9 Item 6 – Performance-Based Fees and Side-By-Side Management ......................................................... 9 Item 7 – Types of Clients ............................................................................................................................ 10 Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss .............................................. 10 A. Methods of Analysis ........................................................................................................................................ 10 B. Risk of Loss ..................................................................................................................................................... 10 Item 9 – Disciplinary Information .............................................................................................................. 12 Item 10 – Other Financial Industry Activities and Affiliations ................................................................ 12 Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading .... 13 A. Code of Ethics ................................................................................................................................................. 13 B. Personal Trading with Material Interest ........................................................................................................... 13 C. Personal Trading in Same Securities as Clients ............................................................................................. 13 D. Personal Trading at Same Time as Client ...................................................................................................... 13 Item 12 – Brokerage Practices ................................................................................................................... 13 A. Recommendation of Custodian[s] ................................................................................................................... 13 B. Aggregating and Allocating Trades ................................................................................................................. 14 Item 13 – Review of Accounts ................................................................................................................... 14 A. Frequency of Reviews ..................................................................................................................................... 14 B. Causes for Reviews ........................................................................................................................................ 14 C. Review Reports ............................................................................................................................................... 14 Item 14 – Client Referrals and Other Compensation ............................................................................... 15 A. Compensation Received by SWMG ................................................................................................................ 15 B. Compensation for Client Referrals .................................................................................................................. 15 Item 15 – Custody ....................................................................................................................................... 15 Item 16 – Investment Discretion ................................................................................................................ 16 Item 17 – Voting Client Securities ............................................................................................................. 16 Item 18 – Financial Information ................................................................................................................. 16 Form ADV Part 2B – Brochure Supplement ............................................................................................. 17 Privacy Policy ............................................................................................................................................. 23 Sard Wealth Management Group, LLC 5607 Glenridge Drive, Suite 275, Building II, Atlanta, GA 30342 Phone: (404) 843-4483 | Fax: (404) 236-7310 www.sardwealth.com Page 3 Item 4 – Advisory Services A. Firm Information Sard Wealth Management Group, LLC (“SWMG” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (LLC) under the laws of the State of Georgia. SWMG was founded in 2007 and is owned and operated by Jonathan Sard (President and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by SWMG. B. Advisory Services Offered SWMG offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, retirement plans, and other financial institutions (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness, and good faith towards each Client and seeks to mitigate potential conflicts of interest. SWMG’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services SWMG provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. SWMG works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. SWMG will then construct an investment portfolio consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks and bonds to meet the needs of its Clients. