WALLEM ASSOCIATES, INC.

Item 1 – Cover Page Lucas Group Financial Advisors, LLC 1753 S. West Ave Freeport, IL 61032 815-235-9610 August 20, 2025 This Brochure provides information about the qualifications and business practices of Lucas Group Financial Advisors, LLC (“LGFA or the "Firm"). If you have any questions about the contents of this Brochure, please contact us at 815-235-9610. 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. The registration of an Investment Adviser does not imply any level of skill or training. Additional information about LGFA is also available on the SEC's website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The CRD number for LGFA is 326880.  Item 2 – Material Changes This Item of the Brochure discusses only specific material changes that have been made to the Brochure since the last update and provides clients with a summary of such changes. Since the last annual updating amendment, Wallem Associates, Inc. has been acquired by Lucas Group Financial Advisors, LLC and is now doing business under the name Lucas Group Financial Advisors, LLC. Due the acquisition, there have been changes made to Items 4, 5, 7, 10, 12, 14 and 15. We will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Currently, our Brochure may be requested by contacting Katherine Downing, Chief Compliance Officer, at (815) 235-9610. Additional information about LGFA is also available via the SEC's web site www.adviserinfo.sec.gov. The SEC's web site also provides information about any persons affiliated with LGFA who are registered, or are required to be registered, as investment adviser representatives of LGFA. (Date of Brochure: 8/20/2025)  Item 3 – Table of Contents Contents Item 1 – Cover Page ................................................................................................................................ 1 Item 2 – Material Changes ...................................................................................................................... 2 Item 3 – Table of Contents ...................................................................................................................... 3 Item 4 – Advisory Business ..................................................................................................................... 4 Item 5 - Fees and Compensation ............................................................................................................ 7 Item 6 - Performance-Based Fees and Side-By-Side Management ......................................................... 10 Item 7 - Types of Clients ....................................................................................................................... 10 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss .................................................... 10 Item 9 - Disciplinary Information ........................................................................................................... 12 Item 10 - Other Financial Industry Activities and Affiliations .................................................................. 12 Item 11- Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................ 13 Item 12 - Brokerage Practices ............................................................................................................... 14 Item 13 - Review of Accounts................................................................................................................ 16 Item 14 - Client Referrals and Other Compensation .............................................................................. 17 Item 15 - Custody ................................................................................................................................. 18 Item 16 - Investment Discretion ............................................................................................................ 18 Item 17 - Voting Client Securities .......................................................................................................... 19 Item 18 - Financial Information ............................................................................................................. 19  Item 4 – Advisory Business LGFA is owned by Lucas Beggin, Katherine Downing, Andrew Stewart and Jeffery Wallem and has been providing advisory services prior to this acquisition since 2023. As of August 20, 2025, the Firm had approximately $325 million in Regulatory Assets Under Management. Investment Management Services LGFA manages investment portfolios for individuals, trusts, charitable organizations and foundations, small businesses and qualified retirement plans. LGFA will work with a client to determine the client's investment objectives and investor risk profile and will design a written investment policy statement. LGFA uses investment and portfolio allocation software to evaluate alternative portfolio designs. LGFA evaluates the client's existing investments with respect to the client's investment policy statement. LGFA works with new clients to develop a plan to transition from the client's existing portfolio to the portfolio recommended by LGFA. LGFA will then continuously monitor the client's portfolio holdings and the overall asset allocation strategy and hold review meetings with the client regarding the account as necessary. LGFA will typically create a portfolio of passive and/or evidence-based mutual funds and Exchange Traded Funds (ETFs) and will use model portfolios if the models match the client's investment policy. LGFA will allocate the client's assets among various investments taking into consideration the overall management style selected by the client. LGFA recommends mutual funds and ETFs that follow this passive/evidence-based strategy, such as Dimensional Fund Advisors (DFA), among others. Client portfolios will include, from time to time, individual equity securities in situations where disposition of these securities would present an overriding tax implication or the client specifically requests they be retained for a personal reason. These situations will be specifically identified