SMART MONEY GROUP, LLC

Item 1: Cover Page Part 2A of Form ADV: Firm Brochure July 2025 Smart Money Group, LLC 106 South Seaman Eastland, TX 76448 254-629-3866 www.SmartMoneyGroup.net This brochure provides information about the qualifications and business practices of Smart Money Group, LLC. If clients have any questions about the contents of this brochure, please contact us at 254-629-3866. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any State Securities Authority. Additional information about our firm is also available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #284187. Please note that the use of the term “registered investment adviser” and description of our firm and/or our associates as “registered” does not imply a certain level of skill or training. Clients are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise clients for more information on the qualifications of our firm and our employees.  Item 2: Material Changes This section of the Brochure will address only those “material changes” that have been incorporated since our last delivery or posting of this document on the SEC’s public disclosure website (IAPD) www.adviserinfo.sec.gov. The material changes in this brochure from the last annual updating amendment of Smart Money Group LLC on March 28, 2025 are described below. Material changes relate to Smart Money Group LLC’s policies, practices, or conflicts of interests only.  On July 1, 2025, Keith Dwyer replaced Jay Kasting as the Chief Compliance Officer. Added additional disclosure to Item 10 regarding the YOKE Core ETF  Item 4 – Added language describing advisory services we provide to exchange-traded funds. If you would like another copy of this Brochure, please download it from the SEC Website as indicated above or you may contact us at 254-629-3866. We encourage you to read this document in its entirety. ADV Part 2A – Firm Brochure Page 2 Smart Money Group, LLC  Item 3: Table of Contents Item 1: Cover Page .................................................................................................................................................................... 1 Item 2: Material Changes ....................................................................................................................................................... 2 Item 3: Table of Contents ....................................................................................................................................................... 3 Item 4: Advisory Business ..................................................................................................................................................... 4 Item 5: Fees & Compensation............................................................................................................................................... 6 Item 6: Performance-Based Fees & Side-By-Side Management ............................................................................. 8 Item 7: Types of Clients & Account Requirements ...................................................................................................... 8 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ..................................................................... 8 Item 9: Disciplinary Information ..................................................................................................................................... 12 Item 10: Other Financial Industry Activities & Affiliations ................................................................................... 12 Item 11: Code of Ethics, Participation, or Interest in Client Transactions & Personal Trading ............. 13 Item 12: Brokerage Practices ............................................................................................................................................ 14 Item 13: Review of Accounts or Financial Plans........................................................................................................ 16 Item 14: Client Referrals & Other Compensation ...................................................................................................... 16 Item 15: Custody .................................................................................................................................................................... 17 Item 16: Investment Discretion........................................................................................................................................ 18 Item 17: Voting Client Securities ..................................................................................................................................... 18 Item 18: Financial Information ......................................................................................................................................... 19 ADV Part 2A – Firm Brochure Page 3 Smart Money Group, LLC  Item 4: Advisory Business Our firm is dedicated to providing individuals and other types of clients with a wide array of investment advisory services. Our firm is a limited liability company formed under the laws of the State of Delaware in 2016. Our firm is owned by James Kennedy, Aaron Kennedy, and Angela Robinson. Our firm provides asset management and investment consulting services for many different types of clients to help meet their financial goals while remaining sensitive to risk tolerance and time horizons. As a fiduciary it is our duty to always act in the client’s best interest. This is accomplished in part by knowing the client. Our firm has established a service-oriented advisory practice with open lines of communication. Working with clients to understand their investment objectives while educating them about our process, facilitates the kind of working relationship we value. Types of Advisory Services Offered Portfolio Management: As part of our Portfolio Management services, Clients may be provided with standalone asset management or a combination of asset management and financial planning or consulting services. This service is designed to assist clients in meeting their financial goals through the use of a financial plan or consultation. Our firm conducts client meetings to understand their current financial situation, existing resources, financial goals, and tolerance for risk. Based on what is learned, an investment approach is presented to the client that may consist of individual stocks, bonds, Exchange Traded Funds (“ETFs”), options, mutual funds and other public and private securities or investments. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals, and objectives. Upon client request, our firm provides a summary of observations and recommendations for the planning or consulting aspects of this service. Financial Planning & Consulting: financial consultations rendered to clients usually Our firm provides a variety of standalone financial planning and consulting services to clients for the management of financial resources based upon an analysis of current situation, goals, and objectives. Financial planning services will typically involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass Investment Planning, Retirement Planning, Estate Planning, Family and Business Succession Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, or Business and Personal Financial Planning. Written include general financial plans or recommendations for a course of activity or specific actions to be taken by the clients. Implementation of the recommendations will be at the discretion of the client. Our firm provides clients with a summary of their financial situation, and observations for financial planning engagements. Financial consultations are not typically accompanied by a written summary of observations and recommendations, as the process is less formal than the planning service. Assuming ADV Part 2A – Firm Brochure Page 4 Smart Money Group, LLC  that all the information and documents requested from the client are provided promptly, plans or consultations are typically completed within 6 months of the client signing a contract with our firm. Referrals to Third-Party Money Managers: Our firm may utilize the services of a third-party money manager for the management of client accounts. Investment advice and trading of securities will only be offered by or through the chosen third-party money manager. Our firm will not offer advice on any specific securities or other investments in connection with this service. Prior to referring clients, our firm will provide initial due diligence on third party money managers and ongoing reviews of their management of client accounts. In order to assist in the selection of a third-party money manager, our firm will gather client information pertaining to financial situation, investment objectives, and reasonable restrictions to be imposed upon the management of the account. The investment management fees charged by the designated third-party money manager, together with the fees charged by the corresponding designated broker- dealer/custodian of the client’s assets, are exclusive of, and in addition to, the annual advisory fee charged by our firm. Our firm reviews third party money manager reports provided to the client at least annually. Our firm will contact clients from time to time in order to review their financial situation and objectives; communicate information to third party money managers as warranted; and, assist the client in understanding and evaluating the services provided by the third-party money manager. Clients will be expected to notify our firm of any changes in their financial situation, investment objectives, or account restrictions that could affect their financial standing. Note for IRA and Retirement Plan Clients: When we provide investment advice to you regarding your retirement plan account or individual retirement account, our firm is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so our firm operates under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Exchange-Traded Funds: Our firm acts as a discretionary sub-adviser to an actively-managed exchange-traded fund (“ETF”) that is an investment company registered under the Investment Company Act of 1940, as amended. We provide its investment advisory services in a sub-advisory capacity to Empowered Funds, LLC d.b.a. EA Advisers, the primary adviser to the ETF. The ETF is a series of EA Series Trust (the “Trust”) and is subject to the general supervision of the Board of Trustees of the Trust. Our firm is responsible for day-to-day management of the ETF’s security selection process. The ETF is managed in accordance with the guidelines and restrictions set forth in the ETF’s Prospectus and Statement of Additional Information and all respective regulatory guidelines or limitations. Please refer to Item 8 for information specific to the investment strategies. Tailoring of Advisory Services Our firm offers individualized investment advice to our Portfolio Management clients. General investment advice will be offered to our Financial Planning & Consulting, and Referrals to Third Party Money Management clients. Portfolio Management clients have the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would ADV Part 2A – Firm Brochure Page 5 Smart Money Group, LLC  entail in managing the account. Participation in Wrap Fee Programs A wrap fee program is an investment program wherein the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. Our firm does not participate in any wrap fee programs. Regulatory Assets Under Management As of December 31, 2024, our firm has $368,881,695 assets under management, all of which are managed on a discretionary basis. Item 5: Fees & Compensation Compensation for Our Advisory Services Portfolio Management: For our services, we charge a percentage of a client’s assets under our management, generally determined in accordance with the following annual fee schedule: FEE SCHEDULE Market Value of Assets Less than $250,000 $250,001 to $500,000 $500.001 to $1,000,000 $1,000,001 and over Rate* 1.5% 1.4% 1.3% 1.2% *Specified rate applies only to assets in that tier. Fees to be assessed will be outlined in the advisory agreement to be signed by the Client. Annualized fees are billed quarterly in advance based on the asset value of the client’s account at the end of the previous quarter as provided by third-party sources, such as pricing services, custodians, fund administrators, and client-provided sources. Cash and accrued interest will be included for billing purposes unless determined otherwise in our sole discretion. For the initial period, our fee will be prorated and paid, in arrears, based on the value of the account as of the last business day of the previous quarter. For accounts closed after the beginning of a new calendar