Overview

Headquarters
Wayzata, MN
Average Client Assets
$5.8 million
SEC CRD Number
160282

Fee Structure

Primary Fee Schedule (SOMERSET GROUP, LLC ADV PART 2A BROCHURE)

MinMaxMarginal Fee Rate
$0 $1,000,000 1.50%
$1,000,001 $5,000,000 1.00%
$5,000,001 and above 0.75%

Minimum Annual Fee: $150

Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $15,000 1.50%
$5 million $55,000 1.10%
$10 million $92,500 0.92%
$50 million $392,500 0.78%
$100 million $767,500 0.77%

Clients

HNW Share of Firm Assets
94.84%
Total Client Accounts
161
Discretionary Accounts
161

Services Offered

Services: Financial Planning, Portfolio Management for Individuals

Regulatory Filings

Primary Brochure: SOMERSET GROUP, LLC ADV PART 2A BROCHURE (2026-03-19)

View Document Text
15600 Wayzata Blvd, Suite 304 Wayzata, MN 55391 952-681-7254 www.Somerset-Group.com Firm Brochure Form ADV Part 2A March 11, 2026 Item 1: Cover Page This Brochure provides information about the qualifications and business practices of Somerset Group LLC [“SG”]. If you have any questions about the contents of this Brochure, please contact us at 952-681-7254 and/or info@somerset-group.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Somerset Group LLC is a registered investment adviser. The registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. Additional information about Somerset Group LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. ADV Part 2A - Brochure i Somerset Group, LLC Item 2: Material Changes Business ownership change: Majority owner, John Murphy, Jr., passed away in January 2024. His ownership shares return to the ownership of Somerset Group, LLC. Somerset continues to be employee owned and operated by Arlene Kielley (majority) and Julie Toelle (minority). The United State Securities and Exchange Commission requires Somerset Group, LLC to disclose any material changes that are made to this Brochure and promptly provide clients with a summary of such changes. Pursuant to SEC Rules, we will ensure that you receive, without charge, a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. We may further provide other ongoing disclosure information about material changes as necessary. There have been no previous material updates to this Brochure since March 28, 2016. The last annual update of the Brochure was on March 11, 2026. Currently, our Brochure may be requested by contacting Julie Toelle, Head of Operations, at 941-964-2434 or julie@somerset-group.com. Additional information about Somerset Group LLC is also available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with Somerset Group LLC (“SG”) who are registered, or are required to be registered, as investment adviser representatives of Somerset Group LLC. ADV Part 2A - Brochure ii Somerset Group, LLC Item 3: Table of Contents Material Changes ............................................................................................................................ ii Table of Contents ........................................................................................................................... iii Advisory Business .......................................................................................................................... 1 Fees and Compensation .................................................................................................................. 1 Performance-Based Fees and Side-By-Side Management ............................................................. 2 Types of Clients .............................................................................................................................. 2 Fiduciary Status .............................................................................................................................. 2 Methods of Analysis, Investment Strategies and Risk of Loss ....................................................... 2 Disciplinary Information ................................................................................................................. 3 Other Financial Industry Activities and Affiliations ...................................................................... 3 Code of Ethics ................................................................................................................................ 4 Brokerage Practices ........................................................................................................................ 5 Review of Accounts ........................................................................................................................ 8 Client Referrals and Other Compensation ...................................................................................... 9 Custody ........................................................................................................................................... 9 Investment Discretion ..................................................................................................................... 9 Voting Client Securities .................................................................................................................. 9 Financial Information...................................................................................................................... 