in the client's Investment Policy Statement (IPS) or Model Allocation. LGFA manages mutual fund and equity portfolios on a discretionary or non-discretionary basis according to the investment policy selected by the client. A client is permitted to impose any reasonable restrictions on LGFA's discretionary authority including restrictions on the types of securities in which LGFA may invest client's assets and on specific securities, which the client may believe to be appropriate. LGFA also provides investment management clients with certain financial planning services. Clients may receive various written financial reports, providing the client with detailed financial information designed to achieve their stated financial goals and objectives. LGFA also offers financial planning on a fee basis with no investment management, by either a flat rate or hourly rate, situation dependent. As part of the financial planning services, clients also engage LGFA to advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts (to the extent permissible without an insurance license) and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, LGFA will  make recommendations on a non-discretionary basis for the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or custodian for the plan trustee or administrator and clients retain responsibility for effecting trades in these accounts. For unmanaged account services held at an independent and unaffiliated third-party qualified custodian, LGFA shall not provide Client investment advice, and will instead solely follow the instructions with respect to the Unmanaged Account(s) as provided by Client. LGFA shall have no discretion to act or transact for Unmanaged Clients without the verbal and/or written instructions from client. These accounts are opened solely as an accommodation to the Client. Use of Third-Party Sub-Advisers: LGFA has retained Focus Partners Advisor Solution (FPAS) to act as a sub-advisor for certain client accounts. FPAS shall provide various model asset allocation portfolios (each a "Portfolio", collectively "Portfolios") for selection by LGFA. Each Portfolio strives to achieve long-term risk and return objectives through diversification among multiple asset classes using investment options available to FPAS, which may include, but not limited to, mutual funds and/or exchange traded funds from Dimensional Fund Advisors LP, Bridgeway Capital Management, Inc., AQR Capital Management, LLC, The Vanguard Group, Inc., Stoneridge Asset Management, LLC or other providers selected by FPAS. Each Portfolio is designed to meet a particular investment goal which LGFA has determined is suitable based on the client's circumstances. Once the appropriate Portfolio(s) has been determined, the Portfolio will continuously be managed based on the portfolio's goal and FPAS will have the discretionary authority to manage the Portfolio(s), including periodically rebalancing. However, LGFA on behalf of its client, will have the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Should material life events occur, clients should immediately contact LGFA to determine if changes to an account and the allocation of the assets held in the account are necessary. LGFA may also recommend fixed income portfolios to investment management clients, which consist of managed accounts of individual bonds. LGFA will request discretionary authority from investment management clients to manage fixed income portfolios, including the discretion to retain a third-party fixed income manager. For client portfolios managed on a non-discretionary basis, client should be aware that the authority for LGFA to retain a fixed income manager is provided in the signed advisory agreement and is provided on a discretionary basis. The fixed income securities manager will be provided with the discretionary authority to invest client assets in fixed income securities consistent with the client's Investment Policy Statement. The fixed income manager will also monitor the account for changes in credit ratings, security call provisions, and tax loss harvesting opportunities (to the extent that the manager is provided with cost basis information). The fixed income manager will obtain LGFA's consent prior to the sale of any client securities. LGFA has retained SEI Private Trust Company (SEI) to act as a co-investment advisor for certain client accounts. SEI acts as a “Manager of managers,” offering different investment managers to sub-advise different asset classes. Together with SEI, LGFA will recommend portfolios to clients made up of several asset classes and sub-advisers. Each Portfolio strives to achieve long-term risk and return objectives  through diversification among multiple asset classes. The client will sign their acknowledgement of the proposed portfolio and will also sign their agreement for any portfolio/manager changes. On an ongoing basis, LGFA will answer clients' inquiries regarding their accounts and review periodically with clients the performance of their accounts. LGFA will periodically, and at least annually, review clients' investment policy, risk profile and discuss the re-balancing of each client's accounts to the extent appropriate. LGFA will provide to investment manager any updated client financial information or account restrictions necessary for investment manager to provide sub-advisory services. In addition to managing the client's investment portfolio, LGFA may consult with clients on various financial areas including income and estate tax planning, business sale structures, college financial planning, retirement planning, insurance analysis, personal cash flow analysis, establishment and design of retirement plans and trust designs, among other things. LGFA does not participate in or sponsor any wrap fee programs. Financial Planning Services: LGFA also provides advice in the form of Financial Planning to its clients. Clients may receive this service as part of the investment management services the Firm provides or as a separate service for a flat or hourly fee. Clients purchasing this service may receive various