quarter, our fees will be prorated and any unearned fees will be refunded to you. Fees are negotiable and will be deducted from client account(s). In rare cases, our firm will agree to directly invoice. As part of this process, Clients understand the following: a) The client’s independent custodian sends statements at least quarterly showing the market values for each security included in the Assets and all account disbursements, including the amount of the advisory fees paid to our firm; b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our ADV Part 2A – Firm Brochure Page 6 Smart Money Group, LLC  firm will send an invoice directly to the custodian; and c) If our firm sends a copy of our invoice to the client, a legend urging the comparison of information provided in our statement with those from the qualified custodian will be included. Financial Planning & Consulting: Our firm charges on an hourly or fixed fee basis for financial planning and consulting services. The total estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our engagement with the client. The maximum hourly fee to be charged will not exceed $350. Fixed fees will not exceed $50,000. The fee-paying arrangements for this service will be determined on a case- by-case basis and will be detailed in the signed consulting agreement. Clients will be invoiced directly for the fees. We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Clients Responsible for Fees Charged by Financial Institutions and Third-Party Money Managers: In connection with our management of an account, a client will incur fees and/or expenses separate from and in addition to our advisory fee. These additional fees may include transaction charges and the fees/expenses charged by any custodian, subadvisor, mutual fund, ETF, separate account manager (and the manager’s platform manager, if any), limited partnership, or other advisor, transfer taxes, odd lot differentials, exchange fees, interest charges, ADR processing fees, and any charges, taxes or other fees mandated by any federal, state or other applicable law, retirement plan account fees (where applicable), margin interest, brokerage commissions, mark-ups or mark-downs and other transaction-related costs, electronic fund and wire fees, and any other fees that reasonably may be borne by a brokerage account. For third-party money managers, clients should review each manager’s Form ADV 2A disclosure brochure and any contract they sign with the third-party money manager (in a dual contract relationship). The client is responsible for all such fees and expenses. Please see Item 12 of this brochure regarding brokerage practices. Termination & Refunds Either party may terminate the advisory agreement signed with our firm for Portfolio Management services in writing at any time. Upon notice of termination our firm will process a pro-rata refund of the unearned portion of the advisory fees charged in advance at the beginning of the quarter. Financial Planning & Consulting clients may terminate their agreement at any time before the delivery of a financial plan by providing written notice. For purposes of calculating refunds, all work performed by us up to the point of termination shall be calculated at the hourly fee currently in effect. Clients will receive a pro-rata refund of unearned fees based on the time and effort expended by our firm. Commissionable Securities Sales Our firm does not buy or sell securities and does not receive any compensation for securities transactions in any client account, other than the investment advisory fees noted above. However, certain advisory personnel of our firm, in their individual capacities, are registered representatives of an unaffiliated broker-dealer. In this capacity these individuals will engage in various types of securities or investment products transactions and will receive separate and typical compensation for doing so. In addition, representatives of our firm, in their individual capacities, are also are licensed as insurance professionals. Such persons earn commission-based compensation for selling insurance products to clients. ADV Part 2A – Firm Brochure Page 7 Smart Money Group, LLC  These practices present a conflict of interest since certain advisory personnel of our firm have an incentive to recommend investment and insurance products based on the compensation received, rather than on a client’s needs. We address this conflict through disclosure and strive to make recommendations which are in the best interests of its clients. Clients are under no obligation to purchase investment or insurance products through any person affiliated with our firm. Clients should understand that lower fees and/or commissions for comparable products may be available from other broker-dealers or insurance providers. Item 6: Performance-Based Fees & Side-By-Side Management Our firm does not charge performance-based fees. Item 7: Types of Clients & Account Requirements Our firm has the following types of clients:  Individuals and High Net Worth Individuals;  Trusts, Estates or Charitable Organizations;  Pension and Profit Sharing Plans;  Corporations, Limited Liability Companies and/or Other Business Types. Our minimum initial account value is $50,000; however, we may accept accounts for less than the minimum. Item 8: Methods of Analysis, Investment Strategies & Risk of Loss We may use the following methods of analysis or investment strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: 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. Charting: In this type of technical analysis, we review charts of market and security activity in an attempt to identify when the market is moving up or down and to predict when and how long the trend may last and when that trend might reverse. Cyclical Analysis: In this type of technical analysis, we measure the movements of a particular stock against the overall market in an attempt to predict the price movement of the security. Fixed Income Portfolio Management Investment Strategies: We believe that a conservative, risk- ADV Part 2A – Firm Brochure Page 8 Smart Money Group, LLC  averse approach to fixed income management will provide both steady incremental outperformance, and low relative volatility. The disciplined process we employ in an effort to realize this philosophy is generally grounded in four key decisions:  Constraint of portfolio duration within a narrow range relative to the benchmark in order to limit exposure to market and interest rate risk.  