Tingey Financial Group Inc.

Regulatory Disclosures and Firm Brochure Part 2A of ADV / Date: 126-February 2026 Tingey Financial Group, inc. 3003 Kempner Road Salt Lake City, UT 84109 Website: www.tingeyfinancial.com (website to become active sometime during first half of 2025) Principal Alan B. Tingey, CFA 3003 Kempner Road Salt Lake City, UT 84109 Email: alan@tingeyfinancial.com Name of Advisory Firm Tingey Financial Group, Inc. (TFG) This brochure provides information about the qualifications and business practices of Tingey Financial Group, Inc. If you have any questions about the contents of this brochure, please contact us at [801-718-9714 and/or alan@tingeyfinancial.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. Registration as a “Registered Investment Advisor” or “RIA” does not imply a certain level of skill or training. The IARD number for Tingey Financial Group, Inc. is #334198. Material Changes from Previous Version: • Key personnel added: o Stephen Q Spencer, CFA, as Senior Portfolio Manager o Gregory S. Tingey, CFP, as Director of Financial Planning Financial planning services were added • • Assets under management have surpassed the $100 million threshold, which moves the firm from state to SEC registration Table of Contents Item Number 1 2 3 4 5 6 7 8 9 10 11 Page 1 1 1 1 2 3 3 3 3 4 5 12 13 14 15 16 17 18 19 Item Cover Page Material Change from Previous Version Table of Contents Advisory Business Fees and Compensation Performance Based Fees and Side-by-Side Management Types of Clients Method of Analysis, Investment Strategies and Risk of Loss Disciplinary Information Other Financial Industry Activities and Affiliations Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Brokerage Practices Review of Accounts Client Referrals and Other Compensation Custody Investment Discretion Voting Client Securities Financial Information Requirements for Registered Advisors 6 7 7 7 8 8 9 9 Advisory Business Tingey Financial Group, Inc. (TFG) was founded on November 12, 2024, and is a fee-based investment advisor that manages discretionary or non-discretionary assets. It specializes in personalized portfolio management for individuals and institutions that allow its clients to achieve individual investment goals by applying personal, individual investment objectives. The principal owner is Alan B. Tingey, CFA, who owns 100% of the firm. Generally, investment advice to clients involves discretionary management of portfolios of publicly traded securities based on its own proprietary research; however, on occasion clients may Version Date: 10 February 2025 1  make requests for other advice involving cash flow analysis or financial planning, etc. for which the Adviser does not charge additional management fees. The advisor sends quarterly newsletters or periodic market commentaries to its clients at no additional charge for informational purposes. Annual educational meetings with clients may be held also without additional charge. Because of its commitment to a personalized approach to investing, TFG may, from time to time, allow clients to impose restrictions on Adviser from purchasing certain stocks, bonds or other financial assets due to tax implications, personal preferences or other matters. TFG also intends to provide advice to trustees and participants of non-discretionary portfolios such as 401(k) plans that require the recommendation of mutual funds managed by other managers. Service and Sequence When a potential client contacts or is contacted by TFG, there is a sequence of services to fulfill TFG’s fiduciary responsibility to know the client and manage the portfolio in line with the client’s objectives. The sequence involves the following steps. First, TFG conducts an initial consultation to get to know the prospective client and allow the prospective client to become familiar with TFG. This allows TFG to gather information about the client’s investment objectives, risk tolerance, stage of life and other factors that may affect the management of the client’s portfolio. Should a client want or need a comprehensive financial plan, TFG will work with the client to create that plan, either in conjunction with the initial consulation or anytime thereafter, as directed by the client. During the consultation, if agreements on terms of service and compensation are met, TFG and the client will execute a management agreement along with an objective statement, and an account is established with a qualified custodian to receive client assets. During the initial consultation, TFG will provide a copy of the ADV Part 2 and Supplement providing disclosure of TFG’s general business and fee structure. A Client Relationship Summary (CRS) is also provided. Basic Management Services TFG provides portfolio management services primarily to individuals but also to businesses, foundations, unions and other institutions. Of primary importance is TFG’s focus on risk tolerance to establish an investment strategy tailored to the individual client that meets the appropriate investment guidelines. TFG allows the client to select one of three categories of objectives: Growth, Balanced and Income, each of which offers asset allocation ranges that guide TFG’s investment decisions. TFG views each client individually and seeks to manage each portfolio on a personal and individual level. Growth portfolios are primarily mostly invested in stocks. Balanced portfolios offer a blend of stocks and fixed income. Income portfolios are primarily invested in fixed income assets. TFG incorporates a diversified, low-turnover investment style wherein fixed income is generally held to