written financial reports, providing the client with detailed financial information designed to achieve their stated financial goals and objectives. In general, the financial plan will address any or all of the following areas of concern: PERSONAL: Family records, budgeting, personal liability, estate information and financial goals. RISK: Review of existing insurance policies to ensure proper coverage for life, health, disability, long-term care, liability, home, and automobile. TAX & CASH FLOW: Income tax and spending analysis and planning for past, current and future years. DEATH & DISABILITY: Cash needs at death, income needs of surviving dependents, estate planning and disability income analysis. RETIREMENT: Analysis of current strategies and investment plans to help the client achieve his or her retirement goals. INVESTMENTS: Analysis of all investment holdings and costs, examining the potential long-term effects on a client's portfolio, recommending appropriate investment options, allocations, or adjustments. LGFA gathers required information through in-depth personal interviews and questionnaires. Information gathered includes a client's current financial status, future goals and attitudes towards risk. Related documents supplied by the client are carefully reviewed and a written report is typically prepared. Should a client choose to implement the recommendations in the plan, the Firm suggests the client work closely with his/her attorney, accountant or insurance agent. Implementation of financial plan recommendations is entirely at the client's discretion. Clients are encouraged to review their plan on a regular basis, especially if there are any changes in their financial situation, goals, needs, or investment objectives.  Employee Benefit Retirement Plan Services: LGFA also provides advisory services to participant-directed employee retirement benefit plans through third-party administration services, which are online bundled service providers offering an opportunity for plan sponsors to provide their participants with daily account access, valuation, and investment education. LGFA will analyze the plan's current investment platform and assist the plan in creating an investment policy statement defining the types of investments to be offered and the restrictions that may be imposed. LGFA will recommend investment options to achieve the plan's objectives, provide participant education meetings, and monitor the performance of the plan's investment vehicles. LGFA will recommend changes in the plan's investment vehicles as may be appropriate from time to time. LGFA generally will review the plan's investment vehicles and investment policy as necessary. For certain retirement plans, LGFA also works in coordination and support with FPAS. Retirement plan clients will engage both LGFA and FPAS. FPAS will provide to the client additional discretionary investment management services and will exercise discretionary authority to select the plan investments made available to the plans' participants by selecting and maintain the plans' investments according to the goals and investment objectives of the plan. LGFA will continue to work with plans to monitor plan investments, provide fiduciary plan advice including regular considerations of the goals and objectives of the plan, and provide participant education services to the plan. Advisory Services to Brokerage Customers LGFA provides investment advisory services to certain broker-dealers’ customers (“Brokerage Customers”) who provide written consent requesting to receive the firm’s advisory services. Brokerage Customers have entered into a written advisory agreement with LGFA. Item 5 - Fees and Compensation In certain circumstances, all fees, account minimums and their applications to family circumstances may be negotiable. Advance fee payments will never exceed $500 for work that will not be completed within six months. LGFA has contracted with FPAS for services including trade processing, collection of management fees, record maintenance, report preparation, marketing assistance, and research. LGFA has also contracted with FPAS for sub-advisory services with respect to clients' accounts. LGFA pays a fee for FPAS services based on management fees paid to LGFA on accounts which use FPAS. The fee paid by LGFA to FPAS consists of a portion of the fee paid by clients to LGFA and varies based on the total client assets administered and/or sub-advised by FPAS through LGFA. These fees are not separately charged to advisory clients. The fee charged by LGFA to its clients includes all sub-advisory fees charged by FPAS. The specific manner in which fees are charged by LGFA is established in a client's written agreement with LGFA. Investment Management and Employee Benefit Plan clients will be invoiced in advance at the  beginning of each calendar quarter based upon the value (market value based on independent, third- party sources or fair market value in the absence of market value; client account balances on which LGFA calculates fees may vary from account custodial statements based on independent valuations and other accounting variances, including mechanisms for including accrued interest in account statements) of the client's account at the end of the previous quarter. New accounts are charged a prorated fee for the remainder of the quarter in which the account is incepted (date of first trade). For accounts where SEI serves as custodian, SEI will provide services including trade processing, collection of management fees, record maintenance, report preparation, marketing assistance, and research. SEI charges an additional “Management Fee” that is separate from the Advisor Fee and varies based on the client’s individual account. The “Management Fee” will be disclosed to the client on the investment proposal prior to opening an account with SEI. For purposes of calculating fees, SEI deducts fees in arrears for the previous quarter. New accounts are charged a prorated fee from inception until the next billing date. For Investment Management and Employee Benefit Plan Services, LGFA