The Wealth Consulting Group

Item 1: Cover Page WCG Wrap Fee Brochure ADV Part 2A Registered As: WCG Wealth Advisors, LLC Doing Business As: The Wealth Consulting Group Registered Investment Adviser 8925 West Post Road Suite 200 | Las Vegas, Nevada 89148 (702) 263-1919 – Phone (702) 977-7750 – Fax April 27, 2026 This wrap fee program brochure provides information about the qualifications and business practices of WCG Wealth Advisors, LLC. If you have any questions about the contents of this brochure, please contact WCG Wealth Advisors, LLC at (702) 263-1919 or compliance@wealthcg.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Registration does not imply a certain level of skill or training. Additional information about WCG Wealth Advisors, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. 1  Item 2: Summary of Material Changes Form ADV Part 2 requires registered investment advisers to amend their Brochures when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochures, the adviser is required to notify you and provide you with a description of the material changes. WCG has one material change since our last Firm Brochure dated March 31, 2026: Item 9: Additional Information WCG will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. WCG may further provide other ongoing disclosure information about material changes, as necessary. WCG will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. requested by contacting WCG at (702) 263-1919 or Currently, our Disclosure Brochure may be compliance@wealthcg.com. Additional information about WCG Wealth Advisors, LLC is also available via the SEC’s website www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons affiliated with WCG Wealth Advisors, LLC who are registered or are required to be registered, as Investment Adviser Representatives of WCG Wealth Advisors, LLC. 2  Item 3: Table of Contents Contents Item 1: Cover Page ....................................................................................................................................... 1 Item 2: Summary of Material Changes ......................................................................................................... 2 Item 3: Table of Contents ............................................................................................................................. 3 Item 4: Services, Fees, and Compensation ................................................................................................... 4 Item 5: Account Requirements and Types of Clients .................................................................................. 12 Item 6: Portfolio Manager Selection and Evaluation .................................................................................. 12 Item 7: Client Information Provided to Portfolio Managers ....................................................................... 19 Item 8: Client Contact with Portfolio Managers ......................................................................................... 19 Item 9: Additional Information ................................................................................................................... 19 3  Item 4: Services, Fees, and Compensation Services WCG Wealth Advisors, LLC (“Advisor” and “WCG”) d/b/a The Wealth Consulting Group offers asset management services based on the individual needs of the client. This Brochure describes the advisory services offered under WCG Wrap Accounts. WCG can participate in wrap fee programs sponsored by other firms. For more information about the Advisor's other investment advisory services, please contact the Advisor for a copy of a similar brochure or visit www.adviserinfo.sec.gov. In WCG Wrap Accounts, Advisor provides ongoing investment advice and management of assets in the client’s account. Advisor provides advice on the purchase and sale of various types of investments, such as mutual funds, exchange- traded funds (“ETFs”), variable annuity subaccounts, equities, and fixed-income securities. Advisor provides advice that is tailored to the individual needs of the client based on the investment objective chosen by the client. Clients may impose restrictions on investing in certain securities or groups of securities by indicating in the written advisory agreement with Advisor. The Advisor provides management services on a discretionary or non-discretionary basis. The client may authorize the Advisor to have discretion on the advisory agreement. All accounts are managed by the Investment Adviser Representative (“IAR”) according to the Investment objective for the accounts. Advisor provides ongoing supervision over the IAR managing an account. The IAR may delegate portfolio management responsibilities to the Advisor using one of the Advisor’s model portfolios. This sub-advisor is a separate offering consisting of portfolio design, investment consulting, trade execution, and portfolio rebalancing services. The sub-advisor utilizes the account custodian and services are provided through WCG through a separate written agreement. IARs of Advisor are under no obligation to utilize these services and WCG Clients who utilize this service are not charged a separate fee. The IARs pay for these services themselves as a business expense. Assets for most program accounts are held at LPL Financial (“LPL”), Charles Schwab & Co., Inc., and Fidelity Brokerage Services, LLC as custodian(s). Other accounts and accounts that are managed by a third party may be custodied by a separate custodian. Fees In WCG Wrap Accounts, clients pay advisors a single annual advisory fee for advisory services and execution of transactions. Clients do not pay brokerage commissions, markups, or transaction charges for the execution of transactions in addition to the advisory fee. The advisory fee is negotiable between the client and the Advisor and is set out in the advisory agreement. The advisory fee is a percentage based on the value of all assets in the account, including cash holdings. The maximum advisory fee charged by WCG is 2.5%. Fees for similarly situated accounts will differ due to the negotiation of the advisory fee with the IAR, the size of the account, the complexity of the client's servicing needs, long-term or family relationship with the IAR, and services requested and time commitment. Fees may also be waived for employees or relatives of the advisor. The advisory fee may be higher than the fee charged by other investment advisers for similar services. The advisory fee is paid to Advisor and is shared between Advisor and its associated persons. Advisor does not accept performance-based fees for program accounts. Asset-Based Pricing (“ABP”) Fee WCG advisors can choose an Asset-Based Fee (ABP) through accounts custodied at LPL Financial or 4  transaction-based pricing. An ABP fee is a percentage charge on the dollar amount of assets in the account in lieu of individual transaction fees on trades executed in the account. The ABP is in addition to the advisory fee charged by the WCG Financial Advisor and in addition to the administrative fee (where applicable). The asset-based fees applicable to your account were negotiated based on the total amount of assets collectively maintained with the custodian of the assets. The ABP is calculated and paid to the custodian directly each month and is used to cover the transaction expenses to implement and trade the individual investment positions in the account. Transaction-Based Pricing (“TBP”) fee: Schwab, Fidelity and LPL offer custodial transaction-based pricing fees. The custodial transaction-based charges are billed by and paid to the custodian, on trade date, when a transaction is executed through the custodian and is based on the specific security or investment involved in the transaction. Custodial transaction-based charges are deducted from WCG’s wrap fee. The custodial transaction- based charges cover various transaction costs, such as mutual fund fees, brokerage commissions and mark- ups/mark-downs for fixed-income securities. WCG’s advisory fees are billed in advance or in arrears. It is important to note that the fees charged to clients can vary based on the investment adviser representative advising the account. An advisor may negotiate the fees at their sole discretion with the client, based on the complexity of the customer’s situation, the scope of services provided, time commitment, and the experience and expertise of the advisor. Please note the Advisor may group certain related Client accounts, often known as “householding”, for the purposes of achieving the minimum account size and determining the annualized fee. The advisory fee will be disclosed as an“Exhibit A” attached to the investment management agreement. In addition, fee schedules are set forth by the platform provider and agreed upon and monitored by WCG in their sole discretion with the client, so long as such fees fall within the ranges approved by the Advisor. WCG will bill you for our investment advice through LPL Financial’s billing system, or through our third-party billing systems. For clients who are billed based on a percentage of account assets, quarter-end fee assessments will be calculated using one of the following methodologies: • Using the LPL Financial system, the fee is calculated by taking the value of the account (based on the fair market value as