maturity. Through the management agreement executed up front, clients generally give TFG discretion over all decision-making regarding investment strategy; however, TFG strives to implement an investment strategy that corresponds with the objective of the client. From time to time, TFG may offer advisory services to 401(k) plans or other qualified retirement plans that may include advice regarding mutual funds for plan participants. However, this type of investment advice does not involve discretion on the part of TFG and only involves recommendations to trustees or participants that may or may not be used to make their respective decisions. While the ultimate responsibility of fund selection in 401(k) plans rests with the plan trustees, the trustees may rely upon the advice of TFG to make plan decisions. TFG will also offer advice to plan participants from time to time regarding their personal investment decisions in such plans. Investment Committee The investment committee consists of Alan B. Tingey, CFA, Stephen Q Spencer, CFA, and Gregory S. Tingey, CFP Each of the investment committee members are portfolio managers and investment decision makers. From time to time, other internal or external individuals may be selected to provide research support or collaborate on prudent investment strategy. Thisinvestment committee only provides research support for client portfolios and does not provide investment advice directly to clients. Client Communication TFG is committed to healthy, consistent and effective communication with its clients on matters pertaining to their personal portfolios. Basic communication efforts fall into the following categories: Statements and newsletters, periodic market commentaries, personal performance reviews, educational seminars and phone calls. In addition to the monthly statements sent by the custodian, TFG will send statements of accounts at quarter-end along with a quarterly newsletter addressing matters pertaining to the capital markets. Additionally, periodic market commentaries sent by email address material market developments as determined by TFG. Periodic personal performance reviews are made at the request and discretion of the client. Clients of TFG have the right to call the portfolio manager at any time to ask questions or discuss investment strategy. Other Tingey Financial Group, Inc. (TFG) was founded on November 12, 2024, and is a fee-based investment advisor currently managing discretionary or non-discretionary assets. It participates in no wrap fee programs. TFG may from time to time be invited to provide other types of consulting services such as acting as an expert witness, or other general or financial consulting. Version Date: 10 February 2025 2  Fees and Compensation TFG offers its management services for a fee based on assets under management. Fees are billed quarterly with no minimum fee. Client fees for assets under management are assessed and paid at the beginning of each quarter. The quarterly percentage fee (calculated as ¼ of the annual fee percentage) is applied against the fair market value of the account at the end of the previous quarter. Fees are billed directly to the custodian unless the client has requested a separate invoice and payment mechanism. Fees for management services may be charged intra-quarter when new assets enter the account. Conversely, fees may not be reimbursed for assets that leave a portfolio during the quarter if it does not involve termination of services. Pre- paid fees for portfolios that terminate TFG advisory services during the quarter (with at least 2 days’ written notice) will be refunded pro rata by a returned check. Under circumstances unique to the client, investment management fees may be negotiable, such as if the portfolio is part of a larger household of portfolios managed by the Adviser, or if the client has requested that certain assets not be altered within the portfolio. Individual requests are reviewed on a case-by-case basis and may be accepted or denied and must be agreeable to both parties. Any decision to use a negotiated fee rather than the company standard fee must be affirmed in writing. Annual Fee Percentage 1.10% on the first $1,000,000 0.95% on the next $2,000,000 0.85% on the next $2,000,000 0.75% on the next $5,000,000 0.50% on assets > $10,000,000 Quarterly Fee Percentage 0.275% on the first $1,000,000 0.2375% on the next $2,000,000 0.2125% on the next $2,000,000 0.1875% on the next $5,000,000 0.125% on assets > $10,000,000 The above blended fee schedule represents a conflict of interest for the Adviser in that the blended fee schedule may result in higher fees for the Adviser than are collected by advisers who use a breakpoint schedule for the same or similar services. Fees for general consulting services other than the basic investment management services described above, including expert witness services, may be billed at a rate of $295.00 per hour. In such cases, the client’s project will be defined up front, and payment will be by invoice and check unless the client requests and authorizes a direct payment from the client’s account. Other than the fees stated above, TFG will not charge additional fees for its management services. The client may incur brokerage or other transactional costs. None of the supervised people accept compensation for the sale of securities, investment products, or as a placement agent for limited partnership interests. Additional information is provided under the paragraph entitled “Brokerage.” Performance Based Fees and Side-by-Side Management TFG does not charge fees based on performance nor does it participate