will request authority from the client to receive quarterly payments directly from the client's account held by an independent custodian. Clients may provide written limited authorization to LGFA or its designated service provider, FPAS, to withdraw fees from the account. Clients will receive custodial statements showing the advisory fees debited from their account(s). Certain third-party administrators will calculate and debit LGFA's fee and remit such fee to LGFA. A client agreement may be canceled at any time by the client for any reason. LGFA must provide 30 days written notice to terminate an agreement. Upon termination of any account, any prepaid, unearned fees will be promptly refunded. The client has the right to terminate an agreement without penalty within five business days after entering into the agreement, regardless of whether or not the disclosure information is delivered within 48 hours prior to entering the contract. LGFA's fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third party investment and other third parties such as fees charged by managers, custodial fees, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund's prospectus. These fees will generally include a management fee and other fund expenses. All fees paid to LGFA for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and ETFs to their shareholders. Such charges, fees and commissions are exclusive of and in addition to LGFA's fee, and LGFA shall not receive any portion of these commissions, fees, and costs. Advisory Services to Brokerage Customers LGFA receives an advisory fee based on the Assets Under Management from Brokerage Customers who have provided written consent to a broker-dealer to receive the investment advisory service from LGFA and have entered into a written advisory contract with LGFA. The advisory fee is calculated in advance  based on the value of the Assets Under Management from Brokerage Customers as of the end of the previous quarter. The maximum advisory fee will not exceed 1% annually. This advisory fee is paid by the broker-dealer and is not charged to the client separately. Advisory Fees The annual fee for investment management services will be charged as a percentage of assets under management, according to the schedule on the client’s personal Advisory Agreement. LGFA’s standard fee schedule is: Assets Under Management $0 - $499,999.99 $500,000 - $999,999.99 $1,000,000.00 - $1,999,999.99 $2,000,000.00 - $2,999,999.99 $3,000,000.00 - $3,999,999.99 $4,000,000 and above Annual Fee (%) 1.25% 1.0% 0.90% 0.80% 0.70% .60% LGFA has a minimum account size requirement of $300,000 for investment advisory services, which is negotiable. All accounts for members of the client's family (husband, wife and dependent children) or related businesses may be assessed fees based on the total balance of all accounts. Fees for variable annuity management and management of accounts held directly at American Funds differ from our standard fee schedule and are defined within the clients investment management agreement. Our fees for Nationwide, Jackson, and Lincoln annuity accounts will be a flat 1%. American Funds accounts will be defined in their own fee schedule. These fees reflect the investment restrictions and limitations present in those type of arrangements. Employee Benefit Retirement Plan Services The annual fee for plan service will be charged as a percentage of assets within the plan charged to plans, or participants, as defined by the plan documents. Should sponsors wish to utilize services from FPAS, the following is the fee schedule for Retirement plan clients engaging both LGFA and FPAS shall apply. Assets Under Management On the first $1,000,000.00 $1,000,000.01 to $5,000,000.00 $5,000,000.01 to $10,000,000.00 $10,000,000.01 and above FPAS’ Annual Fee 0.20% 0.15% 0.08% 0.05% LGFA’s Annual Fee 0.50% 0.40% 0.25% 0.15% Financial Planning Services:  LGFA's Financial Planning fees are determined based on the nature of the services being provided and the complexity of each client's circumstances. All fees are agreed upon prior to entering into a contract with any client. Financial planning fees will be charged in one of two ways: On an hourly basis ranging from $300 to $600 per hour. As a fixed fee, typically ranging from $3,000 to $25,000 depending on the nature and complexity of the engagement, the number of financial planning topic analysis areas requested by the Client, the number of hours to complete the engagement and the different reports to be produced. Fixed fees shall be mutually agreed upon with Client. An estimate for total hours may be determined at the start of the advisory relationship. 50% of the estimated fee may be due upon signing the advisory agreement, with the balance due upon presentation of the plan to the client. LGFA will never hold client funds greater than $500 for more than six months in advance of completion of the financial plan. Item 6 - Performance-Based Fees and Side-By-Side Management LGFA does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). All fees are calculated as described above and are not charged on the basis of income or capital gains or capital appreciation of the funds or any portion of the funds of an advisory client. Item 7 - Types of Clients LGFA provides services to individuals, trusts, charitable organizations, foundations, and broker dealers. LGFA generally requires a minimum account size of $300,000 for Investment Management Services. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategy LGFA's services are based on long-term investment strategies incorporating the principles of Modern Portfolio Theory. LGFA's investment approach is firmly rooted in the belief that markets are "efficient" over periods of time and that investors' long-term returns are determined principally by asset allocation decisions, rather than market timing or stock picking. LGFA recommends diversified portfolios, principally through the use of passively managed, asset class mutual funds. LGFA selects or recommends to clients portfolios of securities, principally broadly-traded open end mutual funds or conservative fixed income securities to implement this investment strategy. Although all investments involve risk, LGFA's investment advice seeks to limit risk through broad diversification among asset classes and, as appropriate for particular clients, the investment directly in conservative fixed income securities to represent the fixed income class. LGFA's investment philosophy  is designed for investors who desire a buy and hold strategy. Frequent trading of securities increases brokerage and other transaction costs that LGFA's strategy seeks to minimize. In the implementation of investment plans LGFA primarily uses mutual funds, ETF's and, as appropriate, portfolios of conservative fixed income securities. Clients may hold or retain other types of assets as well, and seek advice from LGFA regarding those various assets as part of its services. Advice regarding such assets will be general in nature and will not typically involve asset management services. LGFA's strategies do not utilize securities that would be classified as having any unusual risks and do not recommend frequent trading, which can increase brokerage and other costs and taxes. LGFA receives supporting research from FPAS and from other consultants, including economists affiliated with Dimensional Fund Advisors ("DFA"). LGFA utilizes DFA mutual funds in client portfolios, as well as other mutual fund managers. DFA mutual funds follow a passive asset class investment philosophy with low holdings turnover. Both DFA and FPAS provide historical market analysis, risk/return analysis, and continuing education to LGFA. Analysis of a Client's Financial Situation In the development of investment plans for clients, including the recommendation of an appropriate asset allocation, LGFA relies on an analysis of the client's financial objectives, current and estimated future resources, and tolerance for risk. To derive a recommended asset allocation, LGFA at times will use Monte Carlo simulation, a standard statistical approach for dealing with uncertainty. As with any other methods used to make projections into the future, there are several risks associated with this method, which may result in the client not being able to achieve their financial goals. They include: • The risk that expected future cash flows will not match those used in the analysis • The risk that future rates of return will fall short of the estimates used in the simulation • The risk that inflation will exceed the estimates used in the simulation • For taxable clients, the risk that tax rates will be higher than was assumed in the analysis Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. All investments present the risk of loss of principal - the risk that the value of securities (mutual funds, ETFs and individual bonds) when sold or otherwise disposed of, may be less than the price paid for the securities. Even when the value of the securities when sold is greater than the price paid, there is the risk that the appreciation will be less than inflation. In other words, the purchasing power of the proceeds may be less than the purchasing power of the original investment. The mutual funds and ETFs utilized by LGFA include funds invested in domestic and international equities, including real estate investment trusts (REITs), corporate and government fixed income securities and commodities. Equity securities include large capitalization, medium capitalization and small capitalization stocks. Mutual funds and ETF shares invested in fixed income securities are subject to the same interest rate, inflation and credit risks associated with the underlying bond holdings.  Among the riskiest mutual funds used in LGFA's investment strategies funds are the U.S. and International small capitalization and small capitalization value funds, emerging markets funds, and commodity futures funds. Conservative fixed income securities have lower risk of loss of principal, but most bonds (with the exception of Treasury Inflation Protected Securities, or TIPS) present the risk of loss of purchasing power through lower expected return. This risk is greatest for longer-term bonds. Certain funds utilized by LGFA contain international securities. Investing outside the United States involves additional risks, such as currency fluctuations, periods of illiquidity and price volatility. These risks increase with investments in developing countries. The risk of loss described herein should not be considered to be an exhaustive list of all the risks which clients should consider. Item 9 - Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of LGFA or the integrity of LGFA's management. LGFA has no information applicable to this Item. Item 10 - Other Financial Industry Activities and Affiliations Focus Partners Advisor Solutions As described above in Item 4, LGFA exercises discretionary authority provided by a client to select an independent third-party investment manager for the management of portfolios of securities. LGFA selects FPAS for such sub-advisory management. LGFA also contracts with FPAS for back office services and assistance with portfolio modeling. LGFA has a fiduciary duty to select qualified and appropriate managers in the client's best interest and believes that FPAS effectively provides both the back-office services that assist with its overall investment advisory practice and sub-advisory services. The management of LGFA continuously analyzes and assesses the use of FPAS in this capacity. While LGFA has a contract with FPAS governing a time period for back-office services, LGFA has no such fixed commitment to the selection of FPAS for sub-advisory services and utilize other investment managers for clients upon reasonable notice to FPAS. Individual Insurance License Some of LGFA Associate's Investment Advisor Representatives, in their individual capacity, are licensed insurance agents and are therefore able to recommend and sell insurance products to the Firm's clients. These individuals can receive commissions in connection with the sale of insurance product transactions to the Firm's advisory clients. Clients are not under any obligation to engage these individuals when considering the implementation of insurance recommendations. The implementation of any and all recommendations is solely at the discretion of the client. While these individuals endeavor at all times to put the interest of the clients first as part of LGFA's fiduciary duty, clients should be aware that the receipt of additional compensation itself creates a conflict of interest and may affect the judgment of this individual when making recommendations.  