THE ADVOCATE GROUP, LLC

The Advocate Group, LLC 601 Carlson Pkwy., Suite 1100 Minnetonka, MN 55305 952-693-2630 www.theadvocategroup.com Form ADV Part 2A – Firm Brochure February 2026 ____________________________________________________________________________________ This brochure provides information about the qualifications and business practices of The Advocate Group, LLC. If you have any questions about the contents of this brochure, please contact us at (952) 693-2630. 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. Registration as an investment adviser does not imply a certain level of skill or training. Additional information about The Advocate Group, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov.  Item 2 – Material Changes Since The Advocate Group’s last annual Brochure update, February 2025, there have been no material changes to our business or service offerings. Pursuant to SEC Rules, The Advocate Group will provide ongoing disclosure information about material changes or new information as necessary. We will provide a current brochure at any time without charge to our clients or prospective clients. A brochure may be requested by contacting Michael Corrigan at mcorrigan@theadvocategroup.com or (952) 693-2630. Additional information about The Advocate Group, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons affiliated with The Advocate Group who are required to be registered as investment adviser representatives of the Firm. 2 The Advocate Group, LLC Form ADV Part 2 - Firm Brochures  Item 3 – Table of Contents Item 2 – Material Changes ....................................................................................................................... 2 Item 3 – Table of Contents ....................................................................................................................... 3 Item 4 – Advisory Business ...................................................................................................................... 4 Brief History ......................................................................................................................................... 4 General Description of Advisory Services............................................................................................. 4 Financial Planning ............................................................................................................................... 4 Investment Management ..................................................................................................................... 4 Client Assets Managed by The Advocate Group .................................................................................. 4 Item 5 – Fees and Compensation ............................................................................................................ 5 Financial Planning ............................................................................................................................... 5 Investment Management ..................................................................................................................... 6 Item 6 – Performance-Based Fees and Side-By-Side Management ......................................................... 7 Item 7 – Types of Clients ......................................................................................................................... 7 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 8 Item 9 – Disciplinary Information ............................................................................................................ 10 Item 10 – Other Financial Industry Activities and Affiliations ................................................................... 10 Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading .............................. 10 Item 12 – Brokerage Practices ............................................................................................................... 11 Custodians and Brokers ..................................................................................................................... 11 Custodian/Broker Selection................................................................................................................ 11 Brokerage and Custody Costs ........................................................................................................... 11 Aggregate Trades .............................................................................................................................. 12 Cross Trades ..................................................................................................................................... 12 Trade Error Policy .............................................................................................................................. 13 Item 13 – Review of Accounts ................................................................................................................ 13 Account Reviews and Reviewers ....................................................................................................... 13 Statements and Reports .................................................................................................................... 13 Item 14 – Client Referrals and Other Compensation .............................................................................. 14 Item 15 – Custody ................................................................................................................................. 14 Item 16 – Investment Discretion ............................................................................................................. 