THE PLANNING GROUP

The Planning Group Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of The Planning Group. If you have any questions about the contents of this brochure, please contact us at (847) 441-9400 or by email at: mbrown@planning-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. Additional information about The Planning Group is also available on the SEC’s website at www.adviserinfo.sec.gov. The Planning Group’s CRD number is: 298496. 465 Central Ave Suite 201 Northfield, IL 60093 (847) 441-9400 mbrown@planning-group.com https://www.planning-group.com Registration does not imply a certain level of skill or training. Version Date: 03/20/2026 i  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of The Planning Group on 03/10/2025 are described below. Material changes relate to The Planning Group’s policies, practices or conflicts of interests. • No material changes have been made ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ............................................................................................................................................................................................ ii Item 3: Table of Contents ........................................................................................................................................................................................... iii Item 4: Advisory Business ........................................................................................................................................................................................... 5 A. Description of the Advisory Firm ..................................................................................................................................................................... 5 B. Types of Advisory Services ................................................................................................................................................................................ 5 C. Client Tailored Services and Client Imposed Restrictions ............................................................................................................................. 6 D. Wrap Fee Programs ............................................................................................................................................................................................ 6 E. Assets Under Management ................................................................................................................................................................................ 6 Item 5: Fees and Compensation .................................................................................................................................................................................. 7 A. Fee Schedule ........................................................................................................................................................................................................ 7 B. Payment of Fees ................................................................................................................................................................................................... 8 C. Client Responsibility For Third Party Fees ...................................................................................................................................................... 8 D. Prepayment of Fees ............................................................................................................................................................................................ 8 E. Outside Compensation For the Sale of Securities to Clients .......................................................................................................................... 9 Item 6: Performance-Based Fees and Side-By-Side Management ........................................................................................................................... 9 Item 7: Types of Clients ................................................................................................................................................................................................ 9 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ...................................................................................................................... 9 A. Methods of Analysis and Investment Strategies ............................................................................................................................................ 9 B. Material Risks Involved ................................................................................................................................................................................... 10 C. Risks of Specific Securities Utilized ............................................................................................................................................................... 11 Item 9: Disciplinary Information ............................................................................................................................................................................... 13 A. Criminal or Civil Actions ................................................................................................................................................................................ 13 B. Administrative Proceedings ............................................................................................................................................................................ 13 C. Self-regulatory Organization (SRO) Proceedings ......................................................................................................................................... 13 Item 10: Other Financial Industry Activities and Affiliations ................................................................................................................................ 13 A. Registration as a Broker/Dealer or Broker/Dealer Representative ........................................................................................................... 13 B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor ............................ 13 C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests ....................................................... 13 D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ............................................. 14 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ....................................................................... 14 A. Code of Ethics .................................................................................................................................................................................................. 14 B. Recommendations Involving Material Financial Interests .......................................................................................................................... 14 C. Investing Personal Money in the Same Securities as Clients ...................................................................................................................... 14 iii  D. Trading Securities At/Around the Same Time as Clients’ Securities ........................................................................................................ 15 Item 12: Brokerage Practices ...................................................................................................................................................................................... 15 A. Factors Used to Select Custodians and/or Broker/Dealers ........................................................................................................................ 15 1. Research and Other Soft-Dollar Benefits ................................................................................................................................................... 15 2. Brokerage for Client Referrals .................................................................................................................................................................... 16 3. Clients Directing Which Broker/Dealer/Custodian to Use.................................................................................................................... 16 B. Aggregating (Block) Trading for Multiple Client Accounts ........................................................................................................................ 16 Item 13: Review of Accounts ..................................................................................................................................................................................... 16 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ......................................................................................... 16 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts ...................................................................................................... 17 C. Content and Frequency of Regular Reports Provided to Clients ............................................................................................................... 