9 Requirements for State Registered Advisers ................................................................................ 10 Fiduciary Status ............................................................................................................................ 10 Our Client Privacy Pledge ............................................................................................................ 10 ADV Part 2A - Brochure iii Somerset Group, LLC Item 4: Advisory Business Established in December 2011, Somerset Group (SG) is an independent wealth management firm offering financial advisory, portfolio management and financial planning services to individual clients, families, and select institutions on a discretionary and non-discretionary basis. SG provides investment management services via separately managed accounts and through discrete investment strategies. Separately managed account portfolios are customized to meet the individual needs and objectives of the client. Separately managed accounts may contain a single strategy or a combination of investment strategies in addition to individual securities selected by the client's relationship manager. Clients may impose restrictions on investing in certain securities or types of securities in their accounts. Somerset Group is 100% owned by employees of the firm. The current members are Arlene J. Kielley, President & Chief Executive Officer; Julie R. Toelle, Treasurer; and Cynthia Hansen, Executive Vice President. Only Arlene Kielley owns 25% or more of Somerset Group. As of December 31, 2025, total assets under management were $145,625,818 (all discretionary). Item 5: Fees and Compensation SG charges clients based on a percentage of Assets Under Management (“AUM”). Less than $1 Million AUM: 1.50% annually $1 Million - $5 Million AUM: 1.00% annually More than $5 Million AUM: 0.75% annually Minimum annual fee: $150 General Information on Fees Typically, under the terms of SG’s standard form investment advisory agreements, the compensation of SG’s service is payable monthly in arrears. Unless the client directs SG otherwise in writing, the client authorizes the custodian of the account to pay the fees due directly from the custody account. The standard form agreements do not have fixed termination or renewal dates but provide for the termination of SG’s services to the client upon prior written notice by either the client or SG to the other. In addition to the schedules of fees set forth above that apply to new clients; there are in effect fee schedules with some clients that differ from those above. From time to time, special requirements of clients may result in advisory contracts with terms or fee arrangements differing from those set forth in SG’s standard forms. There are circumstances under which fees may be negotiated. The minimum fees noted above may be waived or reduced when, for example, a new account is expected to grow rapidly in size, a relationship exists with a present client of SG, or for other reasons, at the discretion of SG. While the fees and payment terms indicated are standard, fees and payment terms may be negotiated. A discount from the standard fee may be offered to accounts of persons associated with SG or ADV Part 2A – Brochure 1 Somerset Group, LLC members of their family. SG clients will pay fees to third parties, such as custodial fees or mutual fund fees, and will incur brokerage charges in connection with the execution of portfolio transactions. See Brokerage Practices for more information. Item 6: Performance-Based Fees and Side-By-Side Management SG does not charge any performance-based fees (fees based on a share of capital gains or on capital appreciation of the assets of a client). Item 7: Types of Clients & Account Requirements SG has the following types of clients: Individuals • • Trusts, estates, or charitable organizations • Corporations SG has no account minimums or requirements for maintaining accounts with us. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss SG utilizes a combination of security specific research and technically driven analysis to form portfolios which are responsive to client objectives. Generally, publicly traded common stocks, fixed income securities and exchange traded funds are used for these purposes. At the beginning of any advisory relationship, SG will work with the client to create detailed and specific investment objectives. This includes objectives such as preservation of capital, total return, income, and long-term growth. SG cannot guarantee that we will achieve our stated investment objective or achieve positive or competitive returns. Past performance is no guarantee of future performance. Investing in securities involves principal balances that will fluctuate, and you could lose all or a portion of your investment assets. Risk of Loss There are several risks inherent to investing in financial markets. Two general types of risk are systemic and non-systemic. Systemic risk, also known as market risk, relates to factors that affect the overall economy or securities markets as a whole. Systemic risk affects all companies. Common systemic risks include: • Interest Rate Risk – risk that the value of a security will go down because of changes in interest rates. ADV Part 2A – Brochure 2 Somerset Group, LLC • Inflation Risk – risk that cost of living (prices of goods and services) will increase and therefore reduce purchasing power. • Liquidity Risk – risk you may not be able to buy or sell investments quickly for a price that is close to the true underlying value of the asset. • Geopolitical Risk – risk that instability or unrest in one or more regions of the world will affect investment markets (i.e. terrorist attacks, war, pandemics) Non-systemic Risk affects far fewer companies or investments and is associated with investing in a particular product, company, or industry sector. Common non-systemic risks include: • Management Risk – also known as company risk, refers to the impact that bad management decisions can have on a company’s performance and subsequent value of an investment in the company. • Credit Risk – also known as default risk, is the possibility that a bond issuer won’t pay interest as scheduled or repay principal at maturity. Investment Strategies Somerset Group manages the following investment strategies: • Core Portfolio- A blended total return approach supported by technical analysis. Utilizes our proven equity discipline coupled with tactical bond, cash, and can include international, master limited partnerships and commodity allocations. • ETF Portfolio- A tactical asset allocation and sector rotation portfolio that utilizes relative strength to identify areas of the market that are the strongest. Implemented using exchange traded funds. • Dividend Growth Portfolio- An equity-based strategy that seeks fundamentally strong companies with anticipated dividend growth in order to provide a growing income stream. • Fixed Income Strategy- Seeks to generate stable income in a maturity structured fixed income portfolio. Customized portfolio construction includes treasuries, corporate, mortgage securities, and municipal bonds depending on tax sensitivity. Item 9: Disciplinary Information SG is required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of our business. SG has no events applicable to this item. Item 10: Other Financial Industry Activities and Affiliations SG offers financial planning advice. SG gathers required information through personal interviews and questionnaires. Information gathered includes a client’s current financial status, future goals, and attitudes toward risk. Related documents supplied by the client are carefully reviewed. Services provided depend on the individual client, but generally include (yet are not limited to) the following: A basic financial assessment including a review and analysis of the clients goals and priorities, construction of a balance sheet, investment and asset allocation analysis, basic insurance needs analysis, general estate planning review, retirement and/or educational funding projections. ADV Part 2A – Brochure 3 Somerset Group, LLC Implementation of financial planning recommendations is entirely at the client’s discretion. The client is not obligated to use SG to implement the investment advice detailed in the recommendations. Item 11: Code of Ethics SG has adopted a Code of Ethics (“Code”) for all supervised persons of the firm describing its high standard of business conduct, and fiduciary duty to its clients. The Code includes provisions relating to the confidentiality of client information, a prohibition on insider trading, guidance on certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at SG must acknowledge the terms of the Code. Supervised persons of SG may from time to time maintain a position, either directly or indirectly, in the securities which are recommended to investment advisory clients by SG. When supervised persons invest in the Firm’s models alongside client investments, all accounts participate in transactions equally and at the same time. SG requires prompt reporting of all personal transactions under the Code. SG further requires that all brokerage account relationships be disclosed, that SG receive duplicate confirmations of transactions and/or custodial account statements, and certifications of compliance with the Code from all supervised persons. In addition to reporting and record keeping requirements, the Code imposes various substantive and procedural restrictions on covered transactions, including the following: 1. All transactions by supervised persons in securities covered by the Code should be pre- approved unless an exemption or exception applies. 2. Participation in the initial underwriting by employees is prohibited. 3. Supervised persons, including immediate family members, who maintain securities positions or accounts separate from the Firm’s models shall not purchase/sell securities of an issuer for their personal account(s) unless the transaction falls within the De Minimis Exemption. The Firm has established a De Minimis Exception that is available to employees or members of their immediate family when engaging in a personal securities transaction. In order to qualify for the De Minimis Exception, the transaction cannot exceed 1% of the average daily volume of the security for the five trading days prior to a purchase/sell. A copy of the Code will be provided upon request to existing and potential clients by contacting Julie Toelle at 941-964-2434 or julie@somerset-group.com. Supervised persons may personally own securities of broker-dealers and/or custodians with which