TWIN CITIES RETIREMENT GROUP

F O R M A D V P A R T 2 A D I S C L O S U R E B R O C H U R E Office Address: th 15600 36 Ave N Suite 240 Plymouth, MN 55446 Telephone: 952-600-7550 info@twincitiesretirementgroup.com www.twincitiesretirementgroup.com A P R I L 2 0 , 2 0 2 6 This brochure provides information about the qualifications and business practices of Twin Cities Retirement Group, LLC. Being registered as a Registered Investment Adviser does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at 952-600- 7550. 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. information about Twin Cities Retirement Group, LLC. Additional (IARD#154974) is available on the SEC’s website at www.adviserinfo.sec.gov i Twin Cities Retirement Group, LLC  Item 2: Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material Material Changes since the Last Update changes occur since the previous release of the Firm Brochure. March 12, 2026, there have been the following Since the last filing of this brochure on material changes: Full Brochure Available Item 5 has been amended to show an updated fee schedule. This Firm Brochure being delivered is the complete brochure for the Firm. ii Twin Cities Retirement Group, LLC  Item 3: Table of Contents Form ADV – Part 2A – Firm Brochure Item 1: Cover Page Item 2: Material Changes .................................................................................................................... ii Annual Update ................................................................................................................................................................... ii Material Changes since the Last Update.................................................................................................................. ii Item 4: Advisory Business .................................................................................................................. 1 Full Brochure Available .................................................................................................................................................. ii Firm Description ............................................................................................................................................................... 1 Types of Advisory Services ........................................................................................................................................... 1 Client Tailored Services and Client Imposed Restrictions ............................................................................... 1 Wrap Fee Programs ......................................................................................................................................................... 2 Item 5: Fees and Compensation ....................................................................................................... 2 Client Assets under Management .............................................................................................................................. 2 Method of Compensation and fee schedule ........................................................................................................... 2 Client Payment of Fees ................................................................................................................................................... 3 Additional Client Fees Charged ................................................................................................................................... 4 Prepayment of Client Fees ............................................................................................................................................ 4 Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 4 External Compensation for the Sale of Securities to Clients ........................................................................... 4 Item 7: Types of Clients ....................................................................................................................... 4 Sharing of Capital Gains ................................................................................................................................................. 4 Description .......................................................................................................................................................................... 4 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 4 Account Minimums .......................................................................................................................................................... 4 Methods of Analysis ......................................................................................................................................................... 4 Investment Strategy ........................................................................................................................................................ 5 Item 9: Disciplinary Information ..................................................................................................... 8 Security Specific Material Risks .................................................................................................................................. 5 Criminal or Civil Actions ................................................................................................................................................ 8 Administrative Enforcement Proceedings ............................................................................................................. 8 Self-Regulatory Organization Enforcement Proceedings ................................................................................ 9 iii Twin Cities Retirement Group, LLC  Item 10: Other Financial Industry Activities and Affiliations ............................................... 9 Broker-Dealer or Representative Registration .................................................................................................... 