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. SWMG will select, recommend and/or retain mutual funds on a fund by fund basis. Due to specific custodial and/or mutual fund company constraints, material tax consideration, and/or systematic investment plans, SWMG will select, recommend and/or retain mutual fund share classes that do not have trading costs but do have higher internal expense ratios than institutional share classes. SWMG will seek to select the lowest cost share class available that is in the best interest of each Client and will ensure the selection aligns with the Client’s financial objectives and stated investment guidelines. SWMG’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. SWMG will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. SWMG evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. SWMG may recommend, on occasion, redistributing investment allocations to diversify the portfolio. SWMG may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. SWMG may recommend selling positions for reasons that include but are not limited to harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. The Advisor may introduce certain Clients to a Pledged Asset Line®, a non-purpose revolving line of credit made available through Charles Schwab Bank, secured by eligible assets held in an account maintained at the Custodian (“Lending Program”). In such instances, the Client’s assets in their account[s] at the Custodian will be Sard Wealth Management Group, LLC 5607 Glenridge Drive, Suite 275, Building II, Atlanta, GA 30342 Phone: (404) 843-4483 | Fax: (404) 236-7310 www.sardwealth.com Page 4 utilized as collateral for a non-purpose revolving line of credit. The recommendation of a Lending Program presents a conflict of interest as the Advisor will continue to receive investment advisory fees for managing the collateralized assets in the Client’s account[s]. Clients are not obligated to engage the Advisor for the Lending Program. For additional information related to the risks involved with non-purpose loans and lines of credit, please see Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss. Annuity Management – As part of the SWMG’s investment management services, the Advisor may be engaged to manage annuities on behalf of the Client. The Advisor will implement, manage, and monitor these assets in accordance with the agreed upon investment objectives of the Client. Held-Away Asset Management- As part of the Advisor’s Investment Management Services, when appropriate, the Advisor will use a third party platform to facilitate management of held away assets with discretion. The platform allows the Advisor to avoid being considered to have custody of Client funds since the Advisor does not have direct access to Client log-in credentials to affect trades. The Advisor is not affiliated with the platform in any way and does not receive compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, the Advisor will review the current account allocations. When deemed necessary, the Advisor will rebalance the account considering client investment goals and risk tolerance. Client account(s) will be reviewed periodically and allocation changes will be made as deemed necessary. Retirement Plan Accounts – When deemed to be in the Client’s best interest, the Advisor will recommend that a Client rollover its retirement plan account into an account managed by the Advisor. In such instances, the Advisor will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). Such a recommendation creates a conflict of interest if the Advisor earns a new (or increases its current) advisory fee as a result of the rollover. No Client is under any obligation to roll over retirement plan assets to an account managed by the Advisor. At no time will SWMG accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 - Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Financial Planning Services SWMG will typically provide a variety of financial planning and consulting services to Clients, either as a component of investment management services or pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to investment planning, retirement planning, personal savings, education savings, insurance needs, and other areas of a Client’s financial situation. A financial plan developed for or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings, and/or charitable giving programs. SWMG may also refer Clients to an accountant, attorney, or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of the contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any Sard Wealth Management Group, LLC 5607 Glenridge Drive, Suite 275, Building II, Atlanta, GA 30342 Phone: (404) 843-4483 | Fax: (404) 236-7310 www.sardwealth.com Page 5 recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Retirement Plan Advisory Services SWMG provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: Investment Policy Statement (“IPS”) Design and Monitoring Investment Oversight Services (ERISA 3(21)) Investment Management Services (ERISA 3(38)) ● Vendor Analysis ● Plan Participant Enrollment and Education Tracking ● ● ● ● Performance Reporting ● Ongoing Investment Recommendation and Assistance These services are provided by SWMG serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of SWMG’s fiduciary status, the specific services to be rendered, and all direct and indirect compensation the Advisor reasonably expects under the engagement. Financial Institution Consulting Services SWMG provides investment consulting services to brokerage customers (herein “Brokerage Customers”) of Mutual Securities, Inc. (herein “MSI”) who provide written consent requesting to receive the Advisor’s consulting services, pursuant to a written agreement with SWMG. Consulting services are strictly on products Clients have purchased through Mutual Securities, Inc. Please see Item 10 – Other Financial Industry Activities and Affiliations for additional details. C. Client Account Management Prior to engaging SWMG to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority, and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – SWMG, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – SWMG will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation, and tolerance for risk for each Client. • Portfolio Construction – SWMG will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – SWMG will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs SWMG does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by SWMG. E. Assets Under Management As of December 31, 2025, SWMG