14 Item 17 – Voting Client Securities .......................................................................................................... 15 Item 18 – Financial Information .............................................................................................................. 15 3 The Advocate Group, LLC Form ADV Part 2 - Firm Brochures  Item 4 – Advisory Business Brief History The Advocate Group, LLC (“formerly TAG Financial Services, Inc.”) has been providing investment advisory services since 2002. The firm has focused its service offerings primarily to senior officers of large companies and individuals. The Advocate Group, LLC (“The Advocate Group”) is a Minnesota limited liability company and has been registered with the Securities and Exchange Commission since 2011. Controlling members include: • Michael L. Corrigan, Chief Executive Officer, Chief Compliance Officer • Rebecca A. Wachter, Chief Operating Officer, Treasurer • Sean P. O’Hagan, Secretary • Seth Heimermann, Chief Investment Officer General Description of Advisory Services The Advocate Group’s services are provided based on the individual needs of each client. The following are brief descriptions of The Advocate Group’s primary services: Financial Planning - The Advocate Group provides advisory services in the form of financial planning services. Financial planning services focus on a client’s overall financial situation. Financial planning can be described as helping individuals determine and set their long-term financial goals, through topics including but not limited to, investment management, tax planning, retirement/cash flow modeling, transition planning, estate design, risk management and philanthropic planning. The role of a financial planner is to find ways to help the client understand his/her overall financial situation and help the client set financial objectives. Investment Management - The Advocate Group provides advisory services in the form of investment management services. Investment management services involve providing clients with on-going supervision of client investment accounts. This means that The Advocate Group will monitor a client’s accounts and make trades in client accounts when necessary. The Advocate Group does not manage Wrap Fee accounts. Client Assets Managed by The Advocate Group As of December 31, 2025, our assets under management are $809,930,205 with $808,204,119 managed on a discretionary basis and $1,726,086 managed on a non-discretionary basis. 4 The Advocate Group, LLC Form ADV Part 2 - Firm Brochures  Item 5 – Fees and Compensation The Advocate Group offers investment management advisory and financial planning services. The details of The Advocate Group’s compensation are documented in the fee schedule and the investment management agreement signed by each client. We charge fees based on a percentage of assets under management when we manage investment accounts. We may also charge fees for financial planning services, and such fees are agreed to by the client in advance and a written financial planning agreement is signed by the client. Financial Planning For clients selecting this service, The Advocate Group provides financial planning services using multiple tools and resources for analysis and to help detail its recommendations. Clients will have online access to their financial plans which often include daily updates to their account values. Clients are also able to consult with The Advocate Group for ongoing advice. Financial planning topics can include both securities and non-securities related matters. To begin the financial planning experience, The Advocate Group will meet with the client to determine the scope of services and financial planning topics to be covered. Once defined and agreed upon, the client and The Advocate Group will enter into a Financial Planning Agreement. Financial planning services are generally provided for a one-year period commencing upon the execution of the Financial Planning Agreement. By entering into the agreement, the client will have continuous access to their online plan. The Advocate Group will consult with the client to make adjustments to financial plans due to significant changes to circumstances in the client’s life or related to taxation, markets and the economy. The exact fee will be quoted to the client in advance of beginning any services. Annual fees are negotiable and will be determined by The Advocate Group based on factors such as the client’s financial situation, as well as breadth and complexity of services needed. Typical initial annual financial planning fees range from $2,500 to $20,000, depending on the complexity of the plan. The fee is collected via AdvicePay, an online payment system, or via check from the client. While not required to do so, clients can choose to engage The Advocate Group for on-going financial planning services after the initial year. Clients can contact The Advocate Group throughout the year to discuss changes in their financial planning situation or ask questions concerning the plan. The Advocate Group will contact financial planning clients at least annually to ensure all information and client assumptions are accurate. Annual fees for on-going financial planning are negotiable and will be quoted to the client in advance of commencing any services. On-going fees typically range from $1,500 to $15,000. The term of each Financial Planning Agreement shall be one year and require a signature from one individual in the household. However, clients have the right to terminate financial planning services without penalty (i.e. no fees due and/or a complete refund of any fees paid in advance) within five (5) business days after executing the Financial Planning