assessed by the qualified custodian on the last day of the quarter) and multiplying that value by your advisory fee, the result is then divided by 360, representing days per accounting year and multiplying that result by the number of days in the month (based on 30 days in the month). • Using the third-party systems, the fee is calculated the same way except based on 365/366 days per accounting year and the actual days in the month. Note: LPL’s quarter-end fee assessment is based on the settlement date, while the third-party assessment is based on the valuation as of the last day of the quarter. Because of the different accounting methods, there may be slight variances in your assessed investment advisory fee. However, both methods are acceptable accounting practices. If you have any questions regarding the differences in fee calculation methods or how your fees are assessed, you are highly encouraged to contact WCG for further guidance. The advisory fee is deducted from the account by the custodian of the assets based on a written authorization from the client. The custodian calculates and deducts the advisory fee quarterly in advance orarrears. If the advisory agreement is terminated before the end of the quarterly period, the client is entitled to a pro-rated refund of any pre-paid quarterly advisory fee based on the number of days remaining in the quarter after the termination date. Generally, advisory fees assessed by WCG do not include the manager's fee, nor does it include brokerage commissions and other trading costs of transactions (such as mark-ups and mark-downs); mutual fund 12b-l fees; sub-transfer 5  agent, networking, and omnibus processing fees; transfer taxes, fund management fees, and administrative servicing fees; certain deferred sales charges on previously purchased mutual funds and other transaction charges and service fees, IRA and Qualified Retirement Plan fees; administrative servicing fees for trust accounts; and other taxes and charges required by law or imposed by exchanges or regulatory bodies. Fees for these platforms are found in the sponsor's or manager's Form ADV. Further information regarding fees and charges assessed by mutual funds, variable annuities, and exchange-traded funds that are passed on to a client is outlined in the sponsor's or manager's Form ADV and in that mutual fund's or annuity's prospectus and other disclosure documents, which are available upon request by contacting your IAR. Important information related to the fees for all available investment platforms is described in additional detail below. LPL Financial (“LPL”) SWM Platform: Transaction costs are included in a single fee that covers both advisory fees and transaction costs, the latter of which is paid by the adviser. As described previously, WCG has the option to negotiate with the custodian for a flat basis point or flat fee to cover all of the transaction charges or will pay the standard transaction fees. It is important to remember that the IAR can charge a higher overall advisory fee in order to offset their cost for the transaction charges involved in the management of the portfolio. Transaction fees vary by broker and/or custodian and can vary by IAR. Please ask your IAR for details on transaction fees and/or commissions specific to your account. The appropriateness of a SWM WRAP account can depend on several factors, including, among other things, client investment objectives and financial situation, frequency of withdrawals from the accounts, the IAR's investment strategies and trading patterns including the frequency of trading and the number and size of the transactions. Clients should consider that depending upon the level of the fee charges, the amount of portfolio activity in their accounts, the value of services that are provided, and other factors, SWM can exceed the aggregatecost of services if they were to be provided separately. A transaction-based pricing arrangement can be more cost-effective for accounts that do not experience frequent trading activity or client withdrawals which would increase the number of transactions. WCG primarily utilizes mutual funds that are part of the custodian's No-Transaction Fee (NTF) platform. This platform allows WCG to buy mutual funds without transaction fees being charged to the account. The client may still pay fees associated with mutual fund family fees that are described in their prospectus and the custodian's fee disclosure. Although clients do not pay a transaction charge for transactions in a SWM account, clients should be aware that WCG can pay LPL transaction charges for those transactions. The transaction charges paid by Advisor vary based on the type of transaction (e.g., mutual fund, equity, or ETF) and for mutual funds based on whether or not the mutual fund pays 12b-1 fees and/or recordkeeping fees to LPL. Because the Advisor pays the transaction charges in SWM accounts, there is a conflict of interest in cases where the mutual fund is offered at both $0 and $26.50. Clients should understand that the cost to WCG of transaction charges may be a factor that the Advisor considers when deciding which securities to select and how frequently to place transactions in a SWM account. In many instances, LPL makes available mutual funds in a SWM account that offer various classes of shares, including shares designated as Class A Shares and shares designed for advisory programs, which can be titled, for example, as "Class I," 'institutional," "retail," "service," "administrative" or "platform" share classes ("Platform Shares"). The Platform Share class offered for a particular mutual fund in SWM in many cases will not be the least expensive share class that the mutual fund makes available and was selected by LPL in certain cases because the share class pays LPL compensation for the administrative and recordkeeping services LPL provides to the mutual fund. Client should understand that another financial services firm may offer the same mutual fund at a lower overall cost to the investor than is available through SWM. Although WCG does not sell Class A share mutual funds, it is important to note that A Shares typically pay LPL a 6  12b-1 fee for providing brokerage-related services to the mutual funds. Platform Shares are generally not subject to 12b-1 fees. As a result of the different expenses of the mutual fund shares classes, it is generally more expensive for a client to own Class A Shares than Platform Shares. An investor in Platform Shares will pay lower fees over time and keep more of his or her own investment returns than an investor who holds Class A Shares of the same fund. Clients should consider any additional indirect expenses borne as a result of mutual fund fees when negotiating and discussing with their Advisor the advisory fee for the management of an account. As noted above, mutual funds are sold with different share classes, whichcarry different cost structures. Eachavailable share class is described in the mutual fund's prospectus. When WCG purchases, or recommends the purchase of, mutual funds for a client, WCG selects the share class that is deemed to be in the client’s best interest, taking into consideration cost, tax implications, and other factors. When the fund is available for purchase at net asset value, WCG will purchase, or recommend the purchase of, the fund at net asset value. WCG also reviews the mutual funds held in accounts that come under our management to determine whether a more beneficial share class is available, considering cost, tax implications, and the impact of contingent deferred sales charges. Other Types of Fees and Charges Program accounts will incur additional fees and charges from parties other than the Advisor as noted below. These fees and charges are in addition to the advisory fee paid to Advisor. Advisor does not share in any portion of these third- party fees. LPL Financial, as the broker-dealer providing brokerage and execution services on program accounts, and various custodians will impose certain fees and charges. LPL notifies clients of these charges at account opening and makes available a list of these fees and charges onits website at www.lpl.com. The custodian that holds the account will deduct these fees and charges directly from the client’s program account. There are other fees and charges that are imposed by other third parties that apply to investments in programaccounts. Some of these fees and charges are described below. • If a client’s assets are invested in mutual funds or other pooled investment products, clients should be aware that there will be two layers of advisory fees and expenses for those assets. Client will pay an advisory fee to the fund manager and other expenses as a shareholder of the fund. Client will also pay Advisor the advisory fee with respect to those assets. Most of the mutual funds available in the program may be purchased directly. Therefore, clients could generally avoid the second layer of fees by not using the management services of an Advisor and by making their own investment decisions. • Certain mutual funds impose fees and charges such as contingent deferred sales charges, early redemption fees, and charges for frequent trading. These charges may apply if the client transfers into or purchases such a fund with the applicable charges in a program account. Although only no-loadand load-waived mutual funds can be purchased in a program account, as noted previously, the client should understand that some mutual funds pay asset-based sales charges or service fees (e.g., 12b-1 fees) to the custodian with respect to account holdings. • If a client holds a variable annuity as part of an account, there are mortality, expense, and administrative charges, fees for additional riders on the contract, and charges for excessive transfers within a calendar year imposed by the variable annuity sponsor. Further information regarding fees assessed by a mutual fund, or variable annuity is available in the appropriate prospectus, which is available upon request from the Advisor or from the product sponsor directly. 