manages $463,973,082 in Client assets, of which $430,708,757 are managed on a discretionary basis, and $33,264,325 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. Sard Wealth Management Group, LLC 5607 Glenridge Drive, Suite 275, Building II, Atlanta, GA 30342 Phone: (404) 843-4483 | Fax: (404) 236-7310 www.sardwealth.com Page 6 Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written agreement with the Advisor. A. Fees for Advisory Services Investment Management Services Investment advisory fees are paid quarterly, at the end of each calendar quarter, pursuant to the terms of the investment advisory agreement. Investment advisory fees are based on the market value of assets under management at the end of each calendar quarter. Investment advisory fees are based on the following schedule: Assets Under Management ($) Annual Rate (%) First to $1,000,000 Next to $1,000,000 Over to $2,000,000 1.00% 0.75% 0.50% The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by SWMG will be independently valued by the Custodian. SWMG will conduct periodic reviews of the Custodian’s valuations. Certain legacy clients may be billed under a different fee schedule. Fees for annuity management are paid quarterly at the end of each calendar quarter. Fees will be charged an annual flat rate of up to 1.00%, based on the total value of annuities managed on the last day of each calendar quarter. Fees will not be adjusted to account for inflows and/or outflows during the billing period. Held-Away Asset Management- Fees associated with the Held-Away Asset Management will be paid quarterly, pursuant to the terms of the agreement. These fees will range up to 1.00% annually, based on the average daily balance of the assets under management at the end of the quarter. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction fees and custody fees and other related costs and expenses, described in Item 5.C. below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Financial Planning Services SWMG offers financial planning services either on an hourly or fixed fee basis. Hourly fees range from $250 to $500 per hour. Fixed fees range from $500 to $10,000 per engagement. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and total costs will be provided to the Client prior to engaging in these services. For clients that pay for financial plans, we provide additional advice for a 12-month period at no additional cost. In each successive year that the Client pays for an updated financial plan, we provide the same access to advice at no additional cost. Retirement Plan Advisory Services Retirement Plan Advisory fees are paid quarterly, at the end of each calendar quarter, pursuant to the terms of the retirement plan agreement. Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. Retirement Plan Advisory fees are based on the market value of assets under management at the end of the calendar quarter. Fees are based on the following schedule: Assets Under Management ($) Annual Rate (%) First $1,000,000 Next $1,000,000 Over $2,000,000 1.00% 0.75% 0.50% Sard Wealth Management Group, LLC 5607 Glenridge Drive, Suite 275, Building II, Atlanta, GA 30342 Phone: (404) 843-4483 | Fax: (404) 236-7310 www.sardwealth.com Page 7 Fees may be negotiable depending on the size and complexity of the Plan. Financial Institution Consulting Services SWMG receives a consulting fee based on the assets under MSI’s management from Brokerage Customers who have provided written consent to MSI to receive the investment consulting services from SWMG. The consulting fee is calculated from the assets under MSI’s management at the end of the calendar quarter multiplied by the annualized rate up to 0.75%. The initial fee is paid only after the completion of one full calendar quarter period following the date of the executed agreement with MSI. B. Fee Billing Investment Management Services Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the respective quarter end date. The amount due is calculated by applying the quarterly rate (annual rate divided by the number of days in the quarter) to the total assets under management with SWMG at the end of each quarter. Investment advisory fees are adjusted for inflows and outflows of greater than 10% of the Client’s total portfolio value that occur during the quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting the deduction of the investment advisory fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide written authorization permitting advisory fees to be deducted by SWMG to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Held-Away Asset Management- Investment advisory fees are calculated by the third party platform and deducted from the Client’s account(s). The amount due is calculated by applying the quarterly rate (annual rate divided by the number of days in the quarter) to the average daily balance of the assets throughout the quarter. Retirement Plan Advisory Services Retirement Plan Advisory fees may be directly invoiced to the Plan sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. Financial Planning Services Financial planning fees are invoiced by the Advisor and are due upon completion of the agreed upon deliverable[s]. Financial Institution Consulting Services MSI shall calculate and pay SWMG for its consulting services on or before thirty (30) days past the end of each calendar quarter. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties other than SWMG in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all securities execution fees and custody fees charged by the Custodian if applicable. The Advisor’s recommended Custodian does not charge securities transaction fees for ETF and equity trades in Client accounts, provided that the Client’s accounts meet the terms and conditions of the Custodian’s brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The fees charged by SWMG are separate and distinct from these custody and execution fees. In addition, all fees paid to SWMG for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage, and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of SWMG, but would not receive the services provided by SWMG, which are designed, among other things, to Sard Wealth Management Group, LLC 5607 Glenridge Drive, Suite 275, Building II, Atlanta, GA 30342 Phone: (404) 843-4483 | Fax: (404) 236-7310 www.sardwealth.com Page 8 assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by SWMG to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. Additionally, as noted above, the Advisor will select share classes that do not have trading costs but do have higher internal expense ratios than institutional share classes. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Investment Management Services SWMG may be compensated for its services at the end of the quarter after investment management services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination, and such fees will be due and payable by the Client. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Financial Planning Services SWMG is compensated for its services upon completion of the engagement deliverable[s]. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination, and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for actual hours logged on the planning project times the contractual hourly rate, or in the case of a fixed fee engagement, the percentage of the engagement scope completed by the Advisor. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. Retirement Plan Advisory Services SWMG is compensated for its services at the end of the quarter after advisory services are rendered. Either party may terminate the retirement plan advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the retirement plan advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination, and such fees will be due and payable by the Client. The Client’s retirement plan advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Financial Institution Consulting Services Either party may terminate the consulting agreement by providing thirty (30) days advance written notice to the other party. The Advisor will be entitled to fees up to the date of termination. E. Compensation for Sales of Securities SWMG does not buy or sell securities to generate securities commissions and does not receive any compensation for securities transactions in any Client account other than the investment advisory fees noted above. Item 6 – Performance-Based Fees and Side-By-Side Management SWMG does not charge performance-based fees for its investment advisory services. The fees charged by SWMG are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. SWMG does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Sard Wealth Management Group, LLC 5607 Glenridge Drive, Suite 275, Building II, Atlanta, GA 30342 Phone: (404) 843-4483 | Fax: (404) 236-7310 www.sardwealth.com Page 9 Item 7 – Types of Clients SWMG offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, retirement plans, and other financial institutions. The amount of each type of Client is available on SWMG’s Form ADV Part 1A. These amounts may change over time and are updated at least annually by the Advisor. SWMG generally requires a minimum relationship size of $1,000,000 to effectively implement its investment process. This minimum may be waived at the sole discretion of the Advisor. Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis SWMG primarily employs fundamental and technical analysis methods in developing investment strategies for its Clients. Research and analysis from SWMG are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases, and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that SWMG will be able to accurately predict such a reoccurrence. As noted above, SWMG generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. SWMG will typically hold all or a portion of a security for more than a year but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, SWMG may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector, or asset class. B. Risk of Loss 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. SWMG will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. 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]. The Advisor shall rely on the financial and other information provided by the Sard Wealth Management Group, LLC 5607 Glenridge Drive, Suite 275, Building II, Atlanta, GA 30342 Phone: (404) 843-4483 | Fax: (404) 236-7310 www.sardwealth.com Page 10 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 the Advisor of any changes in financial condition, goals, or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment approach: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Fixed Income Risks Fixed Income Securities are subject to specific risks, including the following: (1) interest rate risks, i.e., the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e., the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e., the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e., the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e., the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e., the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore, a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Digital Assets Risks Digital assets are highly speculative and volatile investments that may become illiquid at any time. Digital assets are loosely regulated. Clients could lose the entire value of their investment in digital assets and is only suitable for Clients with high risk tolerances. Cryptocurrency ETF Risks Cryptocurrency ETFs are investment vehicles designed to provide exposure to the price movements of cryptocurrencies or cryptocurrency-related assets through exchange-listed securities. Cryptocurrencies and cryptocurrency-related