Strategic allocations to key sectors to add value relative to the benchmark.  Proactive management of term structure to add value in different yield curve environments.  Security selection based on rigorous credit and relative value analysis and broad diversification of nongovernment issuers. 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. Mutual Fund and/or ETF Analysis: We look at the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap in the underlying investments held in another fund(s) in the client’s portfolio. We also look at sector and style of the mutual funds(s) or ETF(s) to determine whether that strategy fits into the portfolio objectives. We also monitor the funds or ETFs in an attempt to determine if they are continuing to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the client’s portfolio. Long-Term Purchases: When utilizing this strategy, we may purchase securities with the idea of holding them for a relatively long time (typically held for at least a year). A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantage of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Typically, we employ this sub-strategy when we believe the securities to be well valued; and/or we want exposure to a particular asset class over time, regardless of the current projection for this class. The potential risks associated with this investment strategy involve a lower than expected return, for many years in a row. Lower-than-expected returns that last for a long time and/or that are severe in nature would have the impact of dramatically lowering the ending value of your portfolio, and thus could significantly threaten your ability to meet financial goals. Technical Analysis: We analyze past market movements and apply that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company. This presents a risk in that a poorly-managed or financially unsound company may underperform regardless of market movement. Third-Party Money Manager Analysis: We examine the experience, expertise, investment ADV Part 2A – Firm Brochure Page 9 Smart Money Group, LLC  philosophies, and past performance of independent third-party investment managers in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We monitor the manager’s underlying holdings, strategies, concentrations and leverage as part of our overall periodic risk assessment. Additionally, as part of our due-diligence process, we survey the manager’s compliance and business enterprise risks. A risk of investing with a third-party manager who has been successful in the past is that he/she may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a third-party manager’s portfolio, there is also a risk that a manager may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our clients. Moreover, as we do not control the manager’s daily business and compliance operations, we may be unaware of the lack of internal controls necessary to prevent business, regulatory, or reputational deficiencies. Sector Allocation: We may allocate client assets to various sectors of the fixed income market and equity market. These fixed income sectors include US Treasury obligations, federal agency securities, corporate notes, mortgage-backed securities and others, based on our quantitative and qualitative analysis in order to manage client exposure to a given sector and to provide exposure to sectors we believe have good value. The risk of sector allocation is that clients may not participate fully in an increase in value in any specific sector. The sectors for equities include the sectors of the overall as well as certain industries within these sectors. Short-Term Purchases: Short-Term purchases are categorized as investments sold within one year of their purchase. A short-term holding is primarily associated with trading to take advantage of short-term market volatility to produce a quick profit. Because of the nature of this strategy, it is common for holdings to deviate from expected trends, thus reducing profitability. It is also common for the number of trades to increase in order to open and close positions, resulting in increased ticketing and transaction charges. Black and White: We analyze investor patterns and the effects those behaviors have on the market. Certain behaviors in the market by investors have been observable and repeatable. We try to exploit those behaviors by either over or under weighting those investible strategies. The risk of this is that all behavioral strategies can underperform the overall market for periods of time and the weighting of these strategies can have a lower than expected return that the overall market. The investment vehicles used to implement this strategy are exchange traded funds, mutual funds, and stocks. The decision for what vehicle to use is based on the purity of the factor being invested and the cost. We can allocate a portion of the portfolio to a specific sector depending on that sector showing a mispricing due to behavioral effects. The portfolio is then weighted to either emphasize the volatility of the portfolio or to correlating to the overall market. We also use fixed income exchange traded funds and or mutual funds to adjust the portfolio to the client’s risk tolerance. Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may increase and the account(s) could enjoy a gain, it is also possible that the stock market may decrease and the account(s) could suffer a loss. It is important that clients understand the risks associated with investing in the stock market Because of the inherent risk of loss associated with investing, we are unable to represent, guarantee, or even imply that our services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. Investors should be aware that accounts are subject to the following risks: ADV Part 2A – Firm Brochure Page 10 Smart Money Group, LLC  • Stock Market Risk – The value of securities in the portfolio will fluctuate and, as a result, the value may decline suddenly or over a sustained period of time. • Managed Portfolio Risk – The manager’s investment strategies or choice of specific securities may be unsuccessful and may cause the portfolio to incur losses. • Industry Risk – The portfolio’s investments could be concentrated within one industry or group of industries. Any factors detrimental