7  Other Important Considerations • The advisory fee is an ongoing wrap fee for investment advisory services, the execution of transactions, and other administrative and custodial services. The advisory fee may cost the client more than purchasing the program services separately, for example, paying an advisory fee plus commissions for each transaction in the account. Factors that bear upon the cost of the account in relation to the cost of the same services purchased separately include the type and size of the account, historical and or expected size or the number of trades for the account, and number and range of supplementary advisory and client-related services provided to the client. • The advisory fee also may cost the client more than if assets were held in a traditional brokerage account. In a brokerage account, a client is charged a commission for each transaction, and the representative has no duty to provide ongoing advice with respect to the account. If the client plans to follow a buy-and-hold strategy for the account or does not wish to purchase ongoing investment advice or management services, the client should consider opening a brokerage account rather than a program account. • The Advisor recommending the program to the client receives compensation as a result of the client’s participation in the program. This compensation includes the advisory fee and also may include other compensation, such as bonuses, awards, or other things of value offered by LPL Financial to the Advisor or its associated persons. The amount of this compensation may be more or less than what the Advisor would receive if the client participated in other LPL Financial programs, and programs of other investment advisors or paid separately for investment advice, brokerage, and other client services. Therefore, the Advisor may have a financial incentive to recommend a program account over other programs and services. • The investment products available to be purchased in the program can be purchased by clients outside of a program account, through broker-dealers, or other investment firms not affiliated with Advisor. Economic Benefits As a registered investment adviser, WCG has access to the institutional platform of your account custodian. As such, WCG will also have access to research products and services from your account custodian and/or other brokerage firms. These products are in addition to any benefits or research WCG pay for with soft dollars, andmay include financial publications, information about particular companies and industries, research software, and other products or services that provide lawful and appropriate assistance to our firm in the performance of our investment decision-making responsibilities. Such research products and services are provided to all investment advisers that utilize the institutional services platforms of these firms and are not considered to be paid for with soft dollars. However, you should be aware that the commissions charged by a particular broker for a particular transaction or set of transactions may be greater than the amounts another broker who did not provide research services or products might charge. Charles Schwab & Co., Inc.- Institutional In addition, WCG receives aneconomic benefit from Schwabin the formof the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. The availability to us of Schwab's products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. Services that Benefit You Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include 8  some to which WCG might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that May Not Directly Benefit You Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. WCG may use this research to service all or some substantial number of our client’s accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: facilitate trade execution and allocate aggregated trade orders for multiple client accounts. • provide access to client account data (such as duplicate trade confirmations and account statements). • • provide pricing and other market data; facilitate payment of our fees from our clients’ accounts; and assist with back-office functions, recordkeeping, and client reporting. Services that Generally Benefit Only Us Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: technology, compliance, legal, and business consulting; • Educational conferences and events; • • publications and conferences on practice management and business succession; • access to employee benefits providers, human capital consultants, and insurance providers; • discount of up to $4,250 on PortfolioCenter® software. Schwabmay provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these servicesor pay all or a part of a third party’s fees. Schwab may also provide us with other benefits such as occasional business entertainment for our personnel. Fidelity Brokerage Services, LLC WCG has an arrangement with Fidelity Brokerage Services LLC (together with all affiliates, "Fidelity") through which Fidelity provides WCG with Fidelity's "platform" services. The platform services include, among others, brokerage, custodial, administrative support, record keeping, and related services that are intended to support firms like WCG in conducting business and in serving the best interests of their clients. Fidelity charges brokerage commissions and transaction fees for effecting certain securities transactions (i.e., transactions fees are charged for certain no- load mutual funds and commissions are charged for individual equity and debt securities transactions). Fidelity enables WCG to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. Fidelity's commission rates are generally considered discounted from customary retail commission rates. However, the commissions and transaction fees charged by Fidelity may be higher or lower than those charged by other custodians and broker-dealers. As part of the arrangement, Fidelity also makes available to WCG, at no additional charge, certain research, and brokerage services, including research services obtained by Fidelity directly from independent research companies, as selected by WCG (within specified parameters). These research and brokerage services include: • provide access to client account data (such as trade confirmations and account statements); • facilitate trade execution and allocate bundled trade orders for multiple client accounts); • provide research, pricing, and other market data; 9  facilitate payment of WCG's fees from its clients' accounts; compliance, legal and business consulting; and • • assist with back-office functions, recordkeeping, and client reporting; • • publications, and conferences on practice management and business succession. As a result of receiving such services for no additional cost, WCG may have an incentive to continue to use or expand the use of Fidelity's services. WCG examined this potential conflict of interest when it chose to enter into the relationship with Fidelity and has determined that the relationship is in the best interests of its clients and satisfies its client obligations, including its duty to seek the best execution. WCG and Fidelity are not affiliated, nor is there any broker-dealer affiliation between WCG and Fidelity. Brokerage for Client Referrals WCG does not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. Retirement Plan Services WCG Wealth Advisors, LLC provides advisory services to employer sponsored retirement plans with participant directed investments. Services provided fall under Sections 3(21) and 3(38) of the Employee Retirement Income Security Act of 1974, as amended (ERISA). When serving as a 3(38) investment manager, WCG Wealth Advisors, LLC will act as fiduciary, as defined by ERISA, in a discretionary capacity, taking responsibility for selecting, monitoring, and adjusting the Plan’s investment lineup according to the Plan’s Investment Policy Statement (IPS). The 3(38) Investment Management Agreement, executed between WCG Wealth Advisors, LLC and the Plan Sponsor, will disclose the full details and provisions of the services provided. When serving as a 3(21) investment advisor, WCG Wealth Advisors, LLC will act as a co-fiduciary with the Plan Sponsor. WCG Wealth Advisors, LLC will make plan investment recommendations for the Plan Sponsor’s ultimate approval or rejection. The Plan Sponsor will be responsible for documenting any decision they make and implementing any recommendation. The 3(21) Investment Advisor Agreement, executed between WCG Wealth Advisors, LLC and the Plan Sponsor, will disclose the full details and provisions