TRITON FINANCIAL GROUP, INC

Triton Financial Group, INC Form ADV Part 2A – Disclosure Brochure Effective: April 10, 2025 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Triton Financial Group, INC (“TFG” or the “Advisor”). If you have any questions about the contents of this Disclosure Brochure, please contact the Advisor at (405) 848-4646. TFG is a registered investment advisor with U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about TFG to assist you in determining whether to retain the Advisor. Additional information about TFG and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor firm name or CRD# 309294. Triton Financial Group, INC 14614 Bogert Parkway Oklahoma City, OK 73134 Phone: (405) 696-7140 Fax: 405-442-0400  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Personnel of CTFG. For convenience, the Advisor has combined these documents into a single disclosure document. TFG believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. TFG encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes The following material changes have been made to this Disclosure Brochure since the last filing and distribution to Clients: The firm has changed its name to Triton Financial Group, INC from Capstone Triton Financial Group. The firm has removed Joel Haworth and Joe Combest from the Investment Committee. (Item 8) Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in our business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 309294. You may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (405) 848-4646. Triton Financial Group, INC14614 Bogert Parkway, Oklahoma City, OK 73134 Phone: 405-696-7140* Fax: 405-442-0400 Page 2  Item 3 – Table of Contents Item 1 – Cover Page Item 2 – Material Changes Item 3 – Table of Contents Item 4 – Advisory Services A. Firm Information B. Advisory Services Offered C. Client Account Management D. Wrap Fee Programs E. Assets Under Management Item 5 – Fees and Compensation A. Fees for Advisory Services B. Fee Billing C. Other Fees and Expenses D. Advance Payment of Fees and Termination E. Compensation for Sales of Securities Item 6 – Performance-Based Fees and Side-By-Side Management Item 7 – Types of Clients Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis B. Risk of Loss Item 9 – Disciplinary Information Item 10 – Other Financial Industry Activities and Affiliations Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics B. Personal Trading with Material Interest C. Personal Trading in Same Securities as Clients D. Personal Trading at Same Time as Client Item 12 – Brokerage Practices A. Recommendation of Custodian[s] B. Aggregating and Allocating Trades Item 13 – Review of Accounts A. Frequency of Reviews B. Causes for Reviews C. Review Reports Item 14 – Client Referrals and Other Compensation A. Compensation Received by CTFG B. Client Referrals from Solicitors Item 15 – Custody Item 16 – Investment Discretion Item 17 – Voting Client Securities Item 18 – Financial Information Form ADV Part 2B – Brochure Supplement Privacy Policy 1 2 3 4 4 4 6 6 6 6 6 7 7 8 8 9 9 9 9 10 11 11 11 11 12 12 12 12 12 13 13 13 13 13 13 13 14 14 14 15 15 16 24 Triton Financial Group, INC14614 Bogert Parkway, Oklahoma City, OK 73134 Phone: 405-696-7140* Fax: 405-442-0400 Page 3  Item 4 – Advisory Services A. Firm Information Triton Financial Group, INC (“TFG” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as an Oklahoma corporation. TFG was founded in February 2020. TFG is 100% owned by the Andrew Oster Revocable Trust, LLC. Andrew E. Oster is the sole trustee of the Andrew Oster Revocable Trust and serves as the President and Chief Compliance Officer (CCO) of TFG. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by TFG. B. Advisory Services Offered TFG offers investment advisory services to individuals, high net worth individuals, corporations (both for-profit and nonprofits), pensions and profit-sharing plans (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. CTFG’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services TFG may provide Clients with wealth management services, which generally includes a broad range of comprehensive financial planning and consulting services in connection with discretionary management of investment portfolios. These services may also be offered on a stand-alone basis and are described below. Investment Management Services – TFG provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. TFG works closely with each Client to identify their investment goals and objectives, risk tolerance and financial situation in order to create a portfolio strategy. TFG will then construct an investment portfolio, primarily consisting of individual stocks, bonds, mutual funds, and exchange-trade funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may retain certain types of investments based on a Client’s legacy portfolio construction. TFG will select, recommend and/or retain mutual funds on a fund-by-fund basis. Due to specific custodial and/or mutual fund company constraints, material tax consideration, and/or systematic investment plans, TFG will select, recommend and/or retain a mutual fund share class that does not have trading costs, but do have higher internal expense ratios than institutional share classes. TFG will seek to select the lowest cost share class available that is in the best interest of each Client and will ensure the selection aligns with the Client’s financial objectives and stated investment guidelines. TFG’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held less than one year to meet the objectives of the Client or due to market conditions. TFG will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. TFG evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. TFG may recommend, on occasion, redistributing investment allocations to diversify the portfolio. TFG may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. TFG may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] Triton Financial Group, INC14614 Bogert Parkway, Oklahoma City, OK 73134 Phone: 405-696-7140* Fax: 405-442-0400 Page 4  in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. At no time will TFG accept or maintain custody of a Client’s funds or securities, except for the limited authority as outline in Item 15 – Custody. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the Client investment advisory agreement. Please see Item 12 – Brokerage Practices. Financial Planning and Consulting Services – TFG will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. Financial consulting may involve preparing a consulting report, but such a report is not required. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. TFG may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Retirement Plan Advisory Services TFG provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: ● Vendor Analysis Triton Financial Group, INC14614 Bogert Parkway, Oklahoma City, OK 73134 Phone: 405-696-7140* Fax: 405-442-0400 Page 5  ● Plan Participant Enrollment and Education Investment Policy Statement (“IPS”) Design and Monitoring ● ● Investment Management Services (ERISA 3(38)) ● Ongoing Investment Recommendation and Assistance ● ERISA 404(c) Assistance These services are provided by TFG serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of TFG’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Prior to engaging TFG to provide investment advisory services, each Client is required to enter into a written agreement with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: ● Establishing an Investment Strategy – TFG, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. ● Asset Allocation – TFG will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. ● Portfolio Construction – TFG will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. ● Investment Management and Supervision – TFG will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs TFG does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by TFG. E. Assets Under Management As of December 31, 2024 TFG manages $ 292,964,881 in Client assets, $ 292,964,881 of which are managed on a discretionary basis and $ 0 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written agreement with the Advisor. A. Fees for Advisory Services Wealth Management Services / Investment Management Services Investment advisory fees may be billed either quarterly or monthly (herein the “Billing Period”), in advance of or at the end of each Billing Period, pursuant to the terms of the agreement. Investment advisory fees are based on the market value of assets under management at the end of the respective calendar period. Investment advisory fees range from 0.25% to 1.50% annually based on several factors, including: the complexity of the services to be provided, the level of assets to be managed, and the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions and other complexities may be charged a higher fee. Client’s with household values of $100,000 and below may have accounts in their household subject to an annual administrative fee of up to $100.00. Triton Financial Group, INC14614 Bogert Parkway, Oklahoma City, OK 73134 Phone: 405-696-7140* Fax: 405-442-0400 Page 6  The investment advisory fee in the first Billing Period of service is prorated from the inception date of the account[s] to the end of the first period. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with Advisor. All securities held in accounts managed by TFG will be independently valued by the designated Custodian. TFG will conduct periodic reviews of the Custodian’s valuations. The Advisor’s fee is exclusive of, and in addition to, brokerage fees, transaction fees, and other related costs and expenses, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Financial Planning and Consulting Services TFG offers financial planning services either on an hourly basis or for a fixed fee. Hourly fees range up to $250. Fixed fees range up to $2,500. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and total costs will be provided to the Client prior to engaging for these services. TFG offers directed research and reporting services subject negotiation of specific topic and content requirements with the Client. Hourly fees for directed research and reporting services range up to $300 per hour. Fixed for this service range up to $50,000. The agreement between Advisor and Client will provide the Client with either an estimate for the total hours and costs associated with the project or the fixed fee for the project prior to engage in these services. Retirement Plan Advisory Services Fees for retirement plan advisory services are charged an annual asset-based fee of up to 1.00% and are billed in arrears, pursuant to the terms of the retirement plan advisory agreement. Retirement plan advisory fees are based on the market value of assets under management at the end of the prior month. Fees may be negotiable depending on the size and complexity of the Plan. B. Fee Billing Wealth Management Services / Investment Management Services Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the respective Billing Period date. The amount due is calculated by applying the Billing Period rate (annual rate divided by 4) to the total assets under management with TFG at the end of each Billing Period. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide written authorization permitting TFG to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Financial Planning and Consulting Services Financial planning fees are invoiced by the Advisor and are due upon completion of the agreed upon deliverable[s]. Retirement Plan Advisory Services Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. It is the responsibility of the Plan Sponsor to verify the accuracy of retirement plan advisory fees listed in the plans recordkeeping system. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than CTFG, in connection with investments made on behalf of the Client’s account[s]. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. Exchange processing fees may still be imposed by the Triton Financial Group, INC14614 Bogert Parkway, Oklahoma City, OK 73134 Phone: 405-696-7140* Fax: 405-442-0400 Page 7  Custodian on ETF and equity trades. However, the Custodian typically charges for mutual funds and other types of investments. The Client is responsible for all custody and securities execution fees charged by the Custodian. The fees charged by TFG are separate and distinct from these custody and execution fees. In addition, all fees paid to TFG for investment advisory services are separate and distinct from the expenses charged by mutual funds and exchange-traded funds to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client could invest in these products directly, without the services of CTFG, but would not receive the services provided by TFG which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by TFG to fully understand the total fees to be paid. Additionally, as noted above, the Advisor will select share classes which do not have trading costs, but do have higher internal expense ratios than institutional share classes. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Wealth Management Services / Investment Management Services TFG is compensated for its services in advance of each Billing Period. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The effective date of termination shall be the last day of the month in which notice of termination is provided (“Termination Effective Date”). Upon termination, advisory fees billed in advance will be prorated and refunded to the Client’s account[s] as of the Termination Effective Date. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Financial Planning and Consulting Services TFG is compensated for its services upon completion of the engagement deliverable[s]. Either party may terminate the financial planning agreement by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for actual hours logged on the planning project times the contractual hourly rate or in the case of a fixed fee engagement, the percentage of the engagement scope completed by the Advisor. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. Retirement Plan Advisory Services TFG is compensated for its services at the beginning of the quarter for which services are rendered. Either party may terminate the retirement plan advisory agreement, at any time, by providing advance written notice to the other party. The effective date of the termination of retirement plan advisory services shall be the last day of the month in which notice of termination is provided (“Retirement Plan Termination Effective Date”). The Client may also terminate the retirement plan advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the Retirement Plan Termination Effective Date and such fees will be due and payable by the Client. The Client’s retirement plan advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Triton Financial Group, INC14614 Bogert Parkway, Oklahoma City, OK 73134 Phone: 405-696-7140* Fax: 405-442-0400 Page 8  E. Compensation for Sales of Securities Item 6 – Performance-Based Fees and Side-By-Side Management TFG does not charge performance-based fees for its investment advisory services. The fees charged by TFG are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. TFG does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients TFG offers investment advisory services to individuals, high net worth individuals, corporations (both for-profit and nonprofit), pensions and profit-sharing plans. The amount of each type of Client is available on TFG Form ADV Part 1A. TFG generally does not impose a minimum relationship size. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis TFG primarily employs fundamental, technical, and cyclical analysis methods in developing investment strategies for its clients. Research and analysis from TFG is derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. TFG s Investment Committee’s purpose is to manage and review TFG investment policies and guidelines, model investment portfolios or any other collection of securities, defined contribution plan investment menu (collectively “Portfolios’). The Investment Committee membership includes Richard DiAngelo (Committee Chair), Andrew Oster and Mara Scott. Fundamental Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Technical Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that TFG will be able to accurately predict such a reoccurrence. Cyclical Cyclical analysis is similar to technical analysis in that it involves the analysis of market conditions at a macro (entire market/economy) or micro (company specific) level, rather than the overall fundamental analysis of the health of the particular company that TFG is recommending. The risks with cyclical analysis are similar to those of technical analysis. Triton Financial Group, INC14614 Bogert Parkway, Oklahoma City, OK 73134 Phone: 405-696-7140* Fax: 405-442-0400 Page 9  As noted above, TFG generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. TFG will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, TFG may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. TFG will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. The following are some of the risks associated with certain components of the Advisor’s investment approach: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs are subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) re-investment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Triton Financial Group, INC14614 Bogert Parkway, Oklahoma City, OK 73134 Phone: 405-696-7140* Fax: 405-442-0400 Page 10  Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds are subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information