to the performance of such industries will disproportionately impact your portfolio. Investments focused in a particular industry are subject to greater risk and are more greatly impacted by market volatility than less concentrated investments. • Non-U.S. Securities Risk – Non-U.S. securities are subject to the risks of foreign currency fluctuations, generally higher volatility, and lower liquidity than U.S. securities, less developed securities markets and economic systems and political and economic instability. • Emerging Markets Risk – To the extent that your portfolio invests in issuers located in emerging markets, the risk may be heightened by political changes and changes in taxation or currency controls that could adversely affect the values of these investments. Emerging markets have been more volatile than the markets of developed countries with more mature economies. • Currency Risk – The value of your portfolio’s investments may fall as a result of changes in exchange rates. • Interest Rate Risk - The value of fixed income securities rises or falls based on the underlying interest rate environment. If rates rise, the value of most fixed income securities could go down. • Credit Risk - Most fixed income instruments are dependent on the underlying credit of the issuer. If we are wrong about the underlying financial strength of an issuer, we may purchase securities where the issuer is unable to meet its obligations. If this happens, your portfolio could sustain an unrealized or realized loss. • Inflation Risk - Most investments will sustain losses if inflation increases or the market anticipates increases in inflation. If we enter a period of moderate or heavy inflation, the purchasing power of your securities could go down. • ETF and Mutual Fund Risk – When we invest in an ETF or mutual fund for a client, the client will bear additional expenses based on its pro rata share of the ETFs or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds. Clients may also incur brokerage costs when purchasing ETFs. • Management Risk – Your investment with us varies with the success and failure of our investment strategies, research, analysis, and determination of portfolio securities. If our investment strategies do not produce the expected returns, the value of the investment may decrease. • Options Risk - Options on securities may be subject to greater fluctuations in value than an investment in the underlying securities. Purchasing and writing put and call options are highly specialized activities and entail greater than ordinary investment risks which could result in losses. ADV Part 2A – Firm Brochure Page 11 Smart Money Group, LLC  • Cybersecurity Risk - The computer systems, networks, and devices used by our firm and service providers to us and our clients to carry out routine business operations employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks, or devices potentially can be breached. Clients could be negatively impacted as a result of a cybersecurity breach. • Third Party Money Managers - SMG may select certain third party money managers to manage a portion of its clients’ assets. In these situations, the success of such recommendations relies to a great extent on the third party money managers’ ability to successfully implement their investment strategies. In addition, SMG generally may not have the ability to supervise the third party money managers on a day-to-day basis • Alternative Investments / Private Funds risk - Investing in alternative investments is speculative, not suitable for all clients, and intended for experienced and sophisticated investors who are willing to bear the high economic risks of the investment, which can include: • • restrictions on transferring interests in the investment; loss of all or a substantial portion of the investment due to leveraging, short-selling or other speculative investment practices; lack of liquidity in that there may be no secondary market for the investment and none expected to develop; • volatility of returns; • • potential lack of diversification and resulting higher risk due to concentration of trading authority when a single adviser is utilized; • absence of information regarding valuations and pricing; • delays in tax reporting; • • less regulation and higher fees than mutual funds; risks associated with the operations, personnel, and processes of the manager of the funds investing in alternative investments. In addition, our firm may invest client cash balances in money market funds, FDIC Insured Certificates of Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, our firm tries to achieve the highest return on client cash balances through relatively low- risk conservative investments. In most cases, at least a partial cash balance will be maintained in a money market account so that our firm may debit advisory fees for our services related to our Portfolio Management services, as applicable. Item 9: Disciplinary Information There are no legal or disciplinary events that are material to the evaluation of our advisory business or the integrity of our management. Item 10: Other Financial Industry Activities & Affiliations Broker-Dealer Affiliation SMG has management persons who are registered representatives of an unaffiliated broker-dealer. ADV Part 2A – Firm Brochure Page 12 Smart Money Group, LLC  Accounting Firm Affiliation SMG is the majority owner of Briscoe & Associates LLC, an accounting firm. From time to time, supervised persons of SMG may offer clients the services of Briscoe & Associates. This presents a conflict of interest as SMG and its owners receive compensation from Briscoe. SMG always acts in the best interest of the client and clients always have the right to decide whether or not to utilize the services of Briscoe & Associates. Clients should be aware that the ability to receive additional compensation by SMG and its management persons or employees creates conflicts of interest that impairs the objectivity of the Firm and these individuals when making advisory recommendations. SMG 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 that they have the right to decide to purchase recommended investment we collect, maintain and document accurate, complete and relevant client back-ground the Firm conducts regular reviews of each client advisory account to verify that all we periodically monitor these outside employment activities