SG does business. SG may invest in securities of which related persons of its employees are insiders. SG’s trading and research will not be based on inside information. ADV Part 2A – Brochure 4 Somerset Group, LLC Employees may have an interest or position in a certain security or group of securities which may also be recommended to a client. Such securities may include publicly traded and privately placed stocks, bonds, and options contracts. SG seeks to avoid or minimize the conflicts that may result from the foregoing activities of principal transactions and personal trading through its Code. Item 12: Brokerage Practices SG may use a portion of trading commissions to pay for certain research services, information, or data (“soft dollar” relationship). These products and services benefit all of SG’s clients and are never used for products or services that benefit only SG. Soft dollar benefits for research are not limited to those clients who may have generated a particular benefit although certain soft dollar allocations are connected to particular clients or groups of clients. Investment Discretion Clients may choose to retain SG as investment adviser with or without granting investment discretion. When a client chooses to grant investment discretion to SG, SG will have authority to supervise and direct the investments of and for the client's account without prior consultation with the client. Pursuant to this discretionary authority, SG normally will determine which securities are bought or sold for the account, the total amount of such purchases and sales, the brokers or dealers through which transactions will be affected, and the commission rates, if any, paid to effect the transactions. SG’s authority may be made subject to conditions imposed in writing by the client, e.g., where the client restricts or prohibits purchases of certain types of securities, or directs that transactions be affected through specific brokers or dealers. When a client does not choose to grant SG investment discretion, SG makes investment recommendations to the client as to which securities are to be purchased or sold, and the amounts to be purchased or sold. Upon approving the recommended transactions, the client may request that SG direct the execution of purchase or sale orders to implement the recommended transactions for the client's account. SG then may be given authority to determine the brokers or dealers through which the transactions will be executed, and the commission rates, if any, paid to effect the transactions. As described above with respect to discretionary accounts, the client may direct that transactions be effected with specific brokers or dealers. SG utilizes third party pricing services in valuing securities. SG may buy, sell, and perform research on or through companies for whom a client may be the company, an employee, officer or director. ADV Part 2A – Brochure 5 Somerset Group, LLC Selection of Brokers and Dealers Subject only to a client's direction to use a particular broker or dealer for the execution of transactions for that client’s account, SG’s overriding objective in selecting brokers and dealers to effect client transactions is to seek the best combination of net price and execution. The best net price, giving effect to brokerage commission, if any, is an important factor in this decision; however, a number of other judgmental factors also may enter into the decision. These factors include SG’s knowledge of negotiated commission rates currently available and other current transaction costs; the nature of the security being purchased or sold; the size of the transaction; the particular security; confidentiality; the execution, clearance and settlement capabilities of the broker or dealer selected and others considered; SG’s knowledge of the financial condition of the broker or dealer selected and such other brokers and dealers; and, SG’s knowledge of actual or apparent operational problems of any broker or dealer. Recognizing the value of these factors, SG may cause a client to pay brokerage commission in excess of that which another broker might have charged for effecting the SG transaction. It is common that best execution is obtained at the client custodian, given trade away fees to trade elsewhere. On occasions when SG deems the purchase and sale of a security to be in the best interests of more than one of its clients, SG may aggregate the securities to be sold or purchased for a client with those to be sold or purchased for such other clients in seeking to obtain best qualitative execution. In such event allocation of the securities so purchased or sold as well as the expenses incurred in the transaction, will be made by SG in the manner considered to be most equitable and consistent with its fiduciary obligations to participating clients. This generally means allocation on a pro rata basis, utilizing a rotation. SG does not participate in Initial Public Offerings (IPO) involving discretionary client accounts. Investment Research Products and Services Furnished by Brokers and Dealers When more than one broker or dealer is believed to be capable of providing a combination of best net price and execution with respect to a particular portfolio transaction, SG often selects a broker or dealer which furnishes to SG investment