of the services provided. Although WCG is deemed a fiduciary under the Investment Advisers Act of 1940, WCG may also provide Plan Consulting Services that are non-fiduciary for purposes of Employee Retirement Income Security Act of 1974 (ERISA). These services may include participant education, enrollment support, due diligence reviews, and benchmarking. The scope of services and applicable terms will be set forth in the governing agreement. WCG does not provide ERISA fiduciary advice when performing these services), WCG Wealth Advisors, LLC does not serve as administrator or trustee of the employer sponsored retirement plan. WCG Wealth Advisors, LLC does not have the authority to initiate third-party disbursements of Plan funds or securities with the exception of, for some plans, having written authorization from the Plan Sponsor to deduct our fees. To the extent required under ERISA Section 408(b)(2), WCG Wealth Advisors, LLC will disclose any material changes to required information as soon as practicable, but no later than sixty (60) days after becoming aware of the change, unless extraordinary circumstances delay the disclosure. Upon written request from the responsible plan fiduciary or Plan Administrator, WCG Wealth Advisors, LLC will provide, within thirty (30) days, any information related to the Retirement Plan Services Agreement and associated compensation necessary for the plan to satisfy its ERISA reporting and disclosure requirements, unless extraordinary circumstances prevent timely delivery. 10  Rollovers In accordance with general WCG policy, WCG IARs do not provide recommendations about whether to roll assets out of employer-sponsored retirement Plans. If Client is a participant in an employer-sponsored retirement plan such as a 401(k) plan and decides to roll assets out of the plan into the Account, WCG IARs have a financial incentive to encourage the Client to invest those assets in the Account, because WCG will be paid on those assets, for example, through advisory fees. You should be aware that such fees likely will be higher than those a participant pays through an employer- sponsored plan, and there can be maintenance and other miscellaneous fees. As securities held in employer-sponsored plans are generally not transferable to the Account, commissions and sales charges may be charged when liquidating such securities prior to the transfer, in addition to commissions and sales charges previously paid on transactions in the plan. However, this conflict of interest is mitigated by WCG’s policy prohibiting its IARs from recommending clients roll out of employer-sponsored plans into a WCG individual retirement account (“IRA”), though IARs may assist by educating clients on their options as well as various pros and cons of initiating a roll-out of an employer-sponsored plan and may recommend how IRA assets be invested after the client has determined to roll out of the plan. Fees for Retirement Plan Services For retirement plan services, Plan Sponsors are charged fees as set forth in the applicable Advisory Agreement. Fees are typically structured as a percentage of plan assets under management (“AUM”). Fees are generally calculated based on the plan’s value, determined using either the quarter-end balance or the average daily balance of plan assets. In certain cases, WCG may charge a fixed fee or other agreed-upon fee arrangement, as specified in the Advisory Agreement. Fees may be billed quarterly in advance or in arrears and, in some instances, may be billed on a monthly basis. The specific fee schedule, billing methodology, and calculation process are detailed in the Advisory Agreement executed with the Plan Sponsor. Fees may be deducted directly from plan assets or participant accounts with written authorization, as outlined in the Advisory Agreement. Alternatively, the Plan Sponsor may be billed directly for the agreed-upon fee. When invoiced, payment is due within thirty (30) days after the end of the quarter. Clients receive account statements from the plan’s qualified custodian and should compare them with any reports provided by WCG. If services terminate during a billing period, prepaid unearned fees will be refunded, or if billed in arrears, fees will be charged only for services provided through the termination date. retirement plan consultants, including WCG Wealth Advisors, LLC believes that its annual fee is reasonable in relation to the services provided and the fees charged by other investment advisors, offering similar services/programs. However, WCG Wealth Advisors, LLC’s annual fee may be higher or lower than that charged by other consultants offering similar services and programs. In addition to WCG Wealth Advisors, LLC's compensation, clients will incur charges imposed at the investment level (e.g., mutual fund advisory fees and other fund expenses) and charges imposed by the Plan’s custodian and Third-Party Administrator (if applicable). Descriptions of mutual fund fees and expenses are available in each mutual fund prospectus. The Plan’s custodian or the Third-Party Administrator to the Plan will send statements to the Plan, at least quarterly, showing all disbursements from the Plan, including, if applicable, the amount of the fee paid to WCG Wealth Advisors, LLC directly from the Plan and when a such fee is deducted directly from the Plan. Any discrepancies between fee billing notices received from WCG Wealth Advisors, LLC and the statements received from the Plan custodian or Third-Party Administrator should be immediately reported to WCG Wealth Advisors, LLC and/or to the issuer of the account statements (the Plan custodian or Third-Party Administrator). Brokerage commissions and/or transaction ticket fees charged by the custodian will be billed directly to the client by the custodian. WCG Wealth Advisors, LLC will not receive any portion of such brokerage commissions or transaction fees from the custodian or the client. 11  The fees charged by WCG Wealth Advisors, LLC are in addition to other costs charged by third parties forcustodial, legal, accounting, or record-keeping tasks. In addition, the client may incur certain charges imposed by third parties other than WCG Wealth Advisors, LLC in connection with investments made through the Plan, including but not limited to, 12(b)-1 fees and surrender charges, variable annuity fees and surrender charges, and qualified retirement plan fees. Item 5: Account Requirements and Types of Clients A minimum account value is not generally required for the program. If you are invested in the WCG Model Portfolios, the minimum requirement ranges from $15,000-$500,000 depending on the portfolio you select. The program is available for individuals, high net worth individuals, individual retirement accounts (“IRAs”), banks and thrift institutions, pension, and profit-sharing plans, including plans subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), trusts, estates, charitable organizations, state and municipal government entities, corporations, and other business entities. WCG is currently not working with other types of clients or pursuing them as prospects but would not turn away any opportunities that may arise. Item 6: Portfolio Manager Selection and Evaluation WCG Wealth Advisors, LLC, through its Investment Advisor Representatives, is responsible for tailored investment advice and asset management on the purchase and sale of various types of investments, such as: • mutual funds • exchange-traded funds (“ETFs”) • variable annuity subaccounts • equities • fixed income securities • Structured products, • Alternative Investments Advice is provided to clients based on their individual needs and investment objectives. Clients may impose restrictions on investing in certain securities or groups of securities in the written advisory agreement. WCG generally requires that Investment Advisor Representatives involved in determining or giving investment advice have several years of experience dealing with individuals and/or small businesses. WCG does not select, review, or recommend partners or portfolio managers not registered with WCG. There are no differences between how the wrap fee program is managed and how other accounts are managed. The other non-wrap fee programs provided by the advisor include: • Asset Management Investment advisor representatives provide advice on the purchase and sale of various types of investments, such as mutual funds, exchange-traded funds (“ETFs”), variable annuity subaccounts, real estate investment trusts (“REITs”), equities, fixed income securities. The advice is tailored to the individual needs of the client based on the investment objective chosen by the client in order to help assist clients in attempting to meet their financial goals. Accounts are reviewed on a regular basis and rebalanced as necessary according to each client’s investment profile. 