Advisory Services to Brokerage Customers LGFA has agreement(s) with broker-dealers to provide investment advisory services to Brokerage Customers. Broker-dealers pay compensation to LGFA for providing investment advisory services to Customers. Brokerage Customers will execute a written advisory agreement directly with LGFA. This relationship presents conflicts of interest. Potential conflicts are mitigated by Brokerage Customers consenting to receive investment advisory services from LGFA; by LGFA not accepting or billing for additional compensation on broker-dealers’ Assets Under Management beyond the advisory fees disclosed in Item 5; and by LGFA not engaging as, or holding itself out to the public as, a securities broker- dealer. LGFA is not affiliated with any broker-dealer. Item 11- Code of Ethics, Participation or Interest in Client Transactions and Personal Trading LGFA has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of business conduct, and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at LGFA must acknowledge the terms of the Code of Ethics annually, or as amended. LGFA or individuals associated with LGFA are permitted to buy or sell securities identical to those recommended to customers for their personal accounts. In addition, any related person(s) may have an interest or position in a certain security(ies) which may also be recommended to a client. It is the expressed policy of LGFA that no person employed by LGFA will take inappropriate advantage of their positions, and the interests of client accounts will be placed first at all times. LGFA anticipates that, in appropriate circumstances, consistent with clients' investment objectives, it will cause accounts over which LGFA has management authority to effect, and will recommend to investment advisory clients or prospective clients, the purchase or sale of securities in which LGFA, its affiliates and/or clients, directly or indirectly, have a position of interest. LGFA's employees and persons associated with LGFA are required to follow LGFA's Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors and employees of LGFA and its affiliates at times trade for their own accounts in securities which are recommended to and/or purchased for LGFA's clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of LGFA will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code, certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of LGFA's clients. In addition, the Code requires pre-clearance of certain transactions. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as  clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between LGFA and its clients. LGFA will provide a complete copy of its Code of Ethics to any client or prospective client upon request. It is LGFA's policy that the firm will not affect any principal or agency cross securities transactions for client accounts. LGFA will also not cross trades between client accounts. Principal transactions are generally defined as transactions where an advisor, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. A principal transaction would also be deemed to have occurred if a security is crossed between an affiliated private fund and another client account. An agency cross transaction is defined as a transaction where a person acts as an investment advisor in relation to a transaction in which the investment advisor, or any person controlled by or under common control with the investment advisor, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions arise in situations where an advisor is dually registered as a broker-dealer or has an affiliated broker-dealer. Item 12 - Brokerage Practices LGFA arranges for the execution of securities transactions with the operational assistance of FPAS. Through FPAS, LGFA participates in the Schwab Advisor Services (SAS) services program offered to independent investment advisors by Charles Schwab & Company, Inc., ("Schwab"). Schwab is an unaffiliated SEC-registered broker dealer and FINRA member broker dealer. LGFA also utilizes the brokerage and clearing services of Pershing Investment Manager Services ("Pershing"), Fidelity Investments (Fidelity), SEI Private Trust Company (SEI), and American Funds & Trusts, Inc. ("American Funds") for investment management accounts. Pershing and American Funds are members of SIPC and are unaffiliated registered broker-dealers and FINRA member broker-dealers. Each broker-dealer offers to independent advisers' certain services which include custody of securities, trade execution, clearance and settlement transactions. Though LGFA recommends brokers with which FPAS has negotiated pricing on behalf of our clients, LGFA does not have discretionary authority to select brokers. We endeavor to recommend broker-dealers that will provide the best services at rates lower than or equivalent to industry standards. The reasonableness of rates is based on the brokers' ability to provide professional services, competitive commission rates, research and other services that will help our firm provide investment management services to clients. Schwab, Pershing, Fidelity, and SEI’s and American Funds' brokerage programs will generally be recommended to advisory clients for the execution of mutual fund and equity securities transactions. LGFA regularly reviews these programs to ensure that recommendations are consistent with its fiduciary duty. These trading platforms are essential to LGFA's service arrangements and capabilities, and LGFA reserves the ability to not accept clients who direct the use of other brokers. As part of these programs, LGFA receives benefits that it would not receive if it did not offer investment advice (See the disclosure under Item 14 of this Brochure).  