markets are highly volatile. Prices may fluctuate dramatically over short periods of time due to factors including, but not limited to, market sentiment, technological developments, macroeconomic events, regulatory actions, and changes in liquidity. As a result, Cryptocurrency ETFs may experience rapid and substantial losses. A Cryptocurrency ETF’s performance may differ materially from the crypto market exposure it seeks to provide due to fees and expenses, portfolio construction and rebalancing, and the use of derivatives, and during periods of market stress liquidity may decline, bid-ask spreads may widen, shares may trade above or below the value of underlying holdings, and trading may be halted or limited, which may prevent buying or selling at desired times or prices. Sard Wealth Management Group, LLC 5607 Glenridge Drive, Suite 275, Building II, Atlanta, GA 30342 Phone: (404) 843-4483 | Fax: (404) 236-7310 www.sardwealth.com Page 11 Options Contracts Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can compound gains or losses. Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Non-Purpose Loans and Lines of Credit Non-purpose loans and lines of credit carry a number of risks, including but not limited to the risk of a market downturn, tax implications if collateralized securities are liquidated, and an increase in interest rates. A decline in the market value of collateralized securities held in the account[s] at the Custodian, may result in a reduction in the draw amount of the Client’s line of credit, a demand from the Lending Program that the Client deposit additional funds or securities in the Client’s collateral account[s], or a forced sale of securities in the Client’s collateral account[s]. Past performance is not a guarantee of future returns. Investing in securities and other investments involves a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory, or disciplinary events involving SWMG or its owner. SWMG values the trust you place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor and its Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 123457. Item 10 – Other Financial Industry Activities and Affiliations Financial Institution Consulting Services SWMG has an agreement with MSI to provide investment consulting services to Brokerage Customers, as noted in Item 4 – Advisory Services. MSI compensates SWMG for providing consulting services to Clients who have purchased products through MSI. This consulting arrangement does not include assuming discretionary authority over Brokerage Customers’ brokerage accounts or the monitoring of securities. These consulting services offered to Brokerage Customers includes a general review of Brokerage Customers’ investment holdings, which will result in SWMG’s Advisory Persons making specific securities recommendations or offering general investment advice. This relationship presents conflicts of interest. Potential conflicts are mitigated by Brokerage Customers consenting to receive consulting services from SWMG. In addition, SWMG will not accept or bill for additional compensation on asset under MSI’s management, beyond the consulting fees disclosed in Item 5 above. Advisory Persons of the Advisor will not engage or hold itself as a registered representative of MSI, as Advisory Persons are not registered to conduct commission based activities under a broker-dealer. Insurance Agency Affiliations Jonathan Sard is also a licensed insurance professional. Implementations of insurance recommendations are separate and apart from one’s role with SWMG. As an insurance professional, Mr. Sard will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Mr. Sard is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by Mr. Sard or the Advisor. Sard Wealth Management Group, LLC 5607 Glenridge Drive, Suite 275, Building II, Atlanta, GA 30342 Phone: (404) 843-4483 | Fax: (404) 236-7310 www.sardwealth.com Page 12 Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading A. Code of Ethics SWMG has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with SWMG (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to you, the Client. SWMG and its Supervised Persons owe a duty of loyalty, fairness, and good faith towards each Client. It is the obligation of SWMG’s Supervised Persons to adhere not only to the specific provisions of the Code but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (404) 843-4483 or via email at ethruston@sardwealth.com. B. Personal Trading with Material Interest SWMG allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. SWMG does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund or advise an investment company. SWMG does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients SWMG allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls), gifts and entertainment, outside business activities, and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades or by trading based on material non-public information. This risk is mitigated by SWMG requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While SWMG allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. At no time will SWMG, or any Supervised Person of SWMG, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] SWMG does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize SWMG to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, SWMG does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where SWMG does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by SWMG. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. SWMG may recommend the Custodian based on criteria such as, but not limited to, the reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. Sard Wealth Management Group, LLC 5607 Glenridge Drive, Suite 275, Building II, Atlanta, GA 30342 Phone: (404) 843-4483 | Fax: (404) 236-7310 www.sardwealth.com Page 13 SWMG will generally recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified custodian”. SWMG maintains an institutional relationship with Schwab, whereby the Advisor receives economic benefits from Schwab. Please see Item 14 below. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars – Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. SWMG does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals – SWMG does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage – All Clients are serviced on a “directed brokerage basis,” where SWMG will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). SWMG will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. SWMG will execute its transactions through the Custodian as authorized by the Client. SWMG may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts on the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre- allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Jonathan Sard, CCO of SWMG. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify SWMG if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage Sard Wealth Management Group, LLC 5607 Glenridge Drive, Suite 275, Building II, Atlanta, GA 30342 Phone: (404) 843-4483 | Fax: (404) 236-7310 www.sardwealth.com Page 14 statements will include all positions, transactions, and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by SWMG SWMG may refer Clients to various unaffiliated, non-advisory professionals (e.g., attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, SWMG may receive non-compensated referrals of new Clients from various third parties. Some mutual fund companies provide marketing support to SWMG. This support is often based on the amount of business that SWMG does with these companies, however, SWMG is not aware of any predetermined formula. The receipt of marketing assistance is a benefit for SWMG and presents a conflict of interest. SWMG mitigates this conflict of interest by notifying you of the conflict and informing you that you are free to consult other financial professionals. We also mitigate this conflict by not selecting products as a result of any monetary or non-monetary assistance. Participation in Institutional Advisor Platform SWMG has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like SWMG. As a registered investment advisor participating on the Schwab Advisor Services platform, SWMG receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a potential conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to SWMG that may not benefit the Client, including: educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest. SWMG believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. B. Compensation for Client Referrals The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place all assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and Sard Wealth Management Group, LLC 5607 Glenridge Drive, Suite 275, Building II, Atlanta, GA 30342 Phone: (404) 843-4483 | Fax: (404) 236-7310 www.sardwealth.com Page 15 securities and direct the Advisor to utilize that Custodian for security transactions in the account[s]. The Client should review statements provided by the Custodian, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions. Item 16 – Investment Discretion SWMG generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by SWMG. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by SWMG will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities SWMG does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither SWMG nor its management has any adverse financial situations that would reasonably impair the ability of SWMG to meet all obligations to its Clients. Neither SWMG nor any of its Advisory Persons have been subject to a bankruptcy or financial compromise. SWMG is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Sard Wealth Management Group, LLC 5607 Glenridge Drive, Suite 275, Building II, Atlanta, GA 30342 Phone: (404) 843-4483 | Fax: (404) 236-7310 www.sardwealth.com Page 16 Form ADV Part 2B – Brochure Supplement for Jonathan Sard, CFP® President and Chief Compliance Officer Effective: February 10, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Jonathan Sard, CFP®, (CRD# 2330785) in addition to the information contained in the Sard Wealth Management Group, LLC (“SWMG” or the “Advisor,” CRD# 123457) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the SWMG Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (404) 843-4483 or by email at ethruston@sardwealth.com. Additional information about Mr. Sard is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or individual CRD# 2330785. Sard Wealth Management Group, LLC 5607 Glenridge Drive, Suite 275, Building II, Atlanta, GA 30342 Phone: (404) 843-4483 | Fax: (404) 236-7310 www.sardwealth.com Page 17 Item 2 – Educational Background and Business Experience Jonathan Sard, CFP®, born in 1970 in New York, is dedicated to advising Clients of SWMG as the President and Chief Compliance Officer. Mr. Sard earned a Bachelor of Science in Business Administration from the University of Florida in 1992. Sard Wealth Management Group, LLC (SWMG) has been in business under this name since 2007. Prior to that, the company used the name Financial Alternatives, Inc. Jonathan Sard, the sole owner of the company, has been a financial advisor and planner since 1992 and created a registered investment advisor (“RIA”) firm in 1997. Additional information regarding Mr. Sard’s employment history is included below. Employment History: President and Chief Compliance Officer, Sard Wealth Management Group, LLC Registered Representative, Purshe Kaplan Sterling Investments, Inc. Registered Representative, Securities Service Network, LLC 08/2007 to Present 07/2020 to 04/2024 08/2002 to 07/2020 CERTIFIED FINANCIAL PLANNER® Professional I am certified for financial planning services in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER® professional