research products or services, such as: economic, industry or company research reports or investment recommendations; research data compilations; compilations of securities prices, earnings, dividends and similar data; computerized databases; quotation equipment and services; research or analytical computer software and services; or services of economic and other consultants. Such selections are not pursuant to any agreement or understanding with any of the brokers or dealers. However, SG does in some instances request a broker to provide a specific research product or service which may be proprietary to the broker or produced by a third party and made available by the broker and, in such instances, the broker, in agreeing to provide the research product or service frequently, will indicate to SG a specific or minimum amount of commissions which it expects to receive by reason of its provision of the product or service. SG does not have an agreement with any broker to direct such specific or minimum amounts of commissions; however, SG does maintain an informal internal procedure to identify those brokers which provide it with research products or services and SG endeavors to direct sufficient commissions on client transactions to ensure the continued receipt of research products and services SG feels are useful. ADV Part 2A – Brochure 6 Somerset Group, LLC In certain instances, SG may receive from brokers products or services which are used by SG both for investment research and for administrative, marketing, or other non-research purposes. In such instances, SG makes a good faith effort to determine the relative proportion of its use of such product or service which is for investment research, and that portion of the cost of obtaining such product or service may be defrayed through brokerage commissions generated by client transactions. While it is permissible to do so under the rules of the Securities and Exchange Commission, SG does not believe it pays brokerage commissions higher than those obtainable from other brokers in return for research products or services provided by brokers. Research products or services provided by brokers may be used by SG in servicing any or all of the clients of SG, and such research products or services may not necessarily be used by SG in connection with the client accounts which paid commissions to the brokers providing such products or services. Client-Directed Brokerage Arrangements If a customer-directed broker is used, depending on the circumstances, the following disclosures are required. • No attempt is being made to negotiate commissions on the client’s behalf. • Best execution is not being obtained and there is an inability to obtain volume discounts. • Lower commission rates are available elsewhere. Clients may direct SG in writing (subject to certain conditions which may from time to time be imposed by SG) to effect portfolio transactions for their accounts through particular brokers or dealers. Such a direction may be conditioned upon the broker or dealer being competitive as to net price and execution of each transaction or may be subject to varying degrees of “restriction,” i.e., an instruction to use the particular broker or dealer whether or not competitive as to net price and execution, or at specified commission rates which are less favorable than otherwise might be obtainable by SG. In the case of a “restricted” designation, SG generally will execute transactions in listed and over-the-counter equity securities through the designated broker, but in the case of transactions in fixed-income securities (a) SG sometimes deviates from the client's designation in situations in which, in SG’s judgement, a significantly more advantageous net price is available from another dealer, or (b) SG may authorize the designated broker-dealer to effect the transaction as agent in order to obtain a better price from another dealer, but will allow the designated “agent” broker-dealer a scheduled mark-up or mark-down on the transaction. Clients sometimes wish to restrict brokerage to a particular broker or dealer in recognition of custodial or other services (including, in some cases, referral of the client to SG for investment advisory services) provided to the client by the broker or dealer. A client which chooses to designate use of a particular broker or dealer completely or on a “restricted” basis, including a client which designates a broker or dealer as custodian of the client’s assets, should consider whether such a designation may result in certain costs or disadvantages described below regarding priority of execution, allocation of new issue purchases, and aggregation of orders. In determining whether to instruct SG to use a particular broker or dealer on a “restricted” basis, the ADV Part 2A – Brochure 7 Somerset Group, LLC client may wish to compare the possible costs or disadvantages of such an arrangement with the value of the custodial or other services provided. Clients who restrict brokerage for their accounts may be disadvantaged in obtaining allocations of securities which SG purchases or recommends for purchase in other client’s accounts. It is SG’s policy that such “restricted” accounts not participate in allocations of securities obtained through brokers and dealers other than that designated