9 Futures or Commodity Registration ......................................................................................................................... 9 Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................... 9 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ................ 9 Trading ................................................................................................................................................... 10 Code of Ethics Description ......................................................................................................................................... 10 Investment Recommendations Involving a Material Financial Interest and Conflict of Interest. 10 Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest 10 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Item 12: Brokerage Practices ......................................................................................................... 11 Transactions and Conflicts of Interest .................................................................................................................. 11 Factors Used to Select Broker-Dealers for Client Transactions ................................................................. 11 Item 13: Review of Accounts ........................................................................................................... 13 Aggregating Securities Transactions for Client Accounts ............................................................................. 12 Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved ............................................................................................................................................................................. 13 Review of Client Accounts on Non-Periodic Basis ........................................................................................... 13 Item 14: Client Referrals and Other Compensation ................................................................ 13 Content of Client Provided Reports and Frequency ........................................................................................ 13 Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest ............................................................................................................................................................................... 13 Item 15: Custody .................................................................................................................................. 13 Advisory Firm Payments for Client Referrals .................................................................................................... 13 Item 16: Investment Discretion ..................................................................................................... 14 Account Statements ...................................................................................................................................................... 13 Item 17: Voting Client Securities ................................................................................................... 14 Discretionary Authority for Trading...................................................................................................................... 14 Item 18: Financial Information ...................................................................................................... 14 Proxy Votes ...................................................................................................................................................................... 14 Balance Sheet .................................................................................................................................................................. 14 Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients ............................................................................................................................................................................ 14 Bankruptcy Petitions during the Past Ten Years .............................................................................................. 14 iv Twin Cities Retirement Group, LLC  Brochure Supplement (Part 2B of Form ADV) .......................................................................... 16 Supervised Person Brochure .................................................................................................................................... 16 Principal Executive Officer - Patrick Illies ........................................................................................................... 16 Item 2 Educational Background and Business Experience .......................................................................... 16 Item 3 Disciplinary Information .............................................................................................................................. 16 Item 4 Other Business Activities ............................................................................................................................. 16 Item 5 Additional Compensation ............................................................................................................................ 17 Item 6 Supervision ........................................................................................................................................................ 