Agreement. After the initial five-day period, a client may invoke early termination by providing notice to The Advocate Group and termination shall be effective upon The Advocate Group’s receipt of termination. After the initial five (5) business days, a pro-rated refund will be made to the client, based upon the number of months remaining in the contract year. 5 The Advocate Group, LLC Form ADV Part 2 - Firm Brochures  Clients with $3,000,000 or more in The Advocate Group’s investment management advisory services receive financial planning services as part of their investment management fee. A description of these services shall be provided in the Investment Management Agreement. If clients choose to implement investment advice through The Advocate Group, clients must select one of the other advisory programs detailed in this brochure and pay the respective additional investment advisory fees to The Advocate Group for participation in the other advisory programs detailed in this brochure. Clients can also work with one of The Advocate Group’s associated persons in their separate capacity as an independent insurance agent. When doing so, The Advocate Group will earn commissions in addition to the financial planning fees charged by The Advocate Group. Investment Management The Advocate Group provides investment management services, which include providing advice regarding buying, selling, or otherwise transacting securities, cash or other investments held by a qualified custodian and based on a client’s individual needs. The Advocate Group provides customized and individualized investment recommendations to clients. Pursuant to each client’s specific investment objectives, securities held in accounts generally include no-load and load-waived mutual funds, fixed income securities and funds such as bonds, unit investment trusts (UITs), closed-end and Exchange Traded Funds (ETFs), Exchange Traded Notes (ETNs), stocks, certificates of deposit, hedge funds, structured products and/or fee-based variable annuities. Clients who wish to engage The Advocate Group for investment management services will sign an Investment Management Agreement. Through this service, The Advocate Group will be granted trading authorization on the client’s account. Trading authority allows The Advocate Group the ability to make trades in the client’s account on behalf of the client. Such authorization is provided on a discretionary or non-discretionary basis, depending on the individual needs and requests of each client. Discretionary authority allows The Advocate Group the ability to make trades in the client’s account without contacting the client prior to each trade. When non- discretionary trading authorization is granted, The Advocate Group must get the client’s approval prior to making any changes in the client’s account. The annual investment advisory fee for services shall be a percentage of the account balance. The percentage calculation shall be determined by The Advocate Group’s tiered fee schedule, which spans from 0.35% to 0.95%. The annual fee shall be divided and paid quarterly in advance through a direct debit to the account and shall be determined based upon the market value of the account as of the last day of the prior quarter. The fee for the first quarter of services shall be prorated based on the number of days services are provided and will be charged at the next quarterly billing period. Due to The Advocate Group’s tiered fee schedule, market fluctuations, and deposits and withdrawals, there may be an increase or decrease in the fee from quarter to quarter. Fees for inflows and outflows at any time other than the beginning of a quarter will be prorated based on the number of days remaining in the quarter. The account may hold cash balances as part of the planned allocation. Such cash balances shall be subject to the investment management fee calculation. Here is an example of how the tiered calculation works: $4,500,000 value across all household accounts managed by The Advocate Group First $2,000,000 x 0.95% = $19,000 Next $2,500,000 x 0.75% = $18,750 $19,000 + 18,750 = $37,750 Total Fee (0.84%) 6 The Advocate Group, LLC Form ADV Part 2 - Firm Brochures  At The Advocate Group’s discretion, The Advocate Group can reduce its standard fee or elect to charge a flat fee. Each client’s specific fee arrangement is negotiable and will be determined based on factors such as, but not limited to, the total assets under management, the number of accounts managed, the client’s financial situation, and the client’s overall relationship with The Advocate Group. The actual fee charged to each client shall be determined prior to establishing the arrangement. Fees are calculated and debited from client accounts at their custodian. Clients must provide written authorization to have advisory fees deducted directly from their accounts and to have fees paid to The Advocate Group. Brokerage fees and/or transaction ticket fees will be unique to each custodian or broker/dealer. The Advocate Group does not receive any portion of such fees from the custodian or client. In addition, clients may incur certain charges imposed by third parties other than The Advocate Group in connection with investments made through the account, including but not limited to, mutual fund sales loads, 12(b)-1 fees and surrender charges, fee-based variable annuity fees and surrender charges, IRA and qualified retirement plan fees, and other fees that may be unique to a product, transaction or custodian. Fees charged by The Advocate Group are separate and distinct from the fees and expenses charged by investment company securities that may be recommended to clients. A description of these fees and expenses