or a CFP® professional, and I may use these and the other certification marks (the “CFP Board Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning, Inc. has licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state law or regulation requires financial planners to hold the CFP® certification. You may find more information about the CFP® certification at www.cfp.net. CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics. To become a CFP® professional, an individual must fulfill the following requirements: • Education – Earn a bachelor’s degree or higher from an accredited college or university and complete CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The coursework covers the financial planning subject areas CFP Board has determined are necessary for the competent and professional delivery of financial planning services, as well as a comprehensive financial plan development capstone course. A candidate may satisfy some of the coursework requirement through other qualifying credentials. CFP Board implemented the bachelor’s degree or higher requirement in 2007 and the financial planning development capstone course requirement in March 2012. Therefore, a CFP® professional who first became certified before those dates may not have earned a bachelor’s or higher degree or completed a financial planning development capstone course. • Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the context of real-life financial planning situations. • Experience – Complete 6,000 hours of professional experience related to the personal financial planning process, or 4,000 hours of apprenticeship experience that meets additional requirements. • Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements to remain certified and maintain the right to continue to use the CFP Board Certification Marks: • Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the Sard Wealth Management Group, LLC 5607 Glenridge Drive, Suite 275, Building II, Atlanta, GA 30342 Phone: (404) 843-4483 | Fax: (404) 236-7310 www.sardwealth.com Page 18 Client, at all times when providing financial advice and financial planning. CFP Board may sanction a CFP® professional who does not abide by this commitment, but CFP Board does not guarantee a CFP® professional's services. A Client who seeks a similar commitment should obtain a written engagement that includes a fiduciary obligation to the Client. Continuing Education – Complete 30 hours of continuing education every two years to maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with developments in financial planning. Two of the hours must address the Code and Standards. Item 3 – Disciplinary Information There are no legal, civil, or disciplinary events to disclose regarding Mr. Sard. Mr. Sard has never been involved in any regulatory, civil, or criminal action. There have been no client complaints, lawsuits, arbitration claims, or administrative proceedings against Mr. Sard. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil, or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair, or unethical practices. As previously noted, there are no legal, civil, or disciplinary events to disclose regarding Mr. Sard. However, the Advisor encourages you to independently view the background of Mr. Sard on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or individual CRD# 2330785. Item 4 – Other Business Activities Insurance Agency Affiliations Mr. Sard is also a licensed insurance professional. Implementations of insurance recommendations are separate and apart from Mr. Sard’s role with SWMG. As an insurance professional, Mr. Sard will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Mr. Sard is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by Mr. Sard or the Advisor. Mr. Sard spends approximately 5% of his time per month in this capacity. Item 5 – Additional Compensation Mr. Sard has additional business activities where compensation is received that are detailed in Item 4 above. Item 6 – Supervision Mr. Sard serves as the President and Chief Compliance Officer of SWMG. Mr. Sard can be reached at (404) 843-4483. SWMG has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of SWMG. Further, SWMG is subject to regulatory oversight by various agencies. These agencies require registration by SWMG and its Supervised Persons. As a registered entity, SWMG is subject to examinations by regulators, which may be announced or unannounced. SWMG is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Sard Wealth Management Group, LLC 5607 Glenridge Drive, Suite 275, Building II, Atlanta, GA 30342 Phone: (404) 843-4483 | Fax: (404) 236-7310 www.sardwealth.com Page 19 Form ADV Part 2B – Brochure Supplement for Craig E. Bober, CFP® Client Relationship Manager Effective: February 10, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Craig E. Bober, CFP®, (CRD# 7775148) in addition to the information contained in the Sard Wealth Management Group, LLC (“SWMG” or the “Advisor”, CRD# 123457) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the SWMG Disclosure Brochure or this Brochure Supplement, please contact us at (404) 843-4483. Additional information about Mr. Bober is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 7775148. Sard Wealth Management Group, LLC 5607 Glenridge Drive, Suite 275, Building II, Atlanta, GA 30342 Phone: (404) 843-4483 | Fax: (404) 236-7310 www.sardwealth.com Page 20 Item 2 – Educational Background and Business Experience Craig E. Bober, CFP®, born in 2000, is dedicated to advising Clients of SWMG as a Client Relationship Manager. Mr. Bober earned a Bachelors of Business Administration in Finance from West Liberty University in 2019. Additional information regarding Mr. Bober’s employment history is included below. Employment History: Client Relationship Manager, Sard Wealth Management Group, LLC Client Service Associate, Osaic Student, West Liberty University 12/2023 