17 v Twin Cities Retirement Group, LLC  Item 4: Advisory Business Firm Description Twin Cities Retirement Group, LLC (“TCRG”) was founded in 2005 and became a Minnesota state-registered investment advisor in 2010 and SEC registered in 2026. TCRG is owned by Patrick Illies. TCRG is a registered investment advisor providing asset management services primarily to individuals. TCRG also provides retirement planning services to individuals nearing retirement, as well as those that have recently retired. This includes evaluating an individual’s financial status and designing the optimal retirement plan for their lifestyle. TCRG can help individuals determine the best time to retire or assist individuals in expanding on plans they’ve already made. TCRG may provide advice in such areas as defined contribution and defined benefit plans, Social Security benefit maximization, cash flow analysis, beneficiary designations, estate planning, and more. Other professionals (e.g., lawyers, accountants, tax preparers, insurance agents, etc.) are engaged directly by the Client on an as-needed basis and may charge fees of their own. Types of Advisory Services Conflicts of interest will be disclosed to the Client in the event they should occur. ASSET MANAGEMENT TCRG offers discretionary asset management services to advisory Clients. TCRG will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The Client will authorize TCRG discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. TCRG may possibly recommend that clients authorize the active discretionary management of REFERRAL ARRANGEMENTS their investments by one or more Independent Registered Investment Advisory Firms based on their stated financial goals and objectives as disclosed in our discussions. The terms and conditions under which clients engage an Independent Registered Investment Advisory Firm will be outlined in a separate written agreement between themselves and the designated option selected. TCRG will provide you with our own ADV Part 2A if you retain our services. You will also receive ADV Part 2A for the Independent Registered Investment Advisory Firm from us. Independent providers may have more restrictive requirements and billing practices than TCRG. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written Client consent. - 1 - Twin Cities Retirement Group, LLC  Wrap Fee Programs Client Assets under Management TCRG does not sponsor any wrap fee programs. TCRG has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: $144,901,181 $0 Date Calculated: April 20, 2026 Item 5: Fees and Compensation Method of Compensation and fee schedule ASSET MANAGEMENT TCRG offers discretionary direct asset management services to advisory Clients. TCRG charges an annual investment advisory fee based on the following fee schedule: Assets Under Management Under $1,000,000 $1,000,000 to $2,000,000 Over $2,000,000 Annual Fee 1.25% 1.00% 0.85% This is a flat rate/breakpoint fee schedule, the entire portfolio is charged the same asset management fee. For example, a Client with $1,500,000 under management would pay $15,000 on an annual basis. $1,500,000 x 1.00% = $15,000. The annual fee may be negotiable based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with Clients, etc.). Fees are billed quarterly in advance based on the amount of assets managed as of the close of business on the last business day of the previous quarter. If cash and/or securities are deposited or withdrawn, a prorated fee will be charged on the net value of the deposit and/or withdrawn as of the date of the activity. For accounts opened or closed mid-billing period, unearned fees will be refunded to the Client. *The fee for a partial quarter is calculated by multiplying the Account Balance by the Annual Fee Percentage divided by 4 times the number of days service was provided in the quarter, divided by the total number of days in the quarter. *The fee for a full quarter is calculated by multiplying the Account Balance by the Annual Fee Percentage divided four. Lower fees for comparable services may be available from other sources. Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement with no obligation and without penalty. Clients may terminate advisory services with thirty (30) days written notice. Client shall be given thirty (30) days prior written notice of any increase in fees. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. For fees that are directly deducted from the account by the custodian: - 2 - Twin Cities Retirement Group, LLC  • TCRG will provide the Client with an invoice concurrent to instructing the custodian to deduct the fee stating the amount of the fee, the formula used to calculate the fee, the amount of assets under management the fee is based on and the time period covered by the fee; • TCRG will obtain written authorization signed by the Client allowing the fees to be deducted; and • The Client will receive quarterly statements directly from the custodian which disclose the fees deducted. REFERRAL FEES TCRG is paid referral fees by third party money managers. The details of the fee structure will be disclosed to the Client prior to signing any investment advisory agreement and the Client will receive a copy of third-party advisors Form ADV Part 2. More information is available in Item 10 of this brochure. Twin Cities Retirement Group, LLC has entered into an agreement with Steele Capital Management, Inc. (SCM), CRD#107097, a Registered Investment Advisor, for the purpose of referring Clients to SCM as an independent Referral in accordance with the provisions of Rule 206(4)-3 under the Investment Advisors Act of 1940. SCM charges a negotiable annualized fee based on the following fee schedule: TCRG Portion Assets Under Management Up to $1,000,000 Total Annual Fee 1.50% 0.9375% $1,000,001 to $1,500,000 1.25% 0.78125% $1,500,001 to $2,500,000 1.00% 0.625% $2,500,001 to $3,500,000 0.85% 0.53125% $3,500,001 to $5,000,000 0.75% 0.46875% Over $5,000,000 negotiable negotiable This is a flat rate/breakpoint fee schedule, the entire portfolio is charged the same asset management fee. For example, a Client with $2,000,000 under management would pay $20,000 on an annual basis. $2,000,000 x 1.00% = $20,000. Fees are payable quarterly in advance based on the market value of the managed assets on the first day of each calendar quarter. Fees are negotiable based upon certain criteria (i.e. anticipated future earning capacity, anticipated additional assets, dollar amount of assets to be managed, historical relationships, related account, etc.) TCRG is compensated for services by a fee equal to 62.5% of the advisory fees collected by Steele Capital Client Payment of Fees Management, Inc., for each client referred to SCM by