are available in each investment company security’s prospectus. Either party may terminate the Investment Management Agreement at any time. If services are terminated within five (5) business days of executing the agreement, services will be terminated without penalty and a full refund of all fees paid in advance will be provided. If services are terminated after the initial five-day period, The Advocate Group shall provide the client with a pro-rated refund of fees paid in advance. The refund will be based on the number of days service was provided during the final billing period. Termination shall be effective from the time the other party receives written notification or such other time as may be mutually agreed upon, subject to the settlement of transactions in progress and the final refund of advisory fees. The Advocate Group does not charge a penalty fee upon termination. Item 6 – Performance-Based Fees and Side-By-Side Management The Advocate Group does not charge or accept performance-based fees which can be defined as fees based on a share of capital gains on or capital appreciation of the assets held within a client’s account. Item 7 – Types of Clients The Advocate Group generally provides investment advice to: Individuals • • High Net Worth Individuals • Pension, profit sharing and retirement plans • Trusts, estates, or charitable organizations • Corporations or other business entities In general, most household relationships have aggregate portfolios of $500,000 or more, however, there is no minimum portfolio requirement. 7 The Advocate Group, LLC Form ADV Part 2 - Firm Brochures  Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss The firm’s core belief is that a comprehensive financial plan should drive investment and asset allocation decisions, not exclusively a client’s personal risk tolerance. The firm’s clients may hold a personal risk tolerance that is higher or lower than the risk necessary to achieve sufficient returns for a successful investment and life outcome. Detailed discussion of this difference between required risk and tolerated risk leads to a clarifying discovery of each client’s actual desired risk. It is this desired risk, not tolerance for risk, which becomes foundational to each client’s individually designed asset allocation with The Advocate Group. Helping a client establish sufficient liquid reserves to remain steady in the face of market volatility is another important element of the firm’s investment philosophy. Most human investment behavior is oriented toward buying at the exuberant market highs and selling at the distressing market lows. Proper liquidity and reserves can create an environment which allows a client to overcome this behavioral tendency to do the exact opposite of what is necessary to be a more successful investor. The Advocate Group’s investment philosophy is also impacted by the unique circumstances of its client base. Many clients of the firm hold a concentrated wealth position in the securities of the company for which they work. Proper management of this concentrated wealth position, within the context of the entire investment portfolio and financial plan, are key elements of the firm’s overall value proposition. Successful investment management at The Advocate Group is not about the achievement of a certain performance level above a predefined benchmark. Our idea of a proper investment management experience is about achieving sufficient return at each client’s desired level of risk to achieve successful fulfillment of their individual financial objectives. Clients must understand that past performance is not indicative of future results. Therefore, current and prospective clients should never assume that future performance of any specific investment or investment strategy will be profitable. Investing in securities involves risk of loss. Further, depending on the different types of investments selected, there are varying degrees of risk. Clients and prospective clients should be prepared to bear investment loss including loss of the original principal invested. Because of the inherent risk of loss associated with investing, our firm is 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. Investing in securities involves the risk of loss and clients should be prepared to bear potential losses. There are certain additional risks associated when investing in securities through our investment management program that are outlined as follows: Market Risk. Either the stock market as a whole, or the value of an individual company, goes down resulting in a decrease in the value of client investments. This is also referred to as systemic risk. Economic Risk: Changes in economic conditions, for example, interest rates, inflation rates, political and diplomatic events and trends, tax laws and innumerable other factors, can substantially and adversely affect investments. Equity (Stock) Risk. Common stocks are susceptible to general stock market fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers 8 The Advocate Group, LLC Form ADV Part 2 - Firm Brochures  change. If you held common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater risk than if you held preferred stocks and debt obligations of the issuer. Company Risk. When investing in stock positions, there is always a certain level of company or industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk and can be reduced through appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. Concentrated Portfolio Risk: To the extent a portfolio has a large portion in a single security or several securities it bears more risk because it is not diversified. Changes in the value of significantly over-weighted security positions