As LGFA will not request the discretionary authority to determine the broker dealer to be used or the commission rates to be paid for mutual fund and equity securities transactions, clients must direct LGFA as to the broker dealer to be used. In directing the use of a particular broker or dealer, it should be understood that LGFA will not have authority to negotiate commissions among various brokers or obtain volume discounts, and best execution may not be achieved. Not all investment advisers require clients to direct the use of specific brokers. LGFA will not exercise authority to arrange client transactions in fixed income securities. Clients will provide this authority to a fixed income manager retained by LGFA on client's behalf by designating the portfolio manager with trading authority over client's brokerage account. Clients will be provided with the Disclosure Brochure (Form ADV Part 2) of portfolio manager. Schwab, Fidelity, SEI, and Pershing do not generally charge clients a custody fee and are compensated by account holders through commissions or other transaction-related fees for securities trades that are executed through the broker or that settle into the clients' accounts at the broker. Trading client accounts through other brokers at times will result in fees (including mark-ups and mark-downs) being charged by the custodial broker and an additional broker. While LGFA will not arrange transactions through other brokers, the authority of the fixed income portfolio manager includes the ability to trade client fixed income assets through other brokers. LGFA also does not have any arrangements to compensate any broker dealer for client referrals. When trading client accounts, errors periodically occur. LGFA does not maintain any client trade error gains. LGFA makes client whole with respect to any trade error losses incurred by client and caused by LGFA. LGFA generally does not aggregate any client transactions in mutual fund or other securities. Client accounts are individually reviewed and managed, and transaction costs are not saved by aggregating orders in almost all circumstances in which LGFA arranges transactions. FPAS, in the management of fixed income portfolios, will aggregate certain transactions among client accounts that it manages, in which case a LGFA client's order may be aggregated with an order for another client of FPAS who is not a LGFA client. See FPAS's Form ADV Part 2. Employee Benefit Plan Services For non-pooled employee benefit plans, LGFA does not arrange for the execution of securities transactions for plans as a part of this service. Transactions are executed directly through employee plan participation. Financial Planning Services LGFA’sfinancial planning practice, due to the nature of its business and client needs, does not include blocking trades, negotiating commissions with broker dealers or obtaining volume discounts, nor necessarily obtaining the best price. Clients will be required to select their own broker dealers and insurance companies for the implementation of financial planning recommendations. The Firm can  recommend any one of several brokers. LGFA's clients must independently evaluate these brokers before opening an account. The factors considered by LGFA when making this recommendation are the broker's ability to provide professional services, LGFA's experience with the broker, the broker's reputation, and the broker's financial strength, among other factors. LGFA’s financial planning clients may use any broker or dealer of their choice. Item 13 - Review of Accounts Reviews Investment Management Services: Account assets are supervised continuously and formally reviewed at least annually by Kate Downing, Chief Compliance Officer. The review process contains each of the following elements: • assessing client goals and objectives; • evaluating the employed strategy(ies); • monitoring the portfolio(s); and • addressing the need to rebalance. Additional account reviews can be triggered by any of the following events: • a specific client request; • a change in client goals and objectives; • an imbalance in a portfolio asset allocation; and • market/economic conditions. For fixed income portfolios, certain account review responsibilities are delegated to a third-party investment manager as described above in Item 4. Employee Benefit Plan Services: Retirement plan assets are reviewed no more than quarterly, and according to the standards and situations described above for investment management accounts. Reports Investment Management Services: Clients will receive at least quarterly statements from their account custodian, which will outline the client's current positions and current market value. Clients may also receive quarterly reports prepared by FPAS or by SEI, if using their services, or upon request from the Firm.  Employee Benefit Plan Services: Plan sponsors are provided with quarterly information and annual performance reviews from LGFA. In addition, plan participant education information will also be provided to the Plan Sponsor or Administrator for distribution to the participants of the plan at their request. Financial Planning Services Financial Planning clients will receive reports at the conclusion of the financial planning work performed per the client's agreement with LGFA. Item 14 - Client Referrals and Other Compensation Client Referrals LGFA does not compensate, either directly or indirectly, any person (defined as a natural person or a company) for client referrals. Other Compensation As indicated under the disclosure for Item 12, Schwab, Pershing and Fidelity respectively provide LGFA with access to services which are not available to retail investors. These services generally are available to independent investment advisors on an unsolicited basis at no charge to them. These services are not related to or based upon any client securities transactions or order flow to the broker. These services benefit