in any wrap fee program. It also does not compensate its employees by performance-based fees. Types of Clients TFG may provide investment advice to the following types of entities: Individuals and institutions, including Trusts, Foundations, Charitable Organizations, Corporations, Partnerships, Unions, Pension and Profit-Sharing Plans, 401(k) and other qualified retirement plans. The adviser has no formal conditions for opening or maintaining an account. Methods of Analysis and Investment Strategies Tingey Financial Group offers investment advice to individuals and institutions based on the following disciplines in the equity and fixed income capital markets. Specifically, TFG may offer advice on securities such as, but not limited to: stocks; warrants; government, corporate or municipal debt or fixed income securities; mutual fund shares; exchange traded funds (ETFs); and real estate investment trusts. Adviser does not use the categories of ETFs that carry higher risks as part of its portfolio construction. These securities carry risks and uncertainties that can cause the loss of all or a portion of a client’s investment portfolio. Stocks, warrants, mutual fund shares, ETFs and real estate investment trusts are subject to the general risks of the strength of the economy, equity market fluctuations and risks inherent in the issuer of the security such as debt levels, market positions, product acceptance in the marketplace, management expertise, etc. Government, corporate or municipal debt or fixed income securities are subject to market swings brought on by interest rate movements as well as the financial strength and credit rating of the individual issuer. Equity Investment Philosophy and Discipline: Tingey Financial Group incorporates a fundamental, value-oriented investment philosophy and seeks to uncover the intrinsic value of a security based on general market factors or those related directly to the security, such as revenues, earnings, cash flows, dividend yields, balance sheet strength, liquidity, market position, management commitment to shareholders, etc. While fundamental analysis is the basis for TFG’s research and decision-making, TFG may also use technical analysis, cyclical analysis, and charting analysis to augment its fundamental efforts. Nevertheless, despite the commitment to fundamental Version Date: 10 February 2025 3  analysis and other analytical tools, any investment in securities carries with it material risks and uncertainties that could cause investors to lose all or a portion of their principal investment. TFG seeks long-term growth opportunities in what it views as high-quality, undervalued assets that offer proven track records. As such, TFG’s lower turnover investment philosophy lends itself to longer-time horizons that seek long-term, rather than short- term, capital gains in growing markets. TFG seeks to invest in companies that are “value-priced” and offer opportunity over an intermediate-term horizon; thus, time is an important factor to realize a company’s value. Liquidity is a fundamental underpinning at TFG. Investments focus on stocks, bonds and other assets that are highly liquid and can be converted quickly to cash and carry potential for growth of principal and interest. The cash portion of a client’s portfolio is invested in highly liquid money market instruments, high quality commercial paper and U.S. Treasury bills or repurchase agreements. Fixed Income Philosophy and Discipline TFG adopts a buy-and-hold strategy for fixed income securities with an attempt to minimize risk by focusing on credit quality and duration of portfolios. Liquidity is a major underpinning with an overall pursuit of investment grade credit quality, after-tax yield and a value orientation relative to “normal” yield spread relationships and inflation expectations. Fixed income holdings are generally held to maturity to keep transaction costs low and to allow the full yield to be achieved. With our dedication to attractive credit quality, low turnover and penchant to avoid material duration risk, we attempt to reduce risk and enhance total return in fixed income portfolios. Similar fixed income strategies are implemented throughout the breadth of investment objectives and can be seen in balanced and fixed income portfolios alike. Investment decisions involve fundamental analysis of the issuer along with analysis of general market risk, interest rate risk, re-investment risk, ill-liquidity risk and the risk of capital loss. Third-party rating agency reports are resources for our fundamental analysis of fixed income. Most portfolios will have a portion of the asset allocation in fixed income securities, which will generally be invested in liquid, investment-grade individual securities. Just as in equity strategy, fixed income strategy involves diversification of risk, especially in non-US Gov’t issues. The securities may include any or all of the following: US Treasury securities, US Government Agency securities, corporate and municipal bonds, mortgage-backed securities or preferred stock. Cash is invested in highly liquid money market funds, including FDIC sweep vehicles, high quality commercial paper and US Treasury Bills or repurchase agreements. With fixed income security issues that are held for multiple years, the rating may drop below investment-grade standards. At that point, TFG may decide to liquidate the position or to hold the position depending on the fundamental variables in place. From time to time, TFG may purchase non-investment-grade bonds if it senses strong fundamental value. In each situation, TFG would purchase these bonds