may have a much more substantial directional effect, either negative or positive, on the portfolio’s performance. Fixed Income Risk. When investing in bonds, there is the risk that issuer will default on the bond and be unable to make payments. Further, individuals who depend on set amounts of periodically paid income face the risk that inflation will erode their spending power. Fixed-income investors receive set, regular payments that face the same inflation risk. Exchange Traded Fund (“ETF”) and Mutual Fund Risk. When our firm invests in an ETF or mutual fund, it 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 will also incur brokerage costs when purchasing ETFs. Exchange Traded Note (“ETN”) Risk. The purpose of ETNs is to create a type of security that combines both the aspects of bonds and ETFs. Similar to ETFs, ETNs are traded on a major exchange, such as the NYSE during normal trading hours. However, investors can also hold the debt security until maturity. At that time the issuer will give the investor a cash amount that would be equal to principal amount (subject to the day's index factor). One factor that affects the ETN's value is the credit rating of the issuer. The value of the ETN may drop despite no change in the underlying index, instead due to a downgrade in the issuer's credit rating. Management Risk. Your investment with our firm 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 will decrease. Artificial Intelligence and Machine Learning Risk. Certain service providers utilized by the Firm to service client accounts have artificial intelligence components. The use of artificial intelligence and machine learning includes increased risk of data inaccuracies and security vulnerabilities. Due to the rapid advancement of machine learning technologies, future risks related to artificial intelligence are unpredictable. As a measure to mitigate these risks to our clients, the Firm performs periodic due diligence of our service providers for assurance that the service providers have appropriate controls in place to protect our clients’ information and to limit data inaccuracies when artificial intelligence is used by the service provider. 9 The Advocate Group, LLC Form ADV Part 2 - Firm Brochures  Item 9 – Disciplinary Information This item is not applicable to The Advocate Group’s brochure because there are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of The Advocate Group’s business or the integrity of The Advocate Group’s management. Item 10 – Other Financial Industry Activities and Affiliations The Advocate Group is an independent investment advisory firm. It provides investment advisory services and is a licensed insurance agency. The firm is not engaged in any other business activities and offers no services other than those described in this brochure. Insurance products are offered on occasion, at client request only, to assist in meeting personal, estate and business needs to minimize clients’ exposure to identified risks. Although clients are under no obligation to purchase insurance products recommended by our staff in their separate capacities as insurance agents, clients do purchase such products when needs arise. For clients of the firm who purchase products causing commissions to be generated, these are directed to the agency and are not for the benefit of an individual agent. For those staff members who are insurance licensed, this activity varies throughout the year. Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading Section 204A-1 of the Investment Advisers Act of 1940 requires all investment advisers to establish, maintain and enforce a Code of Ethics. The Advocate Group has established a Code of Ethics that applies to all of its associated persons. An investment adviser is considered a fiduciary according to the Investment Advisers Act of 1940. 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. The Advocate Group has a fiduciary duty to all clients. This fiduciary duty is considered the core underlying principle for the advisor’s Code of Ethics which also covers its Insider Trading and Personal Securities Transactions Policies and Procedures. The Advocate Group requires all its supervised persons 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 or affiliation and when changes occur, all supervised persons will sign an acknowledgement that they have read, understand and agree to comply with The Advocate Group’s Code of Ethics. The Advocate Group has the responsibility to make sure that the interests of all clients are placed ahead of The Advocate Group’s or its supervised person’s own investment interest. Full disclosure of all material facts and potential conflicts of interest will be provided to clients prior to any services being conducted. The Advocate Group and its supervised persons 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. The Advocate Group or its associated persons are permitted to buy or sell for their personal accounts, investment products identical to those recommended to clients. This creates a potential conflict of interest. It is the express policy of The Advocate Group that all persons associated in any manner with The Advocate Group must place the interests of The Advocate Group’s clients ahead of their own when implementing personal investments. The Advocate Group and its associated persons shall not buy or sell securities for their personal account(s) where their decision is derived, in whole or in part, by information obtained as a result of his/her employment unless the information is also available to the investing public upon reasonable inquiry. 