LGFA but may not benefit its clients' accounts. Many of the products and services assist LGFA in managing and administering clients' accounts. These include software and other technology that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of LGFA's fees from its clients' accounts, and assist with back-office functions, recordkeeping and client reporting. Many of these services are generally used to service all or a substantial number of LGFA's accounts. Recommended brokers also make available to LGFA other services intended to help LGFA manage and further develop its business enterprise. These services include consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, and marketing. LGFA does not, however, enter into any commitments with the brokers for transaction levels in exchange for any services or products from brokers. While as a fiduciary, LGFA endeavors to act in its clients' best interests, LGFA's requirement that clients maintain their assets in accounts at Schwab or Pershing is based, in part, on the benefit to LGFA of the availability of some of the foregoing products and services and not solely on the nature, cost or quality of custody and brokerage services provided by the brokers, which creates a conflict of interest. LGFA also receives software from FPAS which LGFA utilizes in forming asset allocation strategies and producing performance reports. FPAS also provides continuing education for LGFA personnel. These services are designed to assist LGFA plan and design its services for business growth.  Item 15 - Custody Custody is defined under Rule 206(4)-2 of the Advisors Act {Custody Rule") generally as holding, having legal control over or having authority to access or instruct a qualified custodian to withdraw funds or securities of advisory clients. When you establish a relationship with our Firm for investment management services, your assets will be maintained by a bank, broker-dealer, mutual fund transfer agent or other such institution deemed a 'qualified custodian' by the SEC. LGFA relies on the custodian to price and value assets, execute and clear transactions, maintain custody of your account and perform other custodial functions. LGFA does not maintain physical possession of any client account assets. Clients' assets must be held by a bank, broker-dealer, mutual fund transfer agent, or other such institution deemed a qualified custodian. LGFA uses Charles Schwab, Pershing, Fidelity, SEI and American Funds as the qualified custodians for client accounts. For fee-based annuities, LGFA may use Nationwide, Jackson, or Lincoln. The Firm is considered to have limited custody due to automatic fee deduction. In order to prevent LGFA from being deemed as maintaining custody of portfolio management client assets, LGFA will ensure the following: a) LGFA will provide a copy of its fee invoice to the custodian at the same time it sends a copy to the client; b) LGFA has a reasonable belief that the account custodian sends at least quarterly statements directly to the client showing all disbursements from the custodial account, including LGFA's advisory fee. Clients provide written authorization for LGFA to deduct advisory fees from the custodial accounts in the client advisory agreement. LGFA urges you to carefully review such statements and compare such official custodial records to the account statements that we provide to you. Our statements at times will vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. LGFA also has custody over client assets due to the authority granted by clients via an executed standing letter of authorization (SLOA), for the Firm to instruct the custodian to transfer assets to client designated third-party accounts. Additionally, as required by the Custody Rule, and the SEC's February 2017 no- action letter, LGFA works with the qualified custodians to keep certain records of client accounts with SLOA instructions. The Firm does not obtain a custody audit with respect to the SLOAs as it relies on the no action relief in the SEC's February 2017 letter. Item 16 - Investment Discretion LGFA requests that it be provided with written authority to determine which securities and the amounts of securities that are bought or sold. For sub-advisory services, this authority will include the discretion to retain a third-party money manager. Any limitations on this discretionary authority shall be included in this written authority statement. Clients may change/amend these limitations as required. Such amendments shall be submitted in writing.  When selecting securities and determining amounts, LGFA observes the investment policies, limitations and restrictions of the clients for which it advises. Investment guidelines and restrictions must be provided to LGFA in writing. Item 17 - Voting Client Securities Proxy Voting: As a matter of firm policy and practice, LGFA does not accept the authority to and does not vote proxies on behalf of advisory client. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Clients will receive applicable proxies directly from the issuer of securities held in clients' investment portfolios. LGFA, however, will provide advice to clients regarding the clients' voting of proxies at their request. Class Actions, Bankruptcies and Other Legal Proceedings: Clients should note that LGFA will neither advise nor act on behalf of the client in legal proceedings involving companies whose securities are held or previously were held in the client's account(s), including, but not limited to, the filing of "Proofs of Claim" in class action settlements. If desired, clients may direct LGFA to transmit copies of class action notices to the client or a third party. Upon such direction, LGFA will make commercially reasonable efforts to forward such notices in a timely manner. Item 18 - Financial Information Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about LGFA's financial condition. LGFA has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of bankruptcy proceedings. LGFA does not require or solicit payment of more than $500 in fees per client, six months or more in advance.