after analysis and the conclusion that such bonds were likely to offer positive and attractive returns. TFG may from time-to-time purchase bonds with a split rating among rating agencies. Despite the “best efforts” analysis by TFG, any investment in securities carries risk and uncertainty and investors may lose all or a portion of their investment. Performance Disclosure Investments in the capital markets are subject to risk and uncertainty and may result in loss of principal. Client portfolio results are subject to the effect of material market or economic conditions and results will be impacted in a positive or negative way based on those conditions regardless of security selection. Portfolio results are impacted by advisory fees, brokerage or other commissions, and any other expenses that a client may pay. Returns are determined by including the change in the price of a particular security and may be based on the reinvestment of dividends and other earnings. Any performance comparison to any benchmark may or may not be of value in evaluating portfolio performance. Benchmarks or indices vary in composition and risk parameters such as volatility and may be materially different from that of the client’s portfolio. Equity portfolios are managed with a view toward income generation and capital appreciation. Equity securities may or may not pay dividends. Analysis of model portfolios, if any, and benchmark results can be of limited usefulness, particularly the fact that such results may not represent actual trading and may not reflect the impact that material economic and market factors might have had on client portfolio decision-making. Important factors in client portfolio results may change materially during the evaluation period such as objectives, economic and capital market conditions, or investment. Past client portfolio results and any of the securities contained in, or the investment strategies followed with respect to, the model or client portfolio do not relate, or only partially relate, to the type of advisory services currently offered by the adviser. For example, an internal management tracking portfolio or past client portfolio may include some types of securities that the adviser no longer recommends for its clients. Past client results may relate to only a select group of portfolios. Other past client portfolio results may be materially different from results portrayed in the model or past client results. Despite the analysis performed by TFG, any investment in securities carries risk and uncertainty and investors may lose all or a portion of their principal investment. Disciplinary Information Version Date: 10 February 2025 4  Neither TFG nor its principal(s) has been subject to any lawsuits or professional disciplinary action. Other Financial Industry Activities and Affiliations Neither TFG nor its management is engaged in business as a broker-dealer, registered representative of a broker-dealer, futures commission merchant (FCM), commodity pool operator (CPO), a commodity trading advisor (CTA) or associated person of a FCM, CPO or CTA. Moreover, neither TFG nor its management has any affiliated relationship or arrangement with a broker-dealer, municipal securities dealer, government securities dealer, investment company, other pooled investment banking or thrift institution, accountant, accounting firm, insurance company, insurance agency, pension consultant, real estate broker, real estate dealer, or a sponsor or syndicator of limited partnerships. From time to time, TFG has given referrals to clients for professional accounting, legal or insurance services and has disclosed if the referral involved any family relationship. Accepting or rejecting the referral has been the client’s decision. TFG does not have any arrangements whereby it receives compensation for recommending third-party advisers to clients. Additional affiliations of Alan B. Tingey, CFA, and Ste;hen Q Spencer, CFA, are as follows: Alan B. Tingey, CFA • Current shareholder of Rich Broadcasting – a privately held media company with radio stations in the state of Idaho. • CFA Society of Salt Lake – the local society of CFA Institute, a global nonprofit member organization of financial analysts, portfolio managers and other investment professionals. • Member, 2101 Partners, LLC – owns office building serving as residence for Tingey Advisors, Inc. Stephen Q Spencer, CFA • • CFA Society of Salt Lake – the local society of CFA Institute, a global nonprofit member organization of financial analysts, portfolio managers and other investment professionals Form 1099 afilliation with ACT Capital Advisors – a privately held middle market investment banking firm headquartered in Mercer Island, WA Gregory S. Tingey, CFP • No additional affiliations Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A fundamental policy of our business is to avoid conflicts of interest between Control Persons and our clients. Tingey Financial Group, Inc. has adopted a Code of Ethics that promotes the fiduciary duty and standard of care by its owners, officers, directors, as well as any employee of TFG who is involved in providing such services – whether by way of security analysis, recommendation, execution of trading orders, portfolio management or otherwise (hereafter “Covered Persons”). It also promotes confidentiality of information, suitability of investments, personal trading, and disclosure of conflicts of interest. A copy of TFG’s Code of Ethics is available upon request for any client or prospective client. One of the practices that presents a potential conflict of interest is that of trading in