TCRG. Asset management fees are billed quarterly in advance and deducted from the Client’s account. Clients pay the third-party money managers’ investment advisory fees. Prior to signing an investment advisory agreement, the method of payment will be disclosed in the third-party money manager’s Form ADV Part 2. - 3 - Twin Cities Retirement Group, LLC  Additional Client Fees Charged Custodians may charge transaction fees on purchases or sales of certain mutual funds, equities, and exchange-traded funds. These charges may include Mutual Fund transactions fees, postage and handling and miscellaneous fees (fee levied to recover costs associated with fees assessed by self-regulatory organizations). The selection of the security is more Prepayment of Client Fees important than the nominal fee that the custodian charges to buy or sell the security. TCRG does not require any prepayment of Client fees of more than $1200 per Client and six External Compensation for the Sale of Securities to Clients months or more in advance. TCRG does not receive any external compensation for the sale of securities to Clients, nor do any of the investment advisor representatives of TCRG. Item 6: Performance-Based Fees and Side-by-Side Management Sharing of Capital Gains Fees are not based on a share of the capital gains or capital appreciation of managed securities. TCRG does not use a performance-based fee structure because of the conflict of interest. Performance-based compensation may create an incentive for the adviser to recommend an investment that may carry a higher degree of risk to the Client. Item 7: Types of Clients Description TCRG provides retirement planning services to individuals and high net worth individuals nearing retirement, as well as, those that have recently retired. Client relationships vary in Account Minimums scope and length of service. TCRG’s minimum for Clients is $1,000,000. TCRG will make exceptions to its minimums in certain situations. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include fundamental analysis, technical analysis, charting, and cyclical analysis. Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always - 4 - Twin Cities Retirement Group, LLC  follow patterns and relying solely on this method may not consider new patterns that emerge over time. Charting analysis strategy involves using and comparing various charts to predict long and short-term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be assuming that past performance will be indicative of future performance. This may not be the case. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are twofold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. The main sources of information include financial newspapers and magazines, annual Investment Strategy reports, prospectuses, and filings with the Securities and Exchange Commission. The investment strategy for a specific Client is based upon the objectives stated by the Client during consultations. The Client may change these objectives at any time by providing written notice to TCRG. Each Client executes a Client profile form or similar form that documents their objectives and their desired investment strategy. Other strategies may include long-term purchases, short-term purchases, trading, and option writing (including covered options, uncovered options or spreading strategies). The designated RIA selected for portfolio management will typically manage each Client portfolio with one of five investment strategies; Conservative, Moderate, Balanced, Growth, or Aggressive, depending on the Client’s objective and tolerance for risk. The aggressive strategy will typically have the most stock market exposure, while the conservative strategy will have the least. Overall, the designated RIA’s investment strategy is typically based on strategic asset allocation discipline; however, it may make tactical adjustments as market conditions dictate. The strategy also may include diversifying portfolios across several investment styles and industry sectors utilizing primarily no-load mutual funds, Security Specific Material Risks however, portfolios may also include individual securities and exchange traded funds. • Market Risk All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks and should discuss these risks with TCRG: : The prices of securities held by mutual funds in which Clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by a fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in market value. - 5 - Twin Cities Retirement Group, LLC  Interest-rate Risk • • : Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become Inflation Risk less attractive, causing their market values to decline. • Currency Risk : When any type of inflation is present, a dollar today will buy more than a dollar next year, because purchasing power is eroding at the rate of inflation. • Reinvestment Risk : Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Liquidity Risk : This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Management Risk: : Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Equity Risk: The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the expected time frame, the overall performance of the Client’s portfolio may suffer. • Fixed Income Risk: Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the Client’s overall portfolio. Small and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. • The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by a fund is likely to decrease. A Investment Companies Risk: nominal interest rate is the sum of a real interest rate and an expected inflation rate. When a Client invests in open end mutual funds or ETFs, the Client indirectly bears their proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will incur higher expenses, which may be duplicative. In addition, the Client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de- - 6 - Twin Cities Retirement Group, LLC  • REIT Risk: listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. Adviser has no control over the risks taken by the underlying