10 The Advocate Group, LLC Form ADV Part 2 - Firm Brochures  This disclosure is provided to give clients a summary of The Advocate Group’s Code of Ethics. However, if a client or a potential client wishes to review The Advocate Group’s Code of Ethics in its entirety, a copy will be provided promptly upon request to Michael Corrigan at (952) 693-2630 or mcorrigan@TheAdvocateGroup.com. Item 12 – Brokerage Practices Custodians and Brokers The Advocate Group recommends broker/dealers and custodians that The Advocate Group feels will provide services in a manner and at a cost that will allow The Advocate Group to meet its duty of best execution. Client assets must be maintained in an account at a qualified custodian; generally, a brokerage firm, mutual fund company or bank. While The Advocate Group does not have discretion to determine which custodian will be used or the commission rates paid, we have relationships with Schwab Advisor Services, a division of Charles Schwab & Co. (“Schwab”), and Fidelity Investments (“Fidelity”). Schwab and Fidelity are registered broker dealers and SIPC members. The Advocate Group is independently owned and operated and is not affiliated with Schwab or Fidelity. Schwab and Fidelity maintain client custody accounts for our clients. Schwab and Fidelity will also buy and sell securities when we instruct them to do so, as your adviser. While we recommend Schwab or Fidelity as qualified custodians, the ultimate decision is left to the client. If the client elects to establish an account to custody assets elsewhere, this can result in the loss of possible advantages derived from bunching of orders for several clients as a single transaction or more attractive share classes at lower minimums. Also, even though an account is maintained at Schwab or Fidelity, clients can still use other brokers to execute trades for their account. Custodian/Broker Selection The Advocate Group seeks to recommend a custodian/broker who will hold client assets and execute transactions on terms that are, overall, most advantageous when compared to other available providers and their services. The factors that we consider in making our recommendations to clients include respective financial strength, reputation, execution quality, pricing, research, and service. Schwab and Fidelity enable us to obtain certain exchange-traded funds (ETFs) and mutual funds without transaction charges and other securities at nominal transaction charges. The Advocate Group recommends transactions in fixed income securities. Although it does not do so at present, The Advocate Group may execute fixed income transactions through broker dealers other than Schwab or Fidelity depending upon the type of bond and price comparisons. Best execution is tested if or when similar bonds might appear in inventory at multiple dealers. Outside broker dealers may act as principal on these trades. Brokerage and Custody Costs Schwab, Fidelity and other broker dealers are compensated by charging commissions, collecting shareholder service fees from Mutual Fund companies, or other fees associated with trade execution and/or delivery. Schwab and Fidelity may charge separately for certain custody services. The client may pay a commission that is higher than another qualified custodian might charge to effect the same transaction where The Advocate Group determines, in good faith, that the commission is reasonable in relation to the value of the brokerage and research services received. The Advocate Group has determined that having Schwab and Fidelity execute most trades is consistent with our duty to seek best execution. Best execution 11 The Advocate Group, LLC Form ADV Part 2 - Firm Brochures  means the most favorable terms for a transaction based on all relevant factors, taking into consideration the full range of a broker dealer's services, including the value of research provided, execution capability, commission rates, and responsiveness. Therefore, while The Advocate Group will seek competitive rates, we may not necessarily obtain the lowest possible commission rates for every client transaction. Clients that select Schwab or Fidelity to serve as custodian of their assets benefit from the commission rates Schwab or Fidelity make available to our clients. While The Advocate Group presently executes all trades through Schwab or Fidelity for client accounts held at those respective custodians, future bond trades may be executed through a different broker dealer if we reasonably believe that an alternate broker dealer will provide best execution. Therefore, future bond trades could be executed at different times and different prices. We periodically and systematically review our policies and procedures regarding recommending broker dealers to our clients in light of our duty to obtain best execution. Clients are permitted to direct The Advocate Group, in writing, to use a particular broker dealer to execute some or all of your transactions; also known as directed brokerage. In that case, the client will negotiate terms and arrangements for the account with that broker dealer. With these directed brokerage arrangements, a client may pay higher commissions, greater spreads or less favorable net prices. If the Firm agrees to a client request to direct brokerage, we are relieved of our obligation to seek better execution services or prices from other broker dealers. Furthermore, we will be unable to "batch" client transactions for execution through other broker dealers with orders for other accounts managed by The Advocate Group. We may decline a client’s request to direct brokerage if, in our sole discretion, such directed brokerage arrangements would result in undue operational difficulties. The Advocate Group does not have any formal soft dollar arrangements. Aggregate Trades In some