Securities laws require an advisor to disclose any instances where the Advisor or its Advisory Persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. The Advisor has no disciplinary information required to be disclosed under this section. Item 10 – Other Financial Industry Activities and Affiliations The above non-advisory activities present a potential conflict of interest, to the extent that Capstone Triton Financial Group management and employees may receive additional compensation as a result of recommending additional services to potential advisory Clients. To mitigate this conflict Triton Financial Group, INC does the following: 1. We disclose to Clients the existence of all material conflicts of interest, including the potential for an affiliated firm to earn compensation from advisory Clients in addition to our advisory fees; 2. We disclose to Clients that they are not obligated to purchase any additional services from our firm or its affiliates; 3. We collect, maintain and document accurate, complete and relevant Client background information, including the Client’s financial goals, objectives and risk tolerance; 4. We require that our employees seek prior approval of any outside employment activity so that we may ensure that any conflicts of interests in such activities are properly addressed; 5. We periodically monitor these outside employment activities to verify that any conflicts of interest continue to be properly addressed by our firm; and 6. We educate our employees regarding the responsibilities of a fiduciary, including the need for having a reasonable and independent basis for the investment advice provided to Clients. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics TFG has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with TFG (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the Client. TFG and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of TFG’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (405) 848-4646. B. Personal Trading with Material Interest TFG allows Supervised Persons to purchase or sell the same securities that may be recommended to and Triton Financial Group, INC14614 Bogert Parkway, Oklahoma City, OK 73134 Phone: 405-696-7140* Fax: 405-442-0400 Page 11  purchased on behalf of Clients. TFG does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund or advise an investment company. TFG does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients TFG allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by TFG requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. TFG has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While TFG allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. At no time will TFG , or any Supervised Person of TFG , transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] TFG does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize TFG to direct trades to this Custodian as agreed in the investment advisory agreement. Further, TFG does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by- trade basis. Where TFG does not exercise discretion over the selection of the Custodian, it may recommend the Custodian[s] to Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost associated with using a custodian not recommended by TFG . However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. TFG may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and location of the Custodian’s offices. The Advisor typically recommends that Clients establish accounts at either Charles Schwab & Co., Inc (“Schwab”) or member FINRA/SIPC. Schwab is an independent and unaffiliated SEC-registered broker-dealer. Schwab offers to independent investment Advisors services, which include custody of securities, trade execution, clearance and settlement of transactions. Advisor receives some benefits from Schwab through its participation in their program. (Please see the disclosure under Item 14 below.) Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with the broker/dealers/custodians in exchange for research and other services. TFG does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals - TFG does not receive any compensation from any third party in connection with the Triton Financial Group, INC14614 Bogert Parkway, Oklahoma City, OK 73134 Phone: 405-696-7140* Fax: 405-442-0400 Page 12  recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where TFG will place trades within the established account[s] at the custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). TFG will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the designated Custodian. The Advisor may not be able to aggregate orders to reduce transaction costs in a Client directed brokerage account. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the broker-dealer/custodian. TFG will execute its transactions through the Custodian as authorized by the Client. TFG may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Client accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by the TFG Investment Committee. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more or less frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify TFG if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by TFG TFG is a fee-based advisory firm that is compensated solely by its Clients and not from any investment product. TFG does not receive commissions or other compensation from product sponsors, broker-dealers or any unrelated third party. TFG may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, TFG may receive non-compensated referrals of new Clients from various third parties. Triton Financial Group, INC14614 Bogert Parkway, Oklahoma City, OK 73134 Phone: 405-696-7140* Fax: 405-442-0400 Page 13  Participation in Institutional Advisor Platform TFG has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like TFG. As a registered investment advisor participating on the Schwab Advisor Services platform, TFG receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services to TFG that may not benefit the Client, including: educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest. TFG believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. B. Client Referrals from Solicitors TFG does not engage paid solicitors for Client referrals. Item 15 – Custody TFG does not accept or maintain custody of any Client accounts, except for the authorized deduction of the Advisor’s fees. All Clients must place their assets with a “qualified custodian”. Clients are required to engage the Custodian to retain their funds and securities and direct TFG to utilize that Custodian for the Client’s security transactions. Clients should review statements provided by the Custodian and compare to any reports provided by TFG to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. Item 16 – Investment Discretion TFG generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by TFG . Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by TFG will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities Triton Financial Group, INC14614 Bogert Parkway, Oklahoma City, OK 73134 Phone: 405-696-7140* Fax: 405-442-0400 Page 14  TFG accepts proxy-voting responsibility for securities held in Client accounts when authorization is provided by the Client. The advisory agreement between TFG and the Client will generally specify whether or not TFG has the authority to vote proxies on behalf of a particular Client. Proxy Voting Policy and Procedures TFG shall vote proxies in the best interest of its Clients and shall not subrogate the Client interest to its own. TFG monitors corporate actions through the Custodian. TFG receives notice of upcoming proxy votes, meeting and record dates and other information on upcoming corporate actions by companies in which TFG Clients are shareholders. Clients may request a copy of TFG proxy voting records, free of charge, by contacting TFG Conflicts of Interest in the Voting Process On occasion, a conflict of interest may exist between the Advisor and the Client regarding the outcome of certain proxy votes. In such cases, the Advisor is committed to resolving the conflict in the best interest of the Clients before the Advisor votes the proxy in question. Client Direction of Voting Although most Clients for whom the Advisor votes proxies authorize the Advisor to vote in accordance with the Advisor’s proxy voting policy, a Client may request that TFG vote its proxies in accordance with a different policy. TFG will seek to accommodate such requests. In addition, a Client may direct TFG to vote its securities in a particular way on a particular proposal and the Advisor will seek to do so, assuming timely receipt of the instruction. Item 18 – Financial Information Neither TFG nor its management, have any adverse financial situations that would reasonably impair the ability of TFG to meet all obligations to its Clients. Neither TFG nor any of its Advisory Persons, has been subject to a bankruptcy or financial compromise. TFG is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in Triton Financial Group, INC14614 Bogert Parkway, Oklahoma City, OK 73134 Phone: 405-696-7140* Fax: 405-442-0400 Page 15  Form ADV Part 2B – Brochure Supplement for Andrew E. Oster, CFP® President & Chief Compliance Officer Effective: March 26, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Andrew E. Oster (CRD# 4635272) in addition to the information contained in the Triton Financial Group, INC (“TFG ” or the “Advisor”, CRD# 309294) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the TFG Disclosure Brochure or this Brochure Supplement, please contact the Advisor at 405-696-7140. Additional information about Mr. Oster is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4635272. Triton Financial Group, INC14614 Bogert Parkway, Oklahoma City, OK 73134 Phone: 405-696-7140* Fax: 405-442-0400 Page 16  Item 2 – Educational Background and Business Experience Andrew E. Oster, born in 1978, is dedicated to advising Clients of TFG as the President and Chief Compliance Officer. Mr. Oster earned a Master of Business Administration (MBA) - Finance from University of Oklahoma in 2003. Mr. Oster also earned a Bachelor of Business Administration (BBA) - Finance from University of Oklahoma in 2001. Additional information regarding Mr. Oster’s employment history is included below. Employment History: 11/2020 to Present President and CCO, Triton Financial Group, INC (03/2022 to Present) Executive Vice President and CCO, Capstone Triton Financial Group INC (11/2020 to 03/2022) President & CCO, Triton Financial Group, INC President & CCO, Triton Wealth Advisors LLC Financial Advisor, SagePoint Financial, Inc. Financial Advisor, Securities America, Inc. 05/2020 to 11/2020 08/2011 to 12/2020 05/2014 to 01/2019 01/2009 to 05/2014 Certified Financial Planner™ (“CFP®”) The Certified Financial Planner™, CFP®, and federally registered CFP® (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified Financial Planner™ Board of Standards, Inc. (“CFP® Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 71,000 individuals have obtained CFP® certification in the United States. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements: ● Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP® Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP® Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; ● Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real-world circumstances; ● Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and ● Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks: ● Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and ● Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients. CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP® Board’s enforcement process, which could result in suspension or permanent revocation of their CFP®. Triton Financial Group, INC14614 Bogert Parkway, Oklahoma City, OK 73134 Phone: 405-696-7140* Fax: 405-442-0400 Page 17  Item 3 – Disciplinary Information Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Oster. However, we do encourage you to independently view the background of Mr. Oster on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4635272. Item 4 – Other Business Activities Mr. Oster acts as a member of Unterschrift Partners, LLC, a family LLC for estate planning purposes to hold the majority of family assets. Additionally, the ongoing business of the LLC may be to purchase and hold real estate for rent/lease. Mr. Oster oversees the general operations of the LLC. Mr. Oster acts as a member of Unterschrift Ventures, LLC, an estate planning mechanism for Mr. Oster’s inherited assets. The ongoing business of Unterschrift Ventures, LLC is to hold title to real estate and other personal investments. Mr. Oster oversees the operations of the LLC. Item 5 – Additional Compensation Mr. Oster has additional business activities where compensation is received that are detailed in Item 4 above. Item 6 – Supervision Mr. Oster serves as the President and the Chief Compliance Officer of TFG. Mr. Oster can be reached at 405-696- 7140. TFG has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of TFG. Further, TFG is subject to regulatory oversight by various agencies. These agencies require registration by TFG and its Supervised Persons. As a registered entity, TFG is subject to examinations by regulators, which may be announced or unannounced. TFG is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Triton Financial Group, INC14614 Bogert Parkway, Oklahoma City, OK 73134 Phone: 405-696-7140* Fax: 405-442-0400 Page 18  Form ADV Part 2B – Brochure Supplement for Richard J. DiAngelo Vice President Effective: March 26, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Richard J. DiAngelo (CRD# 2528991) in addition to the information contained in the Triton Financial Group, INC (“TFG” or the “Advisor”, CRD# 309294) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the TFG Disclosure Brochure or this Brochure Supplement, please contact us at 405-696-7140. Additional information about Mr. DiAngelo is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2528991. Triton Financial Group, INC14614 Bogert Parkway, Oklahoma City, OK 73134 Phone: 405-696-7140* Fax: 405-442-0400 Page 19  Item 2 – Educational Background and Business Experience Richard J. DiAngelo, born in 1963, is dedicated to advising Clients of TFG as a Vice President. Mr. DiAngelo earned a BA Economics from Rutgers University in 1985. Mr. DiAngelo also received a certificate in Blockchain and Digital Assets from the Digital Assets Council of Financial Professionals in 2022. Additional information regarding Mr. DiAngelo’s employment history is included below. Employment History: Vice President, Triton Financial Group, INC Managing Partner, Kachina Investment 04/2021 to Present 07/2003 to 04/2021 Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. DiAngelo. Mr. DiAngelo has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. DiAngelo. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. DiAngelo. However, we do encourage you to independently view the background of Mr. DiAngelo on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2528991. Item 4 – Other Business Activities Mr. DiAngelo is dedicated to the investment advisory activities of TFG’s Clients. Mr. DiAngelo does not have any other business activities. Item 5 – Additional Compensation Mr. DiAngelo is dedicated to the investment advisory activities of TFG Clients. Mr. DiAngelo does not receive any additional forms of compensation. Item 6 – Supervision Mr. DiAngelo serves as a Vice President of TFG and is supervised by Andrew Oster, the Chief Compliance Officer. Mr. Oster can be reached at 405-696-7140. TFG has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of TFG. Further, TFG is subject to regulatory oversight by various agencies. These agencies require registration by TFG and its Supervised Persons. As a registered entity, TFG is subject to examinations by regulators, which may be announced or unannounced. TFG is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Triton Financial Group, INC14614 Bogert Parkway, Oklahoma City, OK 73134 Phone: 405-696-7140* Fax: 405-442-0400 Page 20  Privacy Policy Effective: July 20, 2023 Our Commitment to You Triton Financial Group, INC (“TFG or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. TFG (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. TFG does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? advisory agreements and legal Custody, brokerage and advisory agreements Other documents information needed to service Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Triton Financial Group, INC14614 Bogert Parkway, Oklahoma City, OK 73134 Phone: 405-696-7140* Fax: 405-442-0400 Page 21  How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No to: processing Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. No Not Shared Marketing Purposes TFG does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where TFG or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Yes Yes Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. No Not Shared Information About Former Clients TFG does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. State-specific Regulations California In response to a California law, to be conservative, we assume accounts with California addresses do not want us to disclose personal information about you to non-affiliated third parties, except as permitted by California law. We also limit the sharing of personal information about you with our affiliates to ensure compliance with California privacy laws. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at 405-696-7140. Triton Financial Group, INC14614 Bogert Parkway, Oklahoma City, OK 73134 Phone: 405-696-7140* Fax: 405-442-0400 Page 22