the securities that are being purchased or sold, or considered for purchase or sale, for clients’ portfolios by Covered Persons for accounts in which they have a beneficial ownership interest or which they control. The Investment Advisors Act of 1940 (“Advisors Act”) and other federal and state securities laws and rules generally prohibit fraudulent, deceptive, or manipulative trading by persons affiliated with investment advisers with respect to securities held, to be acquired or under consideration for purchase or sale by the advisory clients. This prohibition extends to trading in furtherance of personal interests to the detriment of TFG and/or its clients as well as any attempt to benefit from the market impact of their anticipated or actual transactions. The Securities and Exchange Commission (“SEC”) regulations require the adoption of procedures designed to prevent such fraudulent conduct. As part of the code of ethics adopted by TFG and agreed to by all Control Persons, TFG or its owners and employees may buy or sell securities which the firm has purchased for its clients. Purchases and sells of assets in any Tingey Financial Group profit sharing account, other TFG qualified plan accounts, or other family relationship accounts of the principals of TFG with active management agreements, that are not employees or principals, may be done at the same time as purchases and sells for other Version Date: 10 February 2025 5  managed accounts; however, we attempt to treat all participants in a trade equally with respect to the outcome of the transaction. Adviser or related party may from time to time recommend to clients securities in which Adviser has a material financial interest. However, personal transactions initiated by owners and employees of Tingey Financial Group must be pre-approved by the Chief Compliance Officer of the firm or one of the principals of the firm prior to the execution of that transaction. As it pertains to personal, individual trades (other than those for any Tingey Financial Group Profit Sharing portfolio or other TFG qualified plans; or other family relationship accounts that are not employees or principals which are included in trades simultaneously with other clients), after receiving approval to perform the transaction, the individual signs a “Personal Trading Authorization Form” stating the following: “I confirm that: (a) to my knowledge and belief, there presently is no outstanding order to purchase or sell the above-listed security for TFG-managed account or portfolio; (b) there is no outstanding oral or written communication with respect to that security that has not been acted upon or rejected; (c) I have no present intention to purchase or sell that security for a TFG client and am not aware that such security is “being considered” by anyone with discretionary authority over trading on behalf of a TFG client and (d) I am not in possession of material non-public information with respect to the security described above nor am I making the transaction described above on the basis of inside information. I further confirm that the above conditions have existed during this entire business day.” Personal transactions involving securities that are also recommended to clients will not occur on the same day as client transactions and only after the representations on the Personal Trading Authorization Form referred to above. Allowable Trades in Proprietary Accounts Because TFG, its owners and employees buy and sell some of the same securities recommended to advisory clients from time to time, it may create a conflict of interest; however, TFG attempts to minimize that conflict of interest by instituting policies that give clients priority over personal transactions of TFG, its owners and employees. TFG acknowledges that a potential conflict of interest exists for preferential treatment for proprietary accounts including family member’s accounts of TFG Principals, since beneficiaries of these accounts may be TFG control or access persons. TFG further acknowledges that if preferential treatment were given it could have a negative impact on clients’ accounts. The TFG code of ethics policy allows for trades in these accounts to be made without the personal trading authorization (PTA) procedures required of personal trades of TFG control or access persons. This allowance is subject to the following conditions: 1) proper disclosure in TFG’s ADV acknowledging that a potential conflict of interest exists with these accounts; 2) the account owner must have signed TFG’s investment management agreement; 3) the accounts are being managed as per written investment guidelines. Such trades are allowable without completing a PTA form. To ensure that proprietary accounts do not receive preferential treatment, TFG will undergo periodic internal audits as part of TFG’s risk assessment process to determine that the proprietary accounts do not or did not receive preferential treatment with respect to trade executions. Furthermore, the TFG code of ethics allows for trades in accounts owned by certain control persons or related parties to be made without the PTA procedures required of individual trades of TFG control or access persons. This allowance is subject to the following conditions: 1) proper disclosure in TFG’s ADV acknowledging that a potential conflict of interest exists with these accounts; 2) account managed by an Investment Advisory Representative (IAR) other than the owner of the account; 3) the owner must have signed TFG’s investment management agreements; 4) the accounts are being managed as per written investment guidelines. Such trades