cases, transactions implemented by The Advocate Group are effected on an individual basis. However, sometimes The Advocate Group will purchase or sell the same securities for several clients at approximately the same time. This process is referred to as aggregating orders, batch trading or block trading and is used by The Advocate Group when The Advocate Group believes such action is advantageous to clients. When The Advocate Group aggregates client orders, the allocation of securities among client accounts will be done on a fair and equitable basis. Typically, the process of aggregating client orders is done to achieve better execution, to negotiate more favorable commission rates or to allocate orders among clients on a more equitable basis to avoid differences in prices and transaction fees or other transaction costs that might be obtained when orders are placed independently. There could be situations where accounts that have special handling instructions and/or restrictions based on client direction could be prevented from taking advantage of the benefits of aggregate batch or block trading and could miss market opportunities based on market fluctuation. Under this procedure, transactions will be allocated among The Advocate Group’s clients in a fair and equitable manner for each client account on any given day. It should be noted, The Advocate Group does not receive any additional compensation or remuneration as a result of aggregation. Cross Trades The Advocate Group will not engage in cross transactions that involve a broker-dealer and where The Advocate Group has discretion over only one of the client accounts involved in the transaction and it, or an affiliated broker-dealer, executes the transaction for both sides in a brokerage capacity. The Advocate Group will engage in cross trades when it is deemed to be in the best interest of the clients. A cross trade occurs when a transaction is implemented between two different clients, both of which are managed by The 12 The Advocate Group, LLC Form ADV Part 2 - Firm Brochures  Advocate Group. These types of cross transactions will only be used when it can be determined that doing so would achieve “best execution” and benefit the clients involved by saving commissions, market impact costs, and other transaction charges. Prior to implementing cross trades, full disclosure will be made in The Advocate Group’s Form ADV and detail of cross trade activity would be fully disclosed and accepted in writing by all participating clients. Cross trades will not be performed if an account is subject to ERISA since it is virtually prohibited. In addition, if a client account managed by The Advocate Group is deemed to hold “plan assets” cross trades will be prohibited regardless of whether the other side to the transaction is subject to ERISA. Trade Error Policy The Advocate Group has implemented procedures designed to prevent trade errors; however, trade errors in client accounts cannot always be avoided. Consistent with its fiduciary duty, it is the policy of The Advocate Group to correct trade errors in a manner that is in the best interest of the client. In cases where the client causes the trade error, the client will be responsible for any loss resulting from the correction. Depending on the specific circumstances of the trade error, the client may not be able to receive any gains generated as a result of the error correction. In situations where the client does not cause the trade error, the client will be made whole and any loss resulting from the trade error will be absorbed by The Advocate Group if the error was caused by The Advocate Group. If the error is caused by the broker/dealer, the broker/dealer will be responsible for covering all trade error costs. The Advocate Group and its associated persons will never retain any portion of any gains made as a result of trade error corrections or profit in any way from trade errors. If the gain does not remain in the account, the broker/dealer will maintain gains that may result from correcting a trade error and in some instances may use such gains to offset overall losses the broker/dealer incurs from trading errors. Item 13 – Review of Accounts Account Reviews and Reviewers Ongoing financial planning services include periodic meetings with clients to review and update the information, assumptions and advice within the base plan. As changes happen throughout the year, The Advocate Group will meet either in person or over the phone to render financial advice on an ongoing basis. Account reviews are provided in connection with investment management accounts. The Advocate Group will contact the client at least annually to review their account and to determine if there have been changes in their financial situation or investment objectives. Reviews are often triggered by changes in the client’s circumstances, by client request, or because of changes within the market. The underlying investments held in client accounts are reviewed on a more frequent basis. Portfolios constructed by The Advocate Group are reviewed on an ongoing basis to reinvest cash, manage deposits and withdrawals, and to rebalance asset allocations. Reasons to make changes to portfolios include the relative valuation changes between asset classes, deviation from management style by fund, or fund closures. Statements and Reports Clients receive account statements directly from the client’s qualified custodian at least quarterly. In addition, The Advocate Group will provide performance or position reports of their accounts managed by The Advocate Group upon request and/or in person during meetings. 