12  As previously mentioned, a minimum account value is not required for the programunless you are in the WCG Model Portfolios. WCG Model Portfolios range from $15,000-$500,000. Assets managed in a wrap fee account are not managed differently from a non-wrap fee account. However, WCG Wealth Advisors, LLC may charge a higher fee, up to 2.5%, and receive a portion of the wrap fee for services provided. As of December 31, 2025, WCG had $6,276,683,993 in discretionary assets under management. The Advisor has entered into agreements with various third-party advisors. Under these agreements, the Advisor offers clients various types of programs sponsored by these advisors. All third-party investment advisors to whom the Advisor will refer clients will be licensed as investment advisors by their resident state and any applicable jurisdictions or registered investment advisors with the Securities and Exchange Commission. After gathering information about a client's financial situation and investment objectives, the Advisor will assist the client in selecting a particular third-party program. The Advisor receives compensation pursuant to its agreements with these third-party advisors for introducing clients to these third-party advisors and for certain ongoing services provided to clients. This compensation is disclosed to the client in a separate disclosure document and is typically equal to a percentage of the investment advisory fee charged by that third-party advisor or a fixed fee. The disclosure document provided by the Advisor will clearly state the fees payable to the Advisor and the impact to the overall fees due to these payments. Since the compensation the Advisor receives may differ depending on the agreement with each third-party advisor, the Advisor may have an incentive to recommend one third-party advisor over another, if the compensation arrangements are more favorable. Since the independent third-party advisor may pay the fee for the investment advisory services of the Advisor, the fee paid to the Advisor is not negotiable under most circumstances. Fees paid by clients to independent third parties are established and payable in accordance with Form ADV 2A or other equivalent disclosure documents of each independent third-party advisor to whom the Advisor refers its clients, and may or may not be negotiable, as disclosed in the disclosure documents of the third-party advisor. Clients who are referred to third-party investment advisors will receive full disclosure, including services rendered and fee schedules, at the time of the referral, by delivery of a copy of the relevant third-party advisor's Form ADV 2A or equivalent disclosure document at the same time as the Form ADV 2A or equivalent disclosure document of the Advisor. In addition, if the investment program recommended to a client is a wrap fee program the client will also receive the wrap fee brochure provided by the sponsor of the program. The Advisor will provide each client with all of the appropriate disclosure statements, including disclosure of solicitation fees to the Advisor and its advisory associates. LPL Sponsored Programs • Optimum Market Portfolios Program (OMP) OMP offers clients the ability to participate in a professionally managed asset allocation program using Optimum Funds Class I shares. Under OMP, the client will authorize LPL Financial on a discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. The advisor will assist the client in determining the suitability of OMP for the client and assist the client in setting an appropriate investment objective. Advisor will have the discretion to select a mutual fund asset allocation portfolio designed by LPL Financial consistent with the client’s investment objective. LPL Financial will have the discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL Financial will also have the authority to 13  rebalance the account. A minimum account value of $10,000 is generally required for OMP. • Personal Wealth Portfolios Program (PWP) PWP offers clients an asset management account using asset allocation model portfolios designed by LPL Financial. Advisors will have discretion inselecting the asset allocationmodel portfolio based onthe client’s investment objective. Advisors will also have discretionfor selecting third-party money managers(PWP Advisors) or mutual funds within each asset class of the model portfolio. LPL Financial willact as the overlay portfoliomanager onall PWP accounts and will be authorized to purchase and sell on a discretionary basis mutual funds and equity and fixed income securities. A minimum account value of $250,000 is required for PWP. • Model Wealth Portfolios Program (MWP) MWP offers clients a professionally managed mutual fund asset allocation program. WCG Wealth Advisors, LLC investment advisor representatives will obtain the necessary financial data from the client, assist the client in determining the suitability of the MWP program and assist the client in setting an appropriate investment objective. The Advisor will initiate the steps necessary to open an MWP account and have the discretion to select a model portfolio designed by LPL Financial’s Research Department consistent with the client’s stated investment objective. LPL Financial’s Research Department is responsible for selecting the mutual funds within a model portfolio and for making changes to the mutual funds selected. The client will authorize LPL Financial to act on a discretionary basis to purchase and sell mutual funds (including in certain circumstances exchange-traded funds) and to liquidate previously purchased securities. The client will also authorize LPL Financial to effect rebalancing for MWP accounts. In the future, the MWP programmay make available model portfolios designed by strategists other than LPL Financial’s Research Department. If such models are made available, Advisor will have the discretion to choose among the available models designed by LPL Financial and outside strategists. A minimum account value of $10,000 – $100,000 is generally required (maybe lower) for MWP depending on the portfolio you choose. • Manager Access Select Program (“MAS")/Manager Access Network (“MAN”) MAS/MAN provides clients access to the investment advisory services of professional portfolio management firms for the individual management of client accounts. The advisor will assist the client in identifying a third-party portfolio manager (Portfolio Manager) from a list of Portfolio Managers made available by LPL Financial. The Portfolio Manager manages the client’s assets on a discretionary basis. Advisor will provide initial and ongoing assistance regarding the Portfolio Manager selection process. A minimum account value of $50,000 is required for Manager Access Select, however, in certain instances, the minimum account size may be higher. A minimum account value of $100,000 is required for Manager Access Network, however, in certain instances, the minimum account size may be higher. 14  Schwab Advisory Program • Managed Account Access Program (Access”) The Managed Account Access Program (“Access”) is a “single contract” structure that allows the Advisor to work with an array of money managers. Other features and benefits include, but are not limited to, bundled fees and access to over 75 managers on this platform. . The money managers will manage the accounts on a discretionary basis. The account minimum for the Managed Account Access program is typically $100,000 for accounts utilizing equities but can be more for fixed income. An advisor recommending the wrap fee program receives compensation as a result of a client’s participation in the program. The amount of this compensation may be more than what the person would receive if the client participated in other programs or paid separately for investment advice, brokerage, and other services. Therefore, advisors may have a financial incentive to recommend the wrap fee program over other programs or services. There may be additional fees on assets held in the wrap program, such as mutual fund expenses and mark-ups, mark-downs, or spreads paid to market makers. A more detailed description of these fees and circumstances is detailed above in Item 4 above. For more information about the associated person of the Advisor managing the account, the client should refer to the Brochure Supplement for the associated person, which the client should have received along with this Brochure at the time client opened the account. LPL Financial performs certain administrative services for Advisor, including the generation of quarterly performance reports for program accounts. Client will receive an individual quarterly performance report, which provides performance information on a time-weighted basis. The performance reports are intended to inform clients as to how their investments have performed for a period, both on an absolute basis and compared to leading investment indices. Methods of Analysis and Investment Strategies • Alternative Strategy Mutual Funds. Certain mutual funds available in the program invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be suitable for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes, and potential illiquidity. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. • Closed-End Funds. Client should be aware that closed-end funds available within the program are not readily marketable. In an effort to provide investor liquidity, the funds may offer to repurchase a certain percentage of shares at net asset value on a periodic basis. Thus, clients may be unable to liquidate all or a portion of their shares in these types of funds. • Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally classified as open- end mutual funds or UITs. However, they differ from traditional mutual funds in that ETF shares are listed on a securities exchange. Shares canbe bought and sold throughout the trading day like shares of other publicly traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the asking price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity and is generally lower if the ETF has a 15  lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities, are not registered as an investment company. • Exchange-Traded Notes (ETNs). An ETN is a senior unsecured debt obligationdesigned to track the total return of an underlying market index or other benchmark. ETNs may be linked to a variety of assets, for example, commodity futures, foreign currency, and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the prevailing market price. Some of the more common risks of an ETN are as follows. The repayment of the principal, interest (if any), and the payment of any returns at maturity or upon redemption are dependent upon the ETN issuer’s ability to pay. In addition, the trading price of the ETN in the secondary market may be adversely impacted if the issuer’s credit rating is downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated in a specific sector, asset class, or country and may therefore carry specific risks. • Options. Certain types of options trading are permitted in order to generate income or hedge a security held in the program account; namely, the selling (writing) of covered call options or the purchasing of put options on a security held in the program account. Client should be aware that the use of options involves additional risks. The risks of covered callwriting include the potential for the market to rise sharply. In such case, the security may be called away and the program account will no longer hold the security. The risk of buying long puts is limited to the loss of the premium paid for the purchase of the put if the option is not exercised or otherwise sold by the program account. • Structured Products. Structured products are securities derived from another asset, such as a security or a basket of securities, an index, a commodity, a debt issuance, or a foreign currency. Structured products frequently limit the upside participation in the reference asset. Structured products are senior unsecured debt of the issuing bank and are subject to the credit risk associated with that issuer. This credit risk exists whether or not the investment held in the account offers principal protection. The creditworthiness of the issuer does not affect or enhance the likely performance of the investment other than the ability of the issuer to meet its obligations. Any payments due at maturity are dependent on the issuer’s ability to pay. In addition, the trading price of the security in the secondary market, if there is one, may be adversely impacted if the issuer’s credit rating is downgraded. Some structured products offer full protection of the principal invested, others offer only partial or no protection. Investors may be sacrificing a higher yield to obtain the principal guarantee. In addition, the principal guarantee relates to the nominal principal and does not offer inflation protection. An investor in a structured product never has a claim on the underlying investment, whether a security, zero coupon bond or option. There may be little or no secondary market for the securities and information regarding independent market pricing for the securities may be limited. This is true even if the product has a ticker symbol or has been approved for listing on an exchange. Tax treatment of structured products may be different from other investments held in the account (e.g., income may be taxed as ordinary income even though payment is not received until maturity). Structured CDs that are insured by the FDIC are subject to applicable FDIC limits. • Hedge Funds and Managed Futures. Hedge and managed futures funds are available for purchase in the program by clients meeting certain qualification standards. Investing in these funds involves additional risks including, but not limited to, the risk of investment loss due to the use of leveraging and other speculative investment practices and the lack of liquidity and performance volatility. In addition, these funds are not required to provide periodic pricing or valuation information to investors and may involve complex tax structures and delays in distributing important tax information. Client should be aware that these funds are 16  not liquid as there is no secondary trading market available. At the absolute discretion of the issuer of the fund, there may be certain repurchase offers made from time to time. However, there is no guarantee that the client will be able to redeem the fund during the repurchase offer. • Variable Annuities. If the client purchases a variable annuity that is part of the program, the client will receive a prospectus and should rely solely on the disclosure contained in the prospectus with respect to the terms and conditions of the variable annuity. Client should also be aware that certain riders purchased with a variable annuity may limit the investment options and the ability to manage the subaccounts. • Margin Accounts. Client should be aware that margin borrowing involves additional risks. Margin borrowing will result in an increased gainif the value of the securities in the account goes up but will result in increased losses if the value of the securities in the account goes down. The custodian, acting as the client’s creditor, will have the authority to liquidate all or part of the account to repay any portion of the margin loan, even if the timing would be disadvantageous to the client. For performance illustration purposes, the margin interest charge will be treated as a withdrawal and will, therefore, not negatively impact the performance figures reflected on the quarterly advisory reports. WCG Financial Advisors may allocate client investable assets within one or more of the following proprietary investment strategies: Stock • The Strategic objective is a long-term focus on performance through full market cycles seeking competitive risk- adjusted returns. Active strategies focus on individual equities and may include ETFs and mutual funds. Stock Gender • The Strategic objective is a long-term focus on performance through full market cycles seeking competitive risk- adjusted returns. Active strategies focus on individual equities and may include ETFs and mutual funds. These models are also screened for gender lens factors and social responsibility, corporate governance, and environmental factors. Stock Select • The strategic objective is a long-term focus on performance through full market cycles seeking competitive risk- adjusted returns. Active strategies focus on individual equities and may include ETFs and mutual funds. These models are also screened for social responsibility, corporate governance, and environmental factors. Tactical • The strategic objective is to participate with the market during normal environments and to tactically reduce risk during volatile environments. The strategy employs four signals for two asset classes that will signal to raise cash when appropriate. The equities in the models are diversified across all market capitalizations and styles. Tactical WLS • The strategic objective is to participate with the market during normal environments and to tactically reduce risk during volatile environments. The strategy employs four signals for two asset classes that will signal to raise cash when appropriate. The equities in the models are only diversified via the S&P 500. Tactical High Yield • Thestrategic objective is to participate in the highyieldmarketduring normal environments andto tactically reduce risk during volatile environments. The strategy employs a trend following signal and will shift to cash when appropriate. The model will only hold high yield bond ETFs or ultra-short fixed income and cash-like ETFs. 17  Stock ETF • The strategic objective is long-term focus on performance through full market cycles seeking competitive risk- adjusted returns. Active and passive strategies including individual stocks, mutual funds, and ETFs are utilized for this portfolio. Income • The strategic objective is long-term focus on performance through full market cycles seeking competitive risk- adjusted returns. Active and passive strategies including individual stocks, mutual funds, and ETFs are utilized for this portfolio. This model focuses primarily on equity income and interest income. MS Value • This is an aggressive growth model that focuses on large stocks that are believed to be undervalued and have a competitive advantage compared to other stocks. MS Growth • This is an aggressive growth model that focuses on large stocks that are experienced strong growth and are believed to be reasonably priced. MS Dividend • This is an aggressive growth model that focuses on large stocks that are paying an above average dividend yield and are believed to be reasonably priced. ETF • The Strategic objective is a long-term focus on performance through full market cycles seeking competitive low cost passive ETFs with actively managed ETFs. When risk- adjusted returns. These models blend appropriate, mutual funds may also be used. ETF Select • The strategic objective is a long-term focus on performance through full market cycles seeking competitive risk- adjusted returns. These models blend low cost passive ETFs with actively managed ETFs. When appropriate, mutual funds may also be used. The funds in the model may also be screened for social responsibility, corporate governance, and environmental factors. High Impact Portfolios (HIP) • The strategic objective is a long-term focus on performance through full market cycles seeking competitive risk- adjusted returns. Actively managed mutual funds that are involved at the company level in proxy voting, engagement, and high impact initiatives may be used in these models. The primary goal of these models is adherence to ESG standards. We may also hold individual stocks and ETFs that are screened for social responsibility, corporate governance, and environmental factors. • Liquid Alternatives Bolt-on (LAB) The strategic objective is to reduce drawdowns and improve diversification when attaching this model to another model. This strategy uses both liquid mutual funds and ETFs in asset classes or strategies that are often not found in other portfolios. These include hedged investments, managed futures, listed infrastructure, market neutral and long/short strategies, gold, and cryptocurrencies. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. Investing in securities involves the risk of loss that clients should be prepared to bear. For more information on Risks, please refer to the WCG Form ADV Part 2A Brochure, Item 8 Methods of Analysis, Investment Strategies, and Risk of Loss. 18  Voting Client Securities WCG does not accept authority to vote client securities. Clients retain the right to vote for all proxies that are solicited for securities held in the account. Clients will receive proxies or other solicitations from the custodianof assets. If clients have questions regarding the solicitation, they should contact the Advisor or the contact person that the issuer identifies in the proxy materials. In addition, WCG does not accept authority to take action with respect to legal proceedings relating to securities held in the account. Item 7: Client Information Provided to Portfolio Managers In WCG Wrap Accounts, the IAR is responsible for account management; there is no separate portfolio manager involved. The IAR obtains the necessary financial data from the client and assists the client in setting an appropriate investment objective for the account. The IAR obtains this information by having the client complete an advisory agreement and other documentation. Clients are encouraged to contact the Advisor if there have been any changes in the client’s financial situation or investment objectives or if they wish to impose any reasonable restrictions on the management of the account or reasonably modify existing restrictions. Client should be aware that the investment objective selected for the program is an overall objective for the entire account and may be inconsistent with a particular holding and the account’s performance at any time. Client should further be aware that achievement of the stated investment objective is a long-term goal for the account. WCG's policy requires an annual client meeting (one review every 12 months) to determine if there have been any changes in the client's financial situation, investment objectives, or restrictions. In addition, the meeting should incorporate the account performance, appropriateness of the account, and any other information determined pertinent to the client's situation. The annual meeting may occur by phone, in person, via e-mail, or video conference and documentation will be maintained to evidence that for example the following topics were reviewed: Investment Objective and Goals • Client’s financial status • Risk Tolerance • Time Horizon • • Asset Allocation and/or Account Holdings Item 8: Client Contact with Portfolio Managers Client should contact WCG at any time with questions regarding the program account. Item 9: Additional Information Disciplinary Information Registered investment advisors are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of an advisory firm or the integrity of a firm’s management. Any such disciplinary information for WCG and its Investment Advisor Representatives would be provided herein and is publicly accessible by selecting the Investment Adviser Search option at http://www.adviserinfo.sec.gov. There are no legal or disciplinary events to disclose. 19  Other Financial Industry Activities and Affiliations Investment Adviser Representatives may also be Registered Representatives of LPL Financial, an unaffiliated SEC registered and FINRA/SIPC member broker/dealer. Clients may choose to engage a registered investment adviser in their capacity as a Registered Representative of the unaffiliated LPL Financial broker/dealer to implement investment recommendations on a commission basis. Please refer to Item 12 for a discussion of the benefits the Adviser may receive from LPL Financial and the conflicts of interest associated with receipt of such benefits. Representatives of our firm may also be insurance agents/brokers. They may offer insurance products and receive customary fees as a result of insurance sales. A conflict of interest arises as these insurance sales create an incentive to recommend products based on what the compensation advisor and/or our supervised persons may earn and may not necessarily be in the best interests of the client. Such potential conflicts of interest are subject to review by the Chief Compliance Officer. Neither WCG Wealth Advisors, LLC nor any of the management persons are registered or have a registration pending to register as a futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of the foregoing entities. IARs are permitted to engage in certain approved activities other than the provision of advisory services through WCG, and in certain cases, an IAR could receive greater compensation through the outside business than through WCG. For example, an IAR could also be an accountant, real estate agent, tax preparer, or lawyer. To the extent that these IARs provide such services all such services shall be performed by those IARs in their individual professional capacities, independent of WCG, for which services WCG shall not receive any portion of the fees charged by the IAR (referral or otherwise). It is expected that these IARs, solely incidental to their activities, may recommend WCG’s services to certain of their clients. No client of WCG is under any obligation to use the services of these IARs. The Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding the above conflict of interest and if you engage with an IAR for services separate from WCG, you may wish to discuss with him or her any questions you have about the compensation he or she receives from the engagement. WCG Wealth Advisors, LLC may recommend and select independent, third-party money managers in addition to the third-party managers offered through LPL Financial to manage all or a portion of a client’s account. It should be noted that the total fees incurred by clients when utilizing third-party managers will include both management fees payable to the third-party managers for their services as well as the fees payable to WCG Wealth Advisors, LLC for their investment advisory services. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading WCG Wealth Advisors, LLC maintains a Code of Ethics, which serves to establish a standard of business conduct for all employees that are based upon fundamental principles of openness, integrity, honesty, and trust. The Code of Ethics includes guidelines regarding personal securities transactions of its employees and Investment Adviser Representatives. WCG’s Code of Ethics permits employees and Investment Adviser Representatives or related persons to invest for their ownpersonal accounts in the same or different securities that an IAR may purchase for clients in program accounts. This presents a potential conflict of interest because trading by an employee or an IAR in their personal securities account in the same or different security onor about the same time as trading by a client couldpotentially disadvantage the client. WCG Wealth Advisors, LLC addresses this conflict of interest by requiring in its Code of Ethics that employees and IARs report certain personal securities transactions and holdings to the Chief Compliance Officer for review. 20  An Investment Adviser Representative is considered a fiduciary. 