by the client. In order to execute client orders most efficiently, SG’s traders may assign a lower priority to execution of orders for client accounts which have restricted brokerage. Accordingly, the execution of orders for accounts which restrict brokerage may be less timely than the execution of orders for other client accounts. This priority of execution may or may not result in any consistent price disadvantage, depending upon the market activity in the security to be purchased or sold. Recommendation of Brokers and Dealers to Clients Where a client is reluctant to incur the fee cost of using the services of a bank or trust company as custodian of the client's assets, SG sometimes suggests the client use a broker for this purpose and, if the client does not already have a satisfactory brokerage arrangement, SG will suggest the names of one or more brokers with which it is familiar and which provide such services. Factors considered by SG in selecting brokers which it recommends to clients for custodial services include: the execution, clearance and settlement capabilities of the broker; SG’s knowledge of the financial stability of the broker; whether the broker offers insurance coverage to customers in excess of the Securities Investor Protection Corporation insurance amounts; SG’s knowledge of actual or apparent operational problems of the broker; and the willingness of the broker to negotiate discounted commission rates for the execution of transactions in the custodial account. The value of research products and services, or other products, if any, provided to SG or a related party by the broker is generally not a factor. Brokerage Practices, General SG receives a benefit when it uses client commissions to receive research, because SG does not have to pay for such services on its own. SG may have an incentive to select or recommend a broker dealer based on its interest in receiving research from a broker dealer or third party, rather than the client’s interest in seeking favorable execution. However, as described above, SG believes it can achieve best execution for its clients even where it is receiving research services from broker dealers. Item 13: Review of Accounts Client transactions are reviewed on a daily basis. Accounts are overseen by a dedicated portfolio manager and reviewed regularly and upon request. Meetings will be scheduled with any client, upon request, to conduct an investment review with the goal of ensuring that the client objectives are current and being integrated into portfolio construction and implementation. ADV Part 2A – Brochure 8 Somerset Group, LLC The firm prepares and delivers valuations of all clients’ accounts at least quarterly, showing cash and all currently held investments. Reports include total return information as well as holding level detail such as unit cost basis and market value. Item 14: Client Referrals and Other Compensation SG does not pay cash referral fees to third party solicitors for business referred to SG. SG does not charge fees for financial planning services. Item 15: Custody The firm has a reasonable belief that the Custodian is sending statements in accordance with SEC Rule 206. Clients should receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains the client’s investment assets. SG urges you to carefully review such statements and compare such official custodial records to the account statements that we may provide to you. Reports or statements produced by the firm are provided to clients. Statements from SG may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. SG maintains custody of some client assets to the extent that the client has a Standing Letter of Authorization (SLOA) on file with their custodian (i.e., Charles Schwab or USBank) allowing SG to move assets between the client’s own accounts or make pre-authorized payments to third parties. Item 16: Investment Discretion SG usually receives discretionary authority from the client at the outset of an advisory relationship to select the identity and number of securities to be bought or sold. In all cases, such discretion is to be exercised in a manner consistent with the stated investment objectives, limitations and restrictions of the clients for which it advises. (i.e., if selecting a mutual fund, SG will always select the most beneficial share class to meet client objectives.) Item 17: Voting Client Securities As a matter of firm policy and practice, SG does not have any authority to and does not vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Clients will receive such information directly from the custodian or transfer agent. SG may provide advice to clients regarding the clients’ voting of proxies. Unless otherwise agreed, SG will not advise or act on behalf of a client in any legal proceedings including bankruptcies or class actions involving assets held in portfolios advised by SG. Item 18: Financial Information ADV Part 2A – Brochure 9 Somerset Group, LLC Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about SG’s financial condition. SG has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. Item 19: Requirements for State Registered Advisers Minnesota-based investment adviser representatives (IARs) that are affiliated with SEC- registered investment advisers are required to register with the state. SG has three (3) employees registered with the state of Minnesota as Investment Adviser Representatives. Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts of interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations. • Never put our financial interests ahead of yours when making recommendations. • Avoid misleading statements about conflicts of interest, fees, and investments. • Give you basic information about conflicts of interest. • Charge no more than is reasonable for our services. • Follow policies and procedures designed to ensure that we give advice that is in your best interest. Our Client Privacy Pledge You trust us with your financial and other personal information. We promise to protect your privacy according to the policy below. We obtain various personal information through account documents and custodial statements. This information is necessary to provide you with the best service. We will not provide current or former client names and account information to any outside firm, person, or organization. Occasionally, it is necessary to provide client information to other service providers to receive accounting, legal and compliance services. Additionally, we provide client information to third party service providers when it is essential for servicing your account. We will only provide client information to other service providers if you have a previously established relationship, have authorized us to do so or in situations where we have a legal or regulatory obligation. We do not provide other businesses with any information specific to accounts maintained at Somerset Group LLC for marketing purposes. Any documentation containing sensitive information is disposed of in a manner that renders the information unreadable. Electronic data is removed from all devices so that information cannot be restored or reconstructed before the device is disposed of or recycled. ADV Part 2A – Brochure 10 Somerset Group, LLC Employees who violate our privacy policy are subject to disciplinary action. In addition, our internal systems are secured through encryption technology, passwords, and physical safeguards. We strive to maintain the confidentiality of your account and all other personal information. ADV Part 2A – Brochure 11 Somerset Group, LLC SOMERSET GROUP LLC (SG) 15600 Wayzata Blvd, Suite 304 Wayzata, MN 55391 (952) 681-7254 www.somerset-group.com Brochure Supplement Arlene J. Kielley Cyndy Hansen This Brochure Supplement provides information on our personnel listed above and supplements the Somerset Group LLC Brochure. You should have received a copy of that Brochure. Additionally, a Summary of Professional Designations is included with this Part 2B Brochure Supplement. This summary is provided to assist you in understanding the professional designations currently held by investment professionals. If you have not received our firm’s Brochure, have any questions about professional designations or about any content of this supplement, please contact us at 952-681-7254 and/or info@somerset-group.com. ADV Part 2B – Brochure Supplement 1 Somerset Group, LLC Arlene J. Kielley President, Chief Executive Officer (952) 681-7663 Educational Background and Business Experience Year of Birth: 1953 Designations: none Education: St. Catherine University, St. Paul, MN B.S. in Business Administration Business Background (preceding 5 years): 04/04 to 2/29/12 Somerset Asset Management LLC Portfolio Manager 3/1/12-Present Somerset Group LLC President Disciplinary Information Arlene Kielley has no reportable disciplinary history. Other Business Activities Arlene Kielley is not involved with any other material investment-related business. Additional Compensation No additional compensation is received by Arlene Kielley. Supervision Arlene Kielley is the Chief Compliance Officer of Somerset Group. She is responsible for oversight and enforcement of the firm’s compliance programs. In doing so, Arlene supervises the activities and services provided by the firm and its representatives. The Chief Compliance Officer is supervised by the Treasurer, Julie Toelle. Requirements for State-Registered Advisers No information is applicable. Somerset Group is registered with the Securities and Exchange Commission (SEC) under the Investment Advisers Act of 1940. ADV Part 2B – Brochure Supplement 2 Somerset Group, LLC Cynthia Hansen, CFP Financial Advisor (952) 681-7254 Educational Background and Business Experience Year of Birth: 1981 Designations: CERTIFIED FINANCIAL PLANNER™ Education: Lewis & Clark College, Portland, OR B.S. in Mathematics Business Background (preceding 5 years): 12/4/2017-Present Somerset Group, LLC Disciplinary Information Cynthia Hansen has no reportable disciplinary history. Other Business Activities Cynthia Hansen is not involved with any other material investment-related business. Additional Compensation No additional compensation is received by Cynthia Hansen. Supervision All advisers are supervised by the Chief Compliance Officer of the firm, Arlene Kielley. Requirements for State-Registered Advisers No information is applicable. Somerset Group is registered with the Securities and Exchange Commission (SEC) under the Investment Advisers Act of 1940. ADV Part 2B – Brochure Supplement 3 Somerset Group, LLC

Frequently Asked Questions