13 The Advocate Group, LLC Form ADV Part 2 - Firm Brochures  Clients are strongly urged to compare all reports prepared by The Advocate Group against the account statements received from the client’s broker/dealer or qualified custodian. Item 14 – Client Referrals and Other Compensation The Advocate Group does not directly or indirectly compensate anybody for client referrals. Other than the benefits from broker/dealers described in Item 12, the only form of compensation received from advisory accounts are the fees described in Item 5. Item 15 – Custody Custody, as it applies to investment advisors, has been defined by the SEC as having access or control over client funds and/or securities. In other words, custody is not limited to physically holding client funds and securities. If an investment advisor has the ability to access or control client funds or securities, the investment advisor is deemed to have custody and must ensure proper procedures are implemented. The Advocate Group is deemed to have custody of client funds and securities whenever The Advocate Group is given the authority to have fees deducted directly from client accounts. Following the February 2017 SEC No-Action Letter guidance, The Advocate Group is also deemed to have custody when assisting clients with 3rd party money movement requests. It should be noted that authorization to trade in client accounts is not deemed as custody by the SEC. For accounts in which The Advocate Group is deemed to have custody and for all other accounts, The Advocate Group has established procedures to ensure all client funds and securities are held at a qualified custodian (such as a broker/dealer or bank) 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 are aware of the qualified custodian’s name, address and the manner in which the funds or securities are maintained. Account statements are delivered directly from the qualified custodian to each client, or the client’s independent representative, at least quarterly. Clients should carefully review those statements and are urged to compare the statements against reports received from The Advocate Group. When clients have questions about their account statements, they should contact The Advocate Group or the qualified custodian preparing the statement. The February 2017 SEC No-Action Letter provided advisors with seven conditions that, if they are met, can help advisors avoid the annual surprise exam requirement when assisting clients with 3rd party money movement requests. The Advocate Group will maintain documentation supporting its compliance with the seven conditions. Item 16 – Investment Discretion Through its investment management services and upon receiving written authorization from a client, The Advocate Group will maintain trading authorization over client accounts. Upon receiving written authorization from the client, The Advocate Group will most often implement trades on a discretionary basis. When discretionary authority is granted, The Advocate Group will have the authority to determine the type of securities and the amount of securities that can be bought or sold for the client’s portfolio without obtaining the client’s consent for each transaction. 14 The Advocate Group, LLC Form ADV Part 2 - Firm Brochures  If you decide to grant trading authorization on a non-discretionary basis, we will be required to contact you prior to implementing changes in your account. Therefore, you will be contacted and required to accept or reject our investment recommendations including: • The security being recommended • The number of shares or units • Whether to buy or sell Once the above factors are agreed upon, we will be responsible for making decisions regarding the timing of buying or selling an investment and the price at which the investment is bought or sold. If your accounts are managed on a non-discretionary basis, you need to know that if you are not able to be reached or are slow to respond to our request, it can have an adverse impact on the timing of trade implementations, and we may not achieve the optimal trading price. All clients have the ability to place reasonable restrictions on the types of investments that can be purchased in an account. Clients can also place reasonable limitations on the discretionary power granted to the firm so long as the limitations are specifically included as an attachment to the client agreement. Item 17 – Voting Client Securities A vote by proxy is a vote that is mailed in or cast in some other way while the person voting is physically absent. This is most frequently used by shareholders in a company who are unable to attend the annual shareholder's meeting but still want their vote to count. The Advocate Group does not perform proxy-voting services on a client’s behalf. Clients are instructed to read through the information provided with the proxy-voting documents and to make a determination based on the information provided. Upon request from the client, The Advocate Group provides limited clarifications of the issues presented in the proxy voting materials based on The Advocate Group’s understanding of issues presented in the proxy-voting materials. However, the client will have the ultimate responsibility for making all proxy-voting decisions. Item 18 – Financial Information This item is not applicable to The Advocate Group’s brochure. The Advocate Group does not require prepayment in fees six months or more in advance. Therefore, The Advocate Group is not required to include a balance sheet for its most recent fiscal year. The Advocate Group is not subject to a financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. Finally, The Advocate Group has not been the subject of a bankruptcy petition at any time. 15 The Advocate Group, LLC Form ADV Part 2 - Firm Brochures