are allowable without completing a PTA form. To ensure that proprietary accounts do not receive preferential treatment, TFG will undergo periodic audits as part of TFG’s risk assessment process to determine that the proprietary accounts do not or did not receive preferential treatment with respect to trade executions. Brokerage Practices Tingey Financial Group will affect trades through the custodian selected by the client if the custodian is also a broker-dealer. When discretion is given to TFG to make trades away from the client-designated custodian that settle at said custodian, TFG will select established brokers who can execute trades in a timely, effective, and fair manner. Commission rates paid to brokers are believed to be reasonable for the services provided. TFG does not enter “soft dollar” arrangements to receive certain investment products, investment research or investment services. Any broker used to affect transactions will be as approved by the qualified custodian chosen by the client. All clients benefit from the products, research and services obtained from soft dollar commissions regardless of whether they pay for them through commissioned-based transactions. Commissions generated to pay for soft dollar items are generally done at a commission rate, as negotiated by TFG on a trade-by-trade basis (a higher number of shares to be traded may result in lower agreed upon per share commission; conversely, a lower number of shares to be traded may result in higher agreed upon Version Date: 10 February 2025 6  per share commission). TFG believes that no clients are materially disadvantaged for trades done through a soft dollar arrangement. However, clients who use the custodial services of a brokerage firm, i.e. Charles Schwab, may not have trades which are executed through a “soft dollar” broker. Tingey Financial Group may refer brokers or trust companies to serve as custodians for the client's assets; however, the actual selection of a custodian rests with the client. TFG believes all clients benefit by maintaining multiple custodial options. From time to time, TFG may or may not use its discretionary authority over broker-dealers to purchase or sell an asset for the client outside of the client-selected custodian’s inventory with the directive that such trade will settle in the client’s account of the client-selected custodian. TFG may also explain that should the client choose to use a broker as a custodian for their assets that the broker/custodian will generally serve as the broker of choice for transactions within their portfolio. Should a client choose to select his own broker, the commission charged by the client's broker may be more or less than that which brokers that are working with TFG would charge. On occasion, a client may contact his/her broker directly to place a trade or ask TFG to place a trade on his/her behalf through his/her own custodian. As stated above, the client chooses his/her custodian which may have a bearing on which broker-dealer is used to affect trades. After a client selects a custodian, the applicable broker will be selected after a review that verifies that said broker is acceptable to the custodian and has demonstrated competence and a reasonable and fair transactional cost structure. On occasion, TFG may engage in “block trading” which involves aggregating multiple accounts to participate in the purchase or sale of a security at one time. Such action allows multiple clients to receive the same price for a similar transaction and allows the portfolio manager to act in a timely manner. Block trades of sufficiently large quantity may or may not have a slightly detrimental effect on the transaction price realized by the individual client. Accounts are managed individually based upon each client’s stipulated investment guidelines, are reviewed individually, and may not be part of a “block trade” due to individual considerations. Review of Accounts Tingey Financial Group views management and review of client portfolios as an on-going process and part of the normal course of business, but at least quarterly, to ensure that portfolios are managed according to clients’ investment guidelines. Investment objectives include asset allocation ranges that allow the manager to work within a specified range of exposure. Portfolios are generally managed within those ranges; however, the ranges are intended to be guidelines and not mandatory barriers. From time to time, portfolios may be managed with asset exposures outside of the prescribed ranges. Additionally, if TFG manages multiple client portfolios within the same household, TFG may, from time to time, combine those portfolios together with respect to investment guideline ranges. Formal client reviews, including performance summaries, may be held from time to time based on the client’s desires. Informal reviews and client updates may also be done from time to time, in person, by email, telephone, or online, at the request of the client. TFG promotes an “open-door-policy” with its clients and is committed to the principle of client communication. Each client has a “lead” portfolio manager that is responsible for implementing a strategy consistent with the client’s investment objective and to be the direct interface with the client, including performance reviews. Any portfolio manager the firm may designate that is not assigned as the “lead” portfolio manager provides support for the lead manager in his absence. Internal Reviews As mentioned above, client portfolios are reviewed as a normal course of business. Internal reviews are conducted from time to time, to ensure that