to verify that any conflicts of we educate our employees regarding the responsibilities of a fiduciary, including the need for • we disclose to clients the existence of all material conflicts of interest, including the potential for the Firm and our employees to earn compensation from advisory clients in addition to the Firm's advisory fees; • products from our employees or Related Companies; • information, including the client’s financial goals, objectives and risk tolerance; • recommendations made to a client are in the best interest of the client’s needs and circumstances; • we require that our 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; • interest continue to be properly addressed by the Firm; and • having a reasonable and independent basis for the investment advice provided to clients. Recommendation of Other Investment Advisers Our firm has a referral arrangement with other investment adviser(s) where we are compensated via a portion of the management fees collected by the recommended adviser(s) if a client elects to enter into an advisory relationship with that adviser. Clients should discuss the fee structure with the investment adviser and review the firm’s 2A Brochure. This arrangement creates a conflict of interest since our firm has an incentive to refer clients to such investment adviser(s) that compensate us with a portion of their management fees. We address this conflict through disclosure and strive to make recommendations which are in the best interests of our clients. However, clients are not obligated to work with any recommended investment advisers. Recommendation of YOKE Core ETF As previously mentioned in Section 4, we provide investment advisory services in a sub-advisory capacity to Empowered Funds, LLC d.b.a. EA Advisers, the primary adviser to the YOKE Core ETF. We often recommend this investment to our clients as part of our advisory services, which creates several conflicts of interest. Smart Money Group, in connection with the management of the YOKE Core ETF, has a contract with Empowered Funds, LLC d.b.a. EA Advisers where a minimum fee is guaranteed to Empowered Funds. If the asset levels do not remain high enough to meet the minimum fee guarantee, Smart Money Group has agreed to pay Empowered Funds the difference. This creates a conflict where Smart Money Group would be incentivized to recommend the YOKE Core ETF to maintain the minimum asset levels. This also creates a conflict of interest where Smart Money Group receives an advisory fee for managing client assets, as well ADV Part 2A – Firm Brochure Page 13 Smart Money Group, LLC  as an advisory fee for managing the same assets in the YOKE Core ETF. This provides an incentive for Smart Money Group to recommend the YOKE Core ETF to obtain additional fees. These conflicts are managed through Smart Money Group’s fiduciary duty, and they will not invest separately managed account assets in the YOKE Core ETF unless such actions are in the best interest of the Client when considering investment objectives, fees, expenses and tax consequences. The management and other services provided by Smart Money Group for advising the YOKE Core ETF are in addition to their regular advisory services and are not duplicative. Item 11: Code of Ethics, Participation, or Interest in Client Transactions & Personal Trading As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. Our fiduciary duty is the underlying principle for our firm’s Code of Ethics, which includes procedures for personal securities transaction and insider trading. Our firm requires all representatives to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment with our firm, and at least annually thereafter, all representatives of our firm will acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and representatives must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. If a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. Our firm recognizes that the personal investment transactions of our representatives demands the application of a Code of Ethics with high standards and requires that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, our firm also believes that if investment goals are similar for clients and for our representatives, it is logical, and even desirable, that there be common ownership of some securities. In order to prevent conflicts of interest, our firm has established procedures for transactions effected by our representatives for their personal accounts. In order to monitor compliance with our personal trading policy, our firm has pre-clearance requirements and a quarterly securities transaction reporting system for all of our representatives. Neither our firm nor a related person recommends, buys or sells for client accounts, securities in which our firm or a related person has a material financial interest without prior disclosure to the client. Related persons of our firm may buy or sell securities and other investments that are also recommended to clients. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Likewise, related persons of our firm may buy or sell securities for themselves at or about the same time they buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying or selling the same securities prior to buying or selling for our clients in the same day unless included in a block trade. ADV Part 2A – Firm Brochure Page 14 Smart Money Group, LLC  Item 12: Brokerage Practices Selecting a Brokerage Firm Our firm does not maintain physical custody of client assets. Client assets must be maintained by a qualified custodian. Our firm seeks to recommend a custodian who will hold client assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. We recommend Charles Schwab & Co., Inc. Advisor Services. The factors considered, among others, are these:  Timeliness of execution  Timeliness and accuracy of trade confirmations  Research services provided  Ability to provide investment ideas  Execution facilitation services provided  Record keeping services provided  Custody services provided  Frequency and correction of trading errors  Ability to access a variety of market venues  Expertise as it relates to specific securities  Financial condition  Business reputation  Quality of services With this in consideration, our firm has arrangements with Charles Schwab, qualified custodians from whom our firm is independently owned and operated. Both offer services to independent investment advisers which include custody of securities, trade execution, clearance, and settlement of transactions. Client accounts will be charged transaction fees, commissions or other fees on trades that are executed or settle into the client’s custodial account. Transaction fees are negotiated with the custodians and are generally discounted from customary retail commission rates. This benefits clients because the overall fee paid is often lower than would be otherwise. Our clients may pay a transaction fee or commission to the custodian that is higher than another qualified broker dealer might charge to affect the same transaction where our firm determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services provided to the client as a whole. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients, our firm may not necessarily obtain the lowest possible commission rates for specific client account transactions. Soft Dollars Our firm does not receive soft dollars benefits from any broker-dealer firm in connection with client transactions. Client Transactions in Return for Soft Dollars ADV Part 2A – Firm Brochure Page 15 Smart Money Group, LLC  Our firm does not direct client transactions to a particular broker-dealer in return for soft dollar benefits. Brokerage for Client Referrals Our firm does not receive brokerage stipends or incentives for client referrals to a particular custodian. Directed Brokerage Our firm allows clients to direct brokerage outside our recommendation. Our firm may be unable to achieve the most favorable execution of client transactions. Client directed brokerage may cost clients more money. For example, in a directed brokerage account, clients may pay higher brokerage commissions because our firm may not be able to aggregate orders to reduce transaction costs, or clients may receive less favorable prices. In certain instances, clients may seek to limit or restrict our discretionary authority in making the determination of the brokers with whom orders for the purchase or sale of securities are placed for execution, and the commission rates at which such securities transactions are effected. Clients may seek to limit our authority in this area by directing that transactions (or some specified percentage of transactions) be executed through specified brokers in return for portfolio evaluation or other services deemed by the client to be of value. Any such client direction must be in writing (often through our advisory agreement), and may contain a representation from the client that the arrangement is permissible under its governing laws and documents, if this is relevant. Our firm provides appropriate disclosure in writing to clients who direct trades to particular brokers, that with respect to their directed trades, they will be treated as if they have retained the investment discretion that our firm otherwise would have in selecting brokers to effect transactions and in negotiating commissions and that such direction may adversely affect our ability to obtain best price and execution. In addition, our firm will inform clients in writing that the trade orders may not be aggregated with other clients’ orders and that direction of brokerage may hinder best execution. Special Considerations for ERISA Clients A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such direction is permitted provided that the goods and services provided are reasonable expenses of the plan incurred in the ordinary course of its business for which it otherwise would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the plan. Consequently, our firm will request that plan sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will be for the exclusive benefit of the plan. Aggregation of Purchase or Sale Our firm provides investment management services for various clients. There are occasions on which portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same security for numerous accounts served by our firm, which involve accounts with similar investment objectives. Although such concurrent authorizations potentially could be either advantageous or disadvantageous to any one or more particular accounts, they are affected only when our firm believes that to do so will be in the best interest of the effected accounts. When such concurrent authorizations occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts ADV Part 2A – Firm Brochure Page 16 Smart Money Group, LLC  involved. In any given situation, our firm attempts to allocate trade executions in the most equitable manner possible, taking into consideration client objectives, current asset allocation, and availability of funds using price averaging, proration, and consistently non-arbitrary methods of allocation. Item 13: Review of Accounts or Financial Plans Our management personnel or financial advisors review accounts on at least an annual basis for our Portfolio Management and Third-Party Money Management clients. The nature of these reviews is to learn whether client accounts are in line with their investment objectives and investment policies, if applicable. Our firm does not provide written reports to clients. Verbal reports to clients take place on at least an annual basis when our Portfolio Management and Third-Party Money Management clients are contacted. Our firm may review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. Once financial plans have been delivered, clients do not receive reviews of their plans unless they have engaged our firm for on-going services or have scheduled a follow up consultation. Follow up consultations may require the execution of an additional agreement for services rendered. Item 14: Client Referrals & Other Compensation Charles Schwab & Co., Inc. Charles Schwab & Co., Inc. Advisor Services provides us with access to Charles Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. Advisor Services retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co., Inc. Advisor Services includes brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For our client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co., Inc. Advisor Services accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to us other products and services that benefit us but may not benefit its clients’ accounts. These benefits may include national, regional or our specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services. Other potential benefits may include occasional business entertainment of personnel by Charles Schwab & Co., Inc. Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist us in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and ADV Part 2A – Firm Brochure Page 17 Smart Money Group, LLC  account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of our fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of our accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to other services intended to help us manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, and human capital consultants, insurance and marketing. In addition, Charles Schwab & Co., Inc. Advisor Services may make available, arrange, and/or pay vendors for these types of services rendered to us by independent third parties. Charles Schwab & Co., Inc. Advisor Services 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. We are independently owned and operated and not affiliated with Charles Schwab & Co., Inc. Advisor Services. Referral Fees Our firm may pay referral fees (non-commission based) to independent solicitors (non-registered representatives) for the referral of clients to our firm in accordance with state and federal rules. Such referral fee represents a share of our investment advisory fee charged to our clients. This arrangement will not result in higher costs to the referred client. All clients referred by Solicitors to our firm will be given full written disclosure describing the terms and fee arrangements between our firm and Solicitor(s). In cases where state law requires licensure of solicitors, our firm ensures that no solicitation fees are paid unless the solicitor is registered as an investment adviser representative. Item 15: Custody We do not have physical custody, as it applies to investment advisors. Custody has been defined by regulators as having access or control over client funds and/or securities. For all accounts, our firm has the authority to have fees deducted directly from client accounts. Our firm has established procedures to ensure all client funds and securities are held at a qualified custodian in a separate account for each client under that client’s name. Clients or an independent representative of the client will direct, in writing, the establishment of all accounts and therefore are aware of the qualified custodian’s name, address and the manner in which the funds or securities are maintained. Finally, account statements are delivered directly from the qualified custodian to each client, or the client’s independent representative, at least quarterly. You should carefully review those statements and are urged to compare the statements against reports received from SMG. When you have questions about your account statements, you should contact SMG or the qualified custodian preparing the statement. Standing Letters of Authorization (“SLOA”) Our firm is deemed to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) and, under that SLOA, it authorizes us to designate the amount or timing of transfers with the custodian. The SEC has set forth a set of standards intended to protect client assets in such situations, which we follow. We do not have a beneficial interest on any of the accounts we are deemed to have Custody where SLOAs are on file. In addition, account statements reflecting all activity on the ADV Part 2A – Firm Brochure Page 18 Smart Money Group, LLC  account(s), are delivered directly from the qualified custodian to each client or the client’s independent representative, at least quarterly. You should carefully review those statements and are urged to compare the statements against reports received from us. When you have questions about your account statements, you should contact us, your Advisor, or the qualified custodian preparing the statement. Please refer to Item 5 for more information about the deduction of adviser fees. Item 16: Investment Discretion For discretionary accounts, prior to engaging SMG to provide investment advisory services, you will enter a written Agreement with us granting the firm the authority to supervise and direct, on an on- going basis, investments in accordance with the client’s investment objective and guidelines. In addition, you will need to execute additional documents required by the Custodian to authorize and enable SMG, in its sole discretion, without prior consultation with or ratification by you, to purchase, sell, or exchange securities in and for your accounts. We are authorized, in our discretion and without prior consultation with you to: (1) buy, sell, exchange and trade any investment company registered under the Investment Company Act of 1940 and (2) determine the amount of securities to be bought or sold and (3) place orders with the custodian. Any limitations to such discretionary authority will be communicated to our Firm in writing by you, the client. For discretionary accounts, we require that we be provided with authority to determine Any limitations on this discretionary authority shall in writing as indicated on the investment The limitations on investment and brokerage discretion held by SMG for you are: 1. which securities and the amounts of securities to be bought or sold. 2. advisory Agreement. You may change/amend these limitations as required. In some instance, we may not have discretion. We will discuss all transactions with you prior to execution or you will be required to make the trades if in an employer sponsored account. Item 17: Voting Client Securities Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, our firm will forward them to the appropriate client and ask the party who sent them to mail them directly to the client in the future. Clients may call, write, or email us to discuss questions they may have about particular proxy votes or other solicitations. Item 18: Financial Information Our firm is not required to provide financial information in this Brochure because:  We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Our firm does not take custody of client funds or securities.  Our firm does not have a financial condition or commitment that impairs our ability to meet ADV Part 2A – Firm Brochure Page 19 Smart Money Group, LLC  contractual and fiduciary obligations to clients. Our firm has never been the subject of a bankruptcy proceeding. ADV Part 2A – Firm Brochure Page 20 Smart Money Group, LLC