to Present 06/2023 to 12/2023 08/2019 to 06/2023 CERTIFIED FINANCIAL PLANNER® Professional I am certified for financial planning services in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER® professional or a CFP® professional, and I may use these and the other certification marks (the “CFP Board Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning, Inc. has licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state law or regulation requires financial planners to hold the CFP® certification. You may find more information about the CFP® certification at www.cfp.net. CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics. To become a CFP® professional, an individual must fulfill the following requirements: • Education – Earn a bachelor’s degree or higher from an accredited college or university and complete CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The coursework covers the financial planning subject areas CFP Board has determined are necessary for the competent and professional delivery of financial planning services, as well as a comprehensive financial plan development capstone course. A candidate may satisfy some of the coursework requirement through other qualifying credentials. CFP Board implemented the bachelor’s degree or higher requirement in 2007 and the financial planning development capstone course requirement in March 2012. Therefore, a CFP® professional who first became certified before those dates may not have earned a bachelor’s or higher degree or completed a financial planning development capstone course. • Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the context of real-life financial planning situations. • Experience – Complete 6,000 hours of professional experience related to the personal financial planning process, or 4,000 hours of apprenticeship experience that meets additional requirements. • Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements to remain certified and maintain the right to continue to use the CFP Board Certification Marks: • Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the Client, at all times when providing financial advice and financial planning. CFP Board may sanction a CFP® professional who does not abide by this commitment, but CFP Board does not guarantee a CFP® professional's services. A Client who seeks a similar commitment should obtain a written engagement that includes a fiduciary obligation to the Client. Sard Wealth Management Group, LLC 5607 Glenridge Drive, Suite 275, Building II, Atlanta, GA 30342 Phone: (404) 843-4483 | Fax: (404) 236-7310 www.sardwealth.com Page 21 • Continuing Education – Complete 30 hours of continuing education every two years to maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with developments in financial planning. Two of the hours must address the Code and Standards. Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Bober. Mr. Bober has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Bober. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Bober. However, we do encourage you to independently view the background of Mr. Bober on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 7775148. Item 4 – Other Business Activities Mr. Bober is dedicated to the investment advisory activities of SWMG’s Clients. Mr. Bober does not have any other business activities. Item 5 – Additional Compensation Mr. Bober is dedicated to the investment advisory activities of SWMG’s Clients. Mr. Bober does not receive any additional forms of compensation. Item 6 – Supervision Mr. Bober serves as a Client Relationship Manager of SWMG and is supervised by Jonathan Sard, the Chief Compliance Officer. Mr. Sard can be reached at (404) 843-4483. SWMG has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of SWMG. Further, SWMG is subject to regulatory oversight by various agencies. These agencies require registration by SWMG and its Supervised Persons. As a registered entity, SWMG is subject to examinations by regulators, which may be announced or unannounced. SWMG is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Sard Wealth Management Group, LLC 5607 Glenridge Drive, Suite 275, Building II, Atlanta, GA 30342 Phone: (404) 843-4483 | Fax: (404) 236-7310 www.sardwealth.com Page 22 Privacy Policy Effective: February 10, 2026 Our Commitment to You Sard Wealth Management Group, LLC (“SWMG” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. SWMG (also referred to as "we," "our," and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. SWMG does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address, and phone number[s] Income and expenses Email address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage, and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use, we maintain physical, procedural, and electronic security measures. These include such safeguards as secure passwords, encrypted file storage, and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Clients’ personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Sard Wealth Management Group, LLC 5607 Glenridge Drive, Suite 275, Building II, Atlanta, GA 30342 Phone: (404) 843-4483 | Fax: (404) 236-7310 www.sardwealth.com Page 23 How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No No Not Shared Yes Yes No Not Shared Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. Marketing Purposes SWMG does not disclose and does not intend to disclose personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where SWMG or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. Information About Former Clients SWMG does not disclose and does not intend to disclose non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (404) 843-4483 or via email at ethruston@sardwealth.com. Sard Wealth Management Group, LLC 5607 Glenridge Drive, Suite 275, Building II, Atlanta, GA 30342 Phone: (404) 843-4483 | Fax: (404) 236-7310 www.sardwealth.com Page 24