17 Item 14: Client Referrals and Other Compensation ................................................................................................................................................ 17 A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) ................. 17 B. Compensation to Non – Advisory Personnel for Client Referrals .............................................................................................................. 18 Item 15: Custody ......................................................................................................................................................................................................... 18 Item 16: Investment Discretion.................................................................................................................................................................................. 19 Item 17: Voting Client Securities (Proxy Voting) .................................................................................................................................................... 19 Item 18: Financial Information .................................................................................................................................................................................. 20 A. Balance Sheet .................................................................................................................................................................................................... 20 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ........................................... 20 C. Bankruptcy Petitions in Previous Ten Years ................................................................................................................................................. 20 iv  Item 4: Advisory Business A. Description of the Advisory Firm TPG Advisors, LLC d/b/a The Planning Group (hereinafter “TPG”) is a Limited Liability Company organized in the State of Illinois. The firm was formed in June 2018, and the principal owners are NJ Brown & Associates, Barron Wealth Management and Shuman Financial Consulting, LLC. B. Types of Advisory Services Portfolio Management Services TPG offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. TPG creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: Personal investment policy Asset selection Regular portfolio monitoring • • • Investment strategy • • Asset allocation • Risk tolerance TPG evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. TPG will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. TPG seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of TPG’s economic, investment or other financial interests. To meet its fiduciary obligations, TPG attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, TPG’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is TPG’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. TPG may direct clients to third-party investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, TPG will always ensure those 5  other advisers are properly licensed or registered as an investment adviser. TPG then makes investments with a third-party investment adviser by referring the client to the third-party adviser. TPG will not review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Financial Planning Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Services Limited to Specific Types of Investments in the gold and precious metal sectors), treasury TPG generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs inflation protected/inflation linked bonds and non-U.S. securities, although TPG primarily recommends strategic asset allocation of mutual funds and ETFs. TPG may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions TPG will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by TPG on behalf of the client. TPG may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent TPG from properly servicing the client account, or if the restrictions would require TPG to deviate from its standard suite of services, TPG reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. TPG does not participate in wrap fee programs. E. Assets Under Management TPG has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 278,698,387 $ 12,762,867 December 31, 2025 6  Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees $0 - $1,000,000 1.10% $1,000,001 - $2,000,000 0.85% $2,000,001 - $3,000,000 0.65% $3,000,001 - and up 0.50% Our asset management fees are annual fees and may be negotiable. Asset management fees are paid quarterly in arrears. Payments are based on the account’s asset value as of the last business day of the prior calendar quarter. The value is multiplied by the applicable annual rate and then multiplied by the pro-rated days in the quarter (example: $100,000 x 1% = $1,000 x 90/360= $250.00). The fee is billed and payable within ten (10) days after the end of the prior quarter. Fees will be deducted only upon receipt of a signed Investment Advisory Contract permitting the fees to be paid directly from your account. The qualified custodian will deliver an account statement to you at least quarterly, which will show all disbursements from your account. We urge you to review all statements for accuracy. As agreed upon with the client, TPG may charge a tiered fee or a single rate fee. Clients may terminate the agreement without penalty for a full refund of TPG's fees within five business days of the signing of the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 30 days' written notice. Financial Planning Fees Fixed Fees The negotiated fixed rate for creating client financial plans is between $500 and $25,000. Hourly Fees The negotiated hourly fee for these services is between $100 and $500. 7  Clients may terminate the agreement without penalty, for full refund of TPG’s fees, within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally upon written notice. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization. Fees are paid quarterly in arrears. Payment of Financial Planning Fees Financial planning fees are paid via check and wire. Fixed financial planning fees are paid 50% in advance, but never more than six months in advance, with the remainder due upon presentation of the plan. Hourly financial planning fees are paid 50% in advance, but never more than six months in advance, with the remainder due upon presentation of the plan. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by TPG. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees TPG collects certain fees in advance and certain fees in arrears, as indicated above. Refunds for fees paid in advance but not yet earned will be refunded on a prorated basis and returned within fourteen days to the client via check or return deposit back into the client’s account. Fixed fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination. For hourly fees that are collected in advance, the fee refunded will be the balance of the fees collected in advance minus the hourly rate times the number of hours of work that has been completed up to and including the day of termination. 8  E. Outside Compensation For the Sale of Securities to Clients Neither TPG nor its supervised persons accept any compensation for the sale of investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management TPG does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients TPG generally provides advisory services to the following types of clients: Individuals High-Net-Worth Individuals Pension and Profit-Sharing Plans Corporations or Business Entities ❖ ❖ ❖ ❖ There is no account minimum for any of TPG’s services. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis TPG’s methods of analysis include Fundamental analysis and Modern portfolio theory. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. 9  Investment Strategies TPG uses long term trading. For certain clients, TPG may use options trading (including covered options, uncovered options, or spreading strategies). Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Investment Strategies TPG's use of options trading generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long-term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Selection of Other Advisers: TPG's selection process cannot ensure that money managers 10  will perform as desired and TPG will have no control over the day-to-day operations of any of its selected money managers. TPG would not necessarily be aware of certain activities at the underlying money manager level, including without limitation a money manager's engaging in unreported risks, investment “style drift” or even regulatory breaches or fraud. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized For certain clients, TPG's use of options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best-known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, 11  or Palladium Bullion backed “electronic shares” not physical metal) specifically may be 12  negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Real estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 13  Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither TPG nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither TPG nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Michael David Brown and Paul Samuel Shuman are CPAs and from time to time, may offer clients advice from those activities and clients should be aware that these services may involve a conflict of interest. TPG always acts in the best interest of the client and clients are in no way required to utilize the services of any representative of TPG in connection with such individual’s activities outside of TPG. Michael David Brown, Nick J Brown, Paul Samuel Shuman, and Dani Gerald Barron are independent licensed insurance agents, and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a 14  commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. TPG always acts in the best interest of the client; including the sale of commissionable products to advisory clients. Clients are in no way required to utilize the services of any representative of TPG in connection with such individual's activities outside of TPG. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections TPG may direct clients to third-party investment advisers to manage all or a portion of the client's assets. Clients will pay TPG its standard fee in addition to the standard fee for the advisers to which it directs those clients. This relationship will be memorialized in each contract between TPG and each third-party advisor. The fees will not exceed any limit imposed by any regulatory agency. TPG will always act in the best interests of the client, including when determining which third-party investment adviser to recommend to clients. TPG will ensure that all recommended advisers are licensed, or notice filed in the states in which TPG is recommending them to clients. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics TPG has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. TPG's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests TPG does not recommend that clients buy or sell any security in which a related person to TPG or TPG has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of TPG may buy or sell securities for themselves that 15  they also recommend to clients. This may provide an opportunity for representatives of TPG to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. TPG will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of TPG may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of TPG to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, TPG will never engage in trading that operates to the client’s disadvantage if representatives of TPG buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers the market expertise and research access provided by Custodians/broker-dealers will be recommended based on TPG’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and TPG may also consider the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in TPG's research efforts. TPG will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. TPG will require clients to use Schwab Institutional, a division of Charles Schwab & Co., Inc. TPG recommends Principal Funds, The Vanguard Group, and Capital Group as custodians for defined contribution plans. 1. Research and Other Soft-Dollar Benefits While TPG has no formal soft dollars program in which soft dollars are used to pay 16  for third party services, TPG may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). TPG may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and TPG does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. TPG benefits by not having to produce or pay for the research, products or services, and TPG will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that TPG’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals TPG receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use TPG will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a broker-dealer. B. Aggregating (Block) Trading for Multiple Client Accounts If TPG buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, TPG would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. TPG would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for TPG's advisory services provided on an ongoing basis are reviewed at least Monthly by Michael D Brown, CCO, with regard to clients’ respective investment 17  policies and risk tolerance levels. All accounts at TPG are assigned to this reviewer. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Michael D Brown, CCO. Financial planning clients are provided a one-time financial plan concerning their financial situation. After the presentation of the plan, there are no further reports. Clients may request additional plans or reports for a fee. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). With respect to financial plans, TPG’s services will generally conclude upon delivery of the financial plan. C. Content and Frequency of Regular Reports Provided to Clients Each client of TPG's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. Each financial planning client will receive the financial plan upon completion. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) With respect to Schwab, TPG receives access to Schwab’s institutional trading and custody services, which are typically not available to Schwab 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 Schwab Advisor Services. Schwab’s services include 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 TPG client accounts maintained in its custody, Schwab 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 Schwab or that settle into Schwab accounts. 18  Schwab also makes available to TPG other products and services that benefit TPG but may not benefit its clients’ accounts. These benefits may include national, regional or TPG specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits may include occasional business entertainment of personnel of TPG by Schwab 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 TPG 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 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 TPG’s 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 TPG’s accounts. Schwab Advisor Services also makes available to TPG other services intended to help TPG 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, human capital consultants, insurance and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services rendered to TPG by independent third parties. Schwab 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 TPG. TPG is independently owned and operated and not affiliated with Schwab. B. Compensation to Non – Advisory Personnel for Client Referrals TPG does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, TPG will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Custody is also disclosed in Form ADV because TPG has authority to transfer money from client account(s), which constitutes a standing letter of authorization (SLOA). We are deemed to have custody as a result of our Standing Letters of Authorization (“SLOA(s)”) to transfer funds from their account to third parties. In such instances where we act under such an SLOA, it is our policy to only initiate these transactions when directed by the client 19  to transfer funds to a third party the client designates for a designated amount and at a designated time, all of their choosing. A surprise examination is not required in this circumstance where we are deemed to have custody due to SLOAs as we are relying on the conditions set forth in the No-Action letter issued by the Securities and Exchange Commission on February 21, 2017. Pursuant to the conditions set forth in the No-Action Letter, we confirm that in those situations • you provide an instruction to the qualified custodian, in writing, that includes your signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed; • you authorize us, in writing, either on the qualified custodian’s form or • separately, to direct transfers to the third party either on a specified schedule or from time to time; the qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify your authorization, and the qualified custodian provides a transfer of funds notice to you promptly after each transfer; • you have the ability to terminate or change the instruction to the qualified custodian; • we have no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in your instruction; • we maintain records showing that the third party is not a related party of TPG or • located at the same address as TPG; and the qualified custodian sends you, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Item 16: Investment Discretion TPG provides discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, TPG generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, TPG’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to TPG. Item 17: Voting Client Securities (Proxy Voting) TPG will not ask for, nor accept voting authority for client securities. Clients will receive 20  proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet TPG neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither TPG nor its management has any financial condition that is likely to reasonably impair TPG’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years TPG has not been the subject of a bankruptcy petition in the last ten years. 21