funds in which Client invests. • Long-term purchases To the extent that a Client invests in REITs, it is subject to risks generally associated with investing in real estate, such as (i) possible declines in the value of real estate, (ii) adverse general and local economic conditions, (iii) possible lack of availability of mortgage funds, (iv) changes in interest rates, and (v) environmental problems. In addition, REITs are subject to certain other risks related specifically to their structure and focus such as: dependency upon management skills; limited diversification; the risks of locating and managing financing for projects; heavy cash flow dependency; possible default by borrowers; the costs and potential losses of self-liquidation of one or more holdings; the possibility of failing to maintain exemptions from securities registration; and, in many cases, relatively small market capitalization, which may result in less market liquidity and greater price volatility. • Short-term purchases : Long-term investments are those vehicles purchased with the intension of being held for more than one year. Typically, the expectation of the investment is to increase in value so that it can eventually be sold for a profit. In addition, there may be an expectation for the investment to provide income. One of the biggest risks associated with long-term investments is volatility, the fluctuations in the financial markets that can cause investments to lose value. • Trading risk : Short-term investments are typically held for one year or less. Generally, there is not a high expectation for a return or an increase in value. Typically, short-term investments are purchased for the relatively greater degree of principal protection they are designed to provide. Short-term investment vehicles may be subject to purchasing power risk — the risk that your investment’s return will not keep up with inflation. : Investing involves risk, including possible loss of principal. There is no • Options Trading assurance that the investment objective of any fund or investment will be achieved. • Trading on Margin: : The risks involved with trading options are that they are very time sensitive investments. An options contract is generally a few months. The buyer of an option could lose his or her entire investment even with a correct prediction about the direction and magnitude of a particular price change if the price change does not occur in the relevant time period (i.e., before the option expires). Additionally, options are less tangible than some other investments. An option is a “book-entry” only investment without a paper certificate of ownership. In a cash account, the risk is limited to the amount of money that has been invested. In a margin account, risk includes the amount of money invested plus the amount that has been loaned. As market conditions fluctuate, the value of marginable securities will also fluctuate, causing a change in the overall account balance and debt ratio. As a result, if the value of the securities held in a margin account depreciates, the Client will be required to deposit additional cash or make full payment of the margin loan to bring account back up to maintenance levels. Clients who cannot comply with such a margin call may be sold out or bought in by the brokerage firm. - 7 - Twin Cities Retirement Group, LLC  • Leveraged Risk • Equity Linked CD Risk: : The risks involved with using leverage may include compounding of returns (this works both ways – positive and negative), possible reset periods, volatility, use of derivatives, active trading and high expenses. • Structured Notes Risk: Penalties may apply to early withdrawals. Fair market value of CD’s when sold in the secondary market may be worth more or less than face value. May or may not be FDIC insured. Returns are not based solely on market returns, as there may be a maximum rate of interest the CD will earn. May be taxed on income earned, but interest isn’t accrued (received) until the CD matures. Many CDs may have “call” features, allowing the bank to close the contract early with no penalty, paying back principle and any accrued interest. • Hedge Funds Risk: The risks involved with using structured notes are credit risk of the issuing investment bank, illiquidity, and there is a risk to the pricing accuracy as most structured notes do not trade after issuance. • Private Equity/Placement Risk: The risks involved with hedge funds are that they may invest in unregistered investments that are not subject to the SEC's registration and disclosure requirements. They may have risky investment strategies, which may include speculative investment and trading strategies. Both unregistered and registered hedge funds are illiquid investments and are subject to restrictions on transferability and resale. The tax structure of investments in hedge funds may be complex. Because offerings are exempt from registration requirements, no regulator has reviewed the offerings to make sure the risks associated with the investment and all material facts about the entity raising money are adequately disclosed. Securities offered through private placements are generally illiquid, meaning there are limited opportunities to resell the security. Risk of the underlying investment may be significantly higher than publicly traded investments. • The risks associated with utilizing third party money managers include: o Manager Risk • the third-party money manager fails to execute the stated investment strategy o Business Risk • third party money manager has financial or regulatory problems The specific risks associated with the portfolios of the third-party money manager’s which is disclosed in the third party money manager’s Form ADV Part 2. Item 9: Disciplinary Information Criminal or Civil Actions Administrative Enforcement Proceedings TCRG and its management have not been involved in any criminal or civil action. TCRG and its management have not been involved in administrative enforcement proceedings. - 8 - Twin Cities Retirement Group, LLC  Self-Regulatory Organization Enforcement Proceedings Patrick Illies submitted a letter of acceptance, waiver, and consent in which he was barred from association from any Financial Regulatory Authority, Inc. (FINRA) member for nine months. (November 2009-August 2010). Without admitting or denying the findings, Illies consented to the described sanction and to the entry of findings that he signed for customers on customer financial forms that he had forgotten to have them sign. The finding stated that the documents related to transactions that the customers had requested and or authorized. Illies in no way benefited financially or otherwise through the aforementioned actions. This represents the only disclosure for Patrick Illies since he began his career in financial services in April 2003. Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration Futures or Commodity Registration Neither TCRG nor any of its employees are registered representatives of a broker-dealer. Neither TCRG nor its employees are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading Material Relationships Maintained by this Advisory Business and Conflicts of Interest advisor. Recommendations or Selections of Other Investment Advisors and Conflicts of Patrick Illies has no other business activities. Interest TCRG may recommend the services of third-party money managers to manage Client accounts. In such circumstances, TCRG receives referral fees from the third-party money manager. Twin Cities Retirement Group, LLC has entered into an agreement with Steele Capital Management, Inc. (SCM), CRD#107097, a Registered Investment Advisor, for the purpose of referring Clients to SCM as an independent Referral in accordance with the provisions of Rule 206(4)-3 under the Investment Advisors Act of 1940. In consideration of such services, TCRG is compensated for services by a fee equal to 62.5% of the advisory fees collected by Steele Capital Management, Inc., for each Client referred to SCM by TCRG. TCRG is not affiliated with SCM. Each Client should review the SCM Form ADV Part 2. SCM charges a negotiable annualized fee not to exceed 1.5%. Fees are payable quarterly in advance based on the market value of the managed assets on the first day of each calendar quarter. Fees are negotiable based upon certain criteria (i.e., anticipated future earning capacity, anticipated additional assets, dollar amount of assets to be managed, historical relationships, related account, etc.) When referring Clients to a third-party money manager, the Client’s best interest will be the main determining factor of TCRG. Clients are not required to accept any recommendation of third-party money managers given by TCRG and have the option to receive investment advice through other money managers of their choosing. - 9 - Twin Cities Retirement Group, LLC  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Description The employees of TCRG have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of TCRG employees and addresses conflicts that may arise. The Code defines acceptable behavior for employees of TCRG. The Code reflects TCRG and its supervised persons’ responsibility to act in the best interest of their Client. One area the Code addresses is when employees buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow any employees to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our Clients. TCRG’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other employee, officer or director of TCRG may recommend any transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. TCRG’s Code is based on the guiding principle that the interests of the Client are our top priority. TCRG’s officers, directors, advisors, and other employees have a fiduciary duty to our Clients and must diligently perform that duty to maintain the complete trust and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of either employees or the company. to Clients, or who have access The Code applies to “access” persons. “Access” persons are employees who have access to non-public information regarding any Clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to such recommendations that are non-public. TCRG will provide a copy of the Code of Ethics to any Client or prospective Client upon Investment Recommendations Involving a Material Financial Interest and Conflict of request. Interest TCRG and its employees do not recommend to Clients securities in which we have a Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of material financial interest. Interest TCRG’s employees may buy or sell securities that are also held by Clients. To mitigate conflicts of interest such as trading ahead of Client trades, employees are required to disclose all reportable securities transactions as well as provide TCRG with copies of their brokerage statements. The Chief Compliance Officer of TCRG is Patrick Illies. He reviews all employee trades each quarter. The personal trading reviews ensure that the personal trading of employees does not affect the markets and that Clients of the firm receive preferential treatment over employee transactions. - 10 - Twin Cities Retirement Group, LLC  Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest TCRG does not maintain a firm proprietary trading account and does not have a material financial interest in any securities being recommended and therefore no conflicts of interest exist. However, employees may buy or sell securities at the same time they buy or sell securities for Clients. To mitigate conflicts of interest such as front running, employees are required to disclose all reportable securities transactions as well as provide TCRG with copies of their brokerage statements. Item 12: Brokerage Practices Factors Used to Select Broker-Dealers for Client Transactions TCRG requires that Clients establish brokerage accounts with the Schwab Institutional 2 1 division of Charles Schwab & Co., Inc. registered broker-dealer and ("Schwab"), a FINRA 3 SIPC member, to maintain custody of Clients’ assets and to effect trades for their accounts. TCRG