the position of the clients’ portfolio matches the clients’ stated investment guidelines. From time to time, certain capital market conditions or other conditions may exist that would allow portfolio managers to temporarily manage asset allocations outside the prescribed ranges. Additionally, portfolio managers may use investment committee meetings to discuss specific client-related investment matters along with the analysis of general market conditions and investment strategy. Client Reports and reviews Clients generally receive a statement of account from Tingey Financial Group at the end of each quarter in addition to monthly statements from their custodian. Additionally, TFG may deliver a quarterly newsletter containing a summary of the markets and general economic and financial information to the clients with their quarterly statement. Topical market commentaries are provided to clients from time to time. Formal reviews may be conducted at a time mutually agreed to by the client and TFG. Client Referrals and Other Compensation Tingey Financial Group does not compensate third parties for client referrals. However, to promote quality and attentive service to clients, Adviser may grant additional compensation (a portion of the normal client management fee) to employees (duly licensed as IARs to give investment advice) who manage client assets. Such “additional compensation” will not cause additional Version Date: 10 February 2025 7  cost or fee to the clients but will be paid out of the “normal and customary” fee agreed to by the client. Adviser does not compensate, directly or indirectly, any person (who is not a supervised person) for client referrals. Custody Rule 206(4)-2 of Section 206(4) of the Investment Advisers Act of 1940 otherwise known as “Custody Rule” is designed to protect client funds or securities from being lost, misused, or misappropriated. The Securities and Exchange Commission in their letter dated February 21, 2017 stated that “custody” of a client’s assets would include, “any arrangement… under which [an investment adviser is] authorized or permitted to withdraw client funds or securities maintained with a custodian upon [its] instruction to the custodian…” Clients who hire Tingey Financial Group place their investable assets with a large financial institution who acts as custodian and physically holds client assets. However, clients who hire TFG to manage their portfolio, may from time to time set up a standing letter of authorization with the custodian to facilitate the movement of money from the custodial account to another account that the client specifies in writing. Furthermore, the client may from time to time authorize Tingey Financial Group to initiate the movement of money through said standing letter of authorization via ACH transfer, check, or journal transfer, to an account prescribed by the client. Under the SEC’s interpretation of Rule 206(4)-2, this constitutes Tingey Financial Group having custody of those assets. Tingey Financial Group does not accept standing letters of authorization set up by client with the custodian with respect to first party or third-party wire transfers. Any wire transfer made from client account will require specific written instruction in a form acceptable to the custodian, by the client at the time of the wire transfer. In the event that the client sets up a standing letter of authorization for the movement of money via ACH transfer, check, or journal to another account, and gives Tingey Financial authorization to initiate those transactions, Tingey Financial will only act on the authorization if a client’s respective custodian certifies that it meets #1, #2, #3, #4, #5 and #7 of the following conditions -- Tingey Financial Group meets condition #6. 1. The client provides instructions to the qualified custodian, in writing, that includes the client’s 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. 2. The client authorizes Tingey Financial Group, 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. 3. The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization and provides a transfer of funds notice to the client promptly after each transfer. 4. The client can terminate or change the instruction to the clients qualified custodian. 5. Tingey Financial has no authority or ability to designate or change the identity of the third party, the address, or any 6. other information about the third party contained in the client’s instruction. Tingey Financial Group maintains records showing that the third party is not a related party of TFG or located at the same address as TFG. 7. The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Furthermore, Tingey Financial Group is deemed to have limited custody of client assets since it deducts management fees directly from client accounts as authorized by the client. TFG may refer brokers or trust companies to serve as custodians for the client's assets, but the actual selection of a custodian to hold assets rests with the client. In addition to the custodian’s monthly account statement sent directly to the client, TFG may send a statement on a quarterly basis. Clients should carefully review and compare the statements from the broker-dealer/custodian with those from Tingey Financial Group. Investment Discretion TFG accepts discretionary authority to manage securities accounts on behalf of clients. TFG will honor appropriate parameters established by the client at the time investment management services are agreed upon. Clients may place limitations on TFG’s discretionary authority in the purchase of individual securities, participating in