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 always. We have a fiduciary duty to all clients. Our fiduciary duty is considered the core underlying principle for our Code of Ethics which also includes Insider Trading and Personal Securities Transactions Policies and Procedures. We always require all our supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws. Upon employment or affiliation and at least annually thereafter, all supervised persons will sign an acknowledgment that they have read, understand, and agree to comply with our Code of Ethics. Our firm and 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. This disclosure is provided to give all clients a summary of our Code of Ethics. However, if a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. WCG and its associated persons may buy or sell the same securities as clients at the same time which can create a conflict of interest. In order to mitigate conflicts of interest, such as frontrunning, no less than quarterly, personal holdings are reviewed of its affiliated persons. These reviews ensure that the personal trading of affiliated persons does not disadvantage Clients of WCG. Neither WCG Wealth Advisors, LLC nor a related person recommends to clients or buys or sells for client accounts, or securities in which you or a related person has a material financial interest. Review of Accounts For those clients to whom WCG provides investment advisory services, account reviews are conducted at least annually by its IARs. All investment advisory clients are advised that it remains their responsibility to advise their IAR of any changes in his/her/its financial situation, investment objectives, and/or risk tolerance. All clients (in person, via virtual meeting, or by telephone) are encouraged to discuss and review all such changes with their IAR on an annual basis. Clients who do not respond to requests to meet will be sent a communication via mail or email to help them understand their current financial position and assist their IAR in the continued management of the account(s). IARs can or will conduct account reviews on an other-than-periodic basis upon the occurrence of a triggering event, such as a change in a client's financial situation, investment objectives, risk tolerance, market corrections, and client request. As mentioned previously, WCG has a dedicated Financial Planning department (“ARC”) that generates financial plans based on the client's goals and objectives that have been discussed with the WCG Financial Advisor. ARC or financial planners on WCG financial advisor teams prepare the financial plans with review by ARC/ WCG Financial Advisor before the presentation of the plan to the client. Financial planning clients do not receive reviews of their written plans unless they take action to schedule a financial consultation with their IAR. WCG does not provide ongoing services to Comprehensive Financial Planning or Hourly Consulting clients unless they separately contract with WCG for a post-financial plan meeting or an update to their initial written financial plan. Retirement Plan Consulting clients receive reviews of their pension plans for the duration of the pension consulting service. IARs also provide ongoing services to pension consulting clients where we meet with such clients upon their request to discuss changes to their circumstances and resulting updates to their plans. Clients are provided, at least quarterly, with written transaction confirmation notices and regular written summary account statements directly from the broker-dealer/custodian and/or program sponsor for the client accounts. WCG Wealth Advisors, LLC may also provide a written periodic report summarizing account activity and performance. 21  Client Referrals and Other Compensation WCG receives an economic benefit from LPL Financial in reimbursement for marketing-related expenses. Please see the detailed discussion of the categories of marketing-related expenses and potential conflicts of interest in Item 12 Brokerage Practices. WCG and its employees may receive additional compensation from product sponsors. However, such compensation may not be tied to the sale of any products. Compensation may include items such as gifts consistent with firm policy, occasional meals or entertainment (e.g, sporting events), and reimbursements related to educational meetings with IARs, client workshops, marketing events, or advertising initiatives, including services used to identify prospective clients. Product sponsors may also pay for or reimburse WCG Wealth Advisors, LLC for costs associated with education or training events attended by its employees and IARs, as well as firm-sponsored conferences and events. WCG Insurance, LLC (an affiliated entity) is a licensed insurance agency, and in such capacity may offer for sale, insurance-related products on a commission basis, including the sale of such products to investment advisory clients of WCG. WCG Financial Advisors providing advice may be licensed insurance agents. Normal commissions from insurance products are earned and paid by insurance companies to WCG Financial Advisors when such products are placed directly with their clients. Insurance products offered through various insurance vendors are often recommended to clients of WCG to minimize clients’ exposure to identified risks. Although clients are under no obligation to purchase insurance products or utilize the companies recommended by WCG, clients often do purchase such products when the needs arise. For clients of WCG who do purchase such products, causing commissions or recurring revenue to be generated, such commissions or recurring revenue are paid to the WCG Financial Advisors. There are no other economic benefits received from non-clients in connection with providing investment advice. WCG Wealth Advisors, LLC may receive referral fees from other third-party managers when we refer clients. Thus, we have a conflict of interest in our decision to recommend a third-party manager that pays WCG Wealth Advisors, LLC a referral fee. At all times, WCG Wealth Advisors, LLC will act in the best interest of the client when recommending a third-party manager. When a client is referred to a third-party manager by us, we will provide the client with a copy of the third-party managers Form ADVPart 2 Disclosure Brochure, if WCG is anunaffiliated registered investment adviser firm, as required by the Investment Advisers Act of 1940. The referral agreements between WCG Wealth Advisors, LLC, and any third-party manager we refer a client to will not result in any charges to clients in addition to the normal level of advisory fees charged. WCG Wealth Advisors, LLC (“WCG”) may enter into written agreements with third parties (“Promoters”) to pay a flat fee or a percentage of advisory fees for client referrals in the future. Such arrangements create a conflict of interest, as Promoters would have a financial incentive to recommend WCG. Any such arrangements will be structured to comply with the SEC Marketing Rule (Rule 206(4)-1), including requirements that Promoters provide prospective clients with written disclosure describing their relationship with WCG and the compensation received. WCG will maintain written agreements with Promoters and implement reasonable oversight of such arrangements. Clients will not pay higher advisory fees as a result of these arrangements unless otherwise disclosed. LPL Financial WCG and/or its Dually Registered Persons are incented to join and remain affiliated with LPL Financial and to recommend that clients establish accounts with LPL Financial through the provision of Transition Assistance (discussed 22  in Item 12 above). LPL also provides other compensation to WCG and its Dually Registered Persons, including but not limited to, bonus payments, repayable and forgivable loans, stock awards, and other benefits. The receipt of any such compensation creates a financial incentive for your representative to recommend LPL Financial ascustodianfor the assets in your advisory account. We encourage you to discuss any such conflicts of interest with your representative before making a decision to the custody of your assets at LPL Financial. The Advisor receives asset-based advisory fees as a result of its clients’ participation in the LPL-sponsored programs. The amount of these fees can be more or less than what WCG would receive if a client participated in other LPL programs or paid separately for investment advice, brokerage, and other client services. Additionally, WCG or one or more of its IARs will receive all or a portion of certain third-party fees that are paid by program clients. Therefore, WCG has a financial incentive when recommending that its clients open an account under the LPL- managed account program. As part of WCG’s fiduciary duty to its clients, WCG and its IARs will endeavor at all times to put the interest of the clients first and will only make recommendations when they are reasonably believed to be in the best interests of the client. Please refer to Item 5 of this Brochure for further details regarding fees. Charles Schwab & Co., Inc.- Institutional In addition, WCG receives an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisers whose clients maintain their accounts at Schwab. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12- Brokerage Practices). The availability to WCG of Schwab's products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. As disclosed under the Fees and Compensation section in this brochure, persons providing investment advice on behalf of our firm are licensed insurance agents. For informationon the conflicts of interest this presents, and how we address these conflicts, refer to the Fees and Compensation section. Refer to the Brokerage Practices section above for disclosures on research and other benefits we may receive resulting from our relationship with your account custodian. Financial Information WCG Wealth Advisors, LLC does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. There are no financial conditions that are reasonably likely to impair WCG’s ability to meet contractual commitments to clients. At no time has WCG Wealth Advisors, LLC been the subject of a bankruptcy petition. 23