is independently owned and operated and not affiliated with Schwab. TCRG has evaluated Schwab and believes that it will provide our Clients with a blend of execution services, commission costs and professionalism that will assist our firm in meeting our fiduciary obligations to Clients. Schwab provides TCRG with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s Clients’ assets are maintained in accounts at Schwab Institutional. These services are not contingent upon our firm committing to Schwab any specific amount of business (assets in custody or trading commissions). Schwab’s brokerage services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For our Client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions and other transaction-related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab Institutional also makes available to TCRG other products and services that benefit TCRG but may not directly benefit our Clients’ accounts. Many of these products and services may be used to service all or some substantial number of our Client accounts, including accounts not maintained at Schwab. Schwab’s products and services that assist TCRG in managing and administering our Clients’ accounts include software and other technology that: 1 2 For information regarding Schwab, please refer to their website: https://www.schwab.com/. FINRA is the largest independent regulator for all securities firms doing business in the United States. For more information, please refer to FINRA’s website: http://www.finra.org/. 3 For information regarding SIPC, please refer to their website: http://www.sipc.org/. - 11 - Twin Cities Retirement Group, LLC  • • • • • provide access to Client account data (such as trade confirmations and account statements). facilitate trade execution and allocate aggregated trade orders for multiple Client accounts. provide research, pricing, and other market data. facilitate payment of our fees from Clients’ accounts; and assist with back-office functions, recordkeeping, and Client reporting. Schwab Institutional also offers other services intended to help us manage and further develop our business enterprise. These services may include: • • • compliance, legal and business consulting. publications and conferences on practice management and business succession; and access to employee benefits providers, human capital consultants and insurance providers. Schwab may make available, arrange and/or pay third-party vendors for the types of services rendered to TCRG. Schwab Institutional may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to our firm. Schwab Institutional may also provide other benefits such as educational events or occasional business entertainment of our personnel. In evaluating whether to recommend or require that Clients custody their assets at Schwab, we may consider the availability of some of the foregoing products and services and other arrangements as part of the total mix of factors we consider and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which may create a potential conflict of interest. TCRG reserves the right to decline acceptance of any Client account for which the Client directs the use of a broker other than Schwab if we believe that this choice would hinder our fiduciary duty to the Client and/or our ability to service the account. In directing the use of Schwab (or any other broker), it should be understood that TCRG will not have authority to negotiate commissions or to necessarily obtain volume discounts, and best execution may not be achieved. In addition, a disparity in commission charges may exist between the commissions charged to the Client and those charged to other Clients (who may direct the use of another broker other than Schwab). Clients should note that, while TCRG has a reasonable belief that Schwab is able to obtain best execution and competitive prices, our firm will not independently seek best execution price capability through other Aggregating Securities Transactions for Client Accounts brokers. TCRG is authorized in its discretion to aggregate purchases and sales and other transactions made for the account with purchases and sales and transactions in the same securities for other Clients of TCRG. All Clients participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rated basis. - 12 - Twin Cities Retirement Group, LLC  Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Accounts are reviewed on a quarterly basis by Investment Advisor Representatives of Review of Client Accounts on Non-Periodic Basis TCRG. Account reviews are performed more frequently when market conditions dictate. Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, Content of Client Provided Reports and Frequency new investment information, and changes in a Client's own situation. Clients receive written account statements no less than quarterly for managed accounts. Account statements are issued by the custodian. Client receives confirmations of each transaction in account from Custodian and an additional statement during any month in which a transaction occurs. Item 14: Client Referrals and Other Compensation Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest As disclosed under Item 12 above, TCRG receives an economic benefit from Schwab in the form of the support products and services it makes available to TCRG and other independent investment advisors that have their Clients maintain accounts at Schwab. These products and services, how they benefit TCRG, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). The availability to TCRG of Schwab’s products and services is not based on TCRG giving particular investment advice, such as buying particular securities for our Clients. TCRG receives a portion of the annual management fees collected by the third-party money managers to whom TCRG refers Clients. This situation creates a conflict of interest because TCRG and/or its Investment Advisor Representative have an incentive to decide what third party money managers to use because of the higher referral fees to be received