specific industry sectors, asset allocations or other factors deemed important by the client. Clients may limit Adviser in areas such as tax planning or personal preferences regarding risk or types of securities. As an investment advisor, Tingey Financial Group will buy and sell securities in keeping with the client’s investment guidelines and also prudent industry practices. Once a client gives investment discretion to TFG, portfolio managers at TFG do not seek prior approval from the client when making investment decisions. Regular communication and reporting will occur which will allow clients to refine investment guidelines over time. Version Date: 10 February 2025 8  Voting Client Securities TFG accepts authority to vote client securities on behalf of the client unless the client retains that responsibility. By policy, Tingey Financial Group will generally vote in accordance with the suggestion(s) of the Board of Directors of the respective companies for which TFG is exercising its authority to vote the proxy. TFG will generally sell its investment position in a company should TFG disagree with the capability of existing management. Following the suggestion(s) of the Board of Directors will include, but is not limited to, such items as changes in corporate governance structures, adoption of amendments to compensation plans (including stock options), and matters involving social issues or corporate responsibility. Should TFG feel the need to vote against the Board of Director’s suggestion(s), TFG will note the exception explaining the reasoning behind a vote against the Board of Director’s suggestion(s). TFG recognizes that there may be material conflicts of interest between its interests and those of its clients, however, TFG policy and procedures strive to minimize those conflicts. If Adviser sees a conflict of interest between clients and TFG’s proxy voting responsibilities, Adviser will address it directly with the client. The client can direct his vote on a particular matter by contacting Adviser and requesting a specific vote action. Procedurally, TFG instructs the respective custodians to deliver all proxy voting information to TFG for which clients have given TFG that authority. TFG then reviews the proxy information and unless noted will vote in favor of the Board of Directors suggestion(s). Specific information concerning the date of the meeting, issues presented for vote by shareholders as well as the Board of Directors suggestion(s) can be accessed via the internet at www.sec.gov. Information can also generally be accessed by going directly to a company’s web site. Clients may obtain information directly from Adviser about how it voted their securities. Clients may obtain a copy of Adviser’s proxy voting policies and procedures upon request. Financial Information As stated in the Fees and Compensation section, Tingey Financial Group bills its fees on a quarterly basis in advance. TFG has no financial condition or obligation that would prevent it from meeting all contractual commitments to its clients, nor has TFG ever filed for bankruptcy. Requirements for Advisors Tingey Financial Group, Inc. is wholly owned by Alan B. Tingey, CFA (age 72) who serves as an officer and director. He directs the investment committee that determines general investment strategy. Other members of the investment committee may be selected from within the firm or outside the firm from time to time for the purpose of research, specific strategy implementation and communication. A description of Alan B. Tingey, CFA’s education and business background can be found on Page 1 of Tingey Financial Group’s ADV Part 2B Firm Brochure Supplement. Other Business of Tingey Financial Group. Whereas providing investment advice is TFG’s primary business, from time to time it may provide services that do not include direct investment advice. For example, TFG may periodically engage in general consulting services for firms or individuals, or a project requested by a client which may or may not involve investment advice. Fees Based on Performance Tingey Financial Group does not charge fees based on performance. Other Legal and Disciplinary Events Tingey Financial Group and/or its principals have not been involved in any legal or disciplinary events that would be material to the evaluation of the advisory business or the integrity of Alan B. Tingey, CFA. Neither TFG nor its principals have been the subject of a bankruptcy petition. Affiliation with Issuer of Securities Alan B. Tingey, CFA is currently a shareholder of Rich Broadcasting, a private company located in Salt Lake City, Utah. However, he has not introduced this security to any clients or potential clients. Historically, he has also been a shareholder and/or director of the now-defunct private companies Genisis Poly, ISYS Technologies and Amendment II, with which there is no current affiliation. Disclaimer: Version Date: 10 February 2025 9  This brochure provides information about the practices and qualifications of Tingey Financial Group, Inc. (TFG). 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. While TFG may refer to itself as a “Registered Investment Advisor” or “RIA,” clients or potential clients should be aware that the registration itself does not imply any level of skill, training or endorsement by regulatory authorities. If you have any questions about the content of this brochure, please contact us. Additional information about Tingey Financial Group, Inc. is available on the SEC’s website at www.adviserinfo.sec.gov (the CRD number for Tingey Financial Group, Inc. is 334198. Version Date: 10 February 2025 10