by TCRG. However, when referring Clients to a third party money manager, the Client’s best interest will be the main determining Advisory Firm Payments for Client Referrals factor of TCRG. TCRG does not compensate for Client referrals. Item 15: Custody Account Statements All assets are held at qualified custodians, which means the custodians provide account statements directly to Clients at their address of record at least quarterly. Clients are urged to compare the account statements received directly from their custodians to any performance report prepared by TCRG. TCRG is deemed to have constructive custody solely because advisory fees are directly deducted from Client’s accounts by the custodian on behalf of TCRG. - 13 - Twin Cities Retirement Group, LLC  Item 16: Investment Discretion Discretionary Authority for Trading TCRG requires discretionary authority to manage securities accounts on behalf of Clients. TCRG has the authority to determine, without obtaining specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The Client will authorize TCRG discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. TCRG allows Client’s to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar document. Such restrictions could include only allowing purchases of socially conscious investments. These restrictions must be provided to TCRG in writing. Item 17: Voting Client Securities Proxy Votes TCRG does not vote proxies on securities. Clients are expected to vote their own proxies. The Client will receive their proxies directly from the custodian of their account or from a transfer agent. When assistance on voting proxies is requested, TCRG will provide recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client. Item 18: Financial Information Balance Sheet A balance sheet is not required to be provided because TCRG does not serve as a custodian for Client funds or securities and TCRG does not require prepayment of fees of more than Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet $1200 per Client and six months or more in advance. Commitments to Clients TCRG has no condition that is reasonably likely to impair our ability to meet contractual Bankruptcy Petitions during the Past Ten Years commitments to our Clients. TCRG does not have any information to disclose. - 14 - Twin Cities Retirement Group, LLC  S U P E R V I S E D P E R S O N B R O C H U R E ITEM 1 COVER LETTER F O R M A D V P A R T 2 B Patrick Illies Office Address: th 15600 36 Ave N Suite 240 Plymouth, MN 55446 Telephone: 952-600-7550 info@twincitiesretirementgroup.com www.twincitiesretirementgroup.com A P R I L 2 0 , 2 0 2 6 This brochure supplement provides information about Patrick Illies and supplements the Twin Cities Retirement Group, LLC’s brochure. You should have received a copy of that brochure. Please contact Twin Cities Retirement Group, LLC if you did not receive the brochure or if you have any questions about the contents of this supplement. Additional information about Patrick Illies (CRD#4781988) is available on the SEC’s website at www.adviserinfo.sec.gov - 15 - Twin Cities Retirement Group, LLC  Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure Principal Executive Officer - Patrick Illies • Item 2 Educational Background and Business Experience Year of birth: 1978 • Educational Background: o University of Florida, Warrington College of Business, 05/04/2002 o Bachelor of Science in Business Administration, Major: Finance Bachelor of Science in Business Administration, Major: Management • • General Securities Representative Examination, Series 7, 04/28/2004 Uniformed Combined State Law Examination, Series 66, 10/25/2004 Professional Designations: CRPC ® sm - Chartered Retirement Planning Counselor Business Experience: Issued by: College Financial Planning Requirements: Successfully complete specialized program, pass examination, sign code of professional ethics, and complete a disclosure form attesting to professional ethics. Continuing Education: Must sign a commitment to ongoing continuing education in the area of retirement planning. • • • • • Twin Cities Retirement Group, LLC; Managing Member/Investment Advisor Representative; 09/2010 – Present Twin Cities Retirement Group, LLC; Managing Member; 04/2005 – Present Twin Cities Land Group LLC; Co-Owner; 05/2018 – 12/2019 Financial Network Investment Corp.; Registered Representative; 04/2005 – 02/2009 Citigroup Global Markets, Inc., Smith Barney; Sales Asst.; 04/2003 – 02/2005 None to report. Item 3 Disciplinary Information Criminal or Civil Action: Administrative Proceeding: Self-Regulatory Proceeding: None to report. Patrick Illies, submitted a letter of acceptance, waiver and consent in which he was barred from association from any Financial Regulatory Authority, Inc. member for nine months. (November 2009-August 2010). Without admitting or denying the findings, Illies consented to the described sanction and to the entry of findings that he signed for customers on customer financial forms that he had forgotten to have themsign. The finding stated that the documents related to transactions that the customers had requested and/or authorized. Illies in no way benefited financially or otherwise through the aforementioned actions. This represents the only disclosure for Patrick Illies Item 4 Other Business Activities since he began his career in financial services in April 2003. Patrick Illies has no other business activities to disclose. - 16 - Twin Cities Retirement Group, LLC  Item 5 Additional Compensation Item 6 Supervision Patrick Illies does not receive any additional compensation. Patrick Illies is the sole owner and Chief Compliance Officer of Twin Cities Retirement Group, LLC, he is solely responsible for all supervision and formulation and monitoring of investment advice offered to Clients. He will adhere to the policies and procedures as described in the firm’s Compliance Manual. Mr. Patrick Illies can be reached by telephone at 952-600-7550 or by email at info@twincitiesretirementgroup.com. - 17 - Twin Cities Retirement Group, LLC