WOLD FINANCIAL GROUP LLC

Form ADV Part 2A: Firm Brochure Item 1 – Cover Page Wold Financial Group LLC 750 Main Street, Suite 109 Mendota Heights, MN 55118 612-347-7825 www.woldgroup.com Date of Disclosure Brochure: March 18, 2025 ____________________________________________________________________________________ This disclosure brochure provides information about the qualifications and business practices of Wold Financial Group LLC (also referred to as we, us and Wold Financial Group throughout this disclosure brochure). If you have any questions about the contents of this disclosure brochure, please contact Stephanie Wright at 612-347-7825 or swright@woldgroup.com. The information in this disclosure brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. information about Wold Financial Group is also available on the Additional Internet at www.adviserinfo.sec.gov. You can view our firm’s information on this website by searching for Wold Financial Group LLC or our firm’s CRD number 316409. *Registration as an investment adviser does not imply a certain level of skill or training. Wold Financial Group LLC Page 1 Form ADV Part 2A Firm Brochure  Item 2 – Material Changes Since our most recent required annual amendment was submitted on March 18, 2025 there have been no material changes have been made to this disclosure brochure: There were no material changes. We will ensure that you receive a summary of any material changes to this and subsequent disclosure brochures within 120 days after our firm’s fiscal year ends. Our firm’s fiscal year ends on December 31, so you will receive the summary of material changes no later than April 30 each year. At that time we will also offer or provide a copy of the most current disclosure brochure. We may also provide other ongoing disclosure information about material changes as necessary. Wold Financial Group LLC Page 2 Form ADV Part 2A Firm Brochure  Item 3 – Table of Contents Item 1 – Cover Page ..................................................................................................................................... 1 Item 2 – Material Changes ............................................................................................................................ 2 Item 3 – Table of Contents ............................................................................................................................ 3 Item 4 – Advisory Business ........................................................................................................................... 4 Introduction................................................................................................................................................ 4 Description of Advisory Services .............................................................................................................. 4 Limits Advice to Certain Types of Investments ......................................................................................... 5 Tailor Advisory Services to Individual Needs of Clients ............................................................................ 5 Client Assets Managed by Wold Financial Group..................................................................................... 6 Item 5 – Fees and Compensation ................................................................................................................. 6 Asset Management Services .................................................................................................................... 6 Consulting Services .................................................................................................................................. 7 Item 6 – Performance-Based Fees and Side-By-Side Management ............................................................ 7 Item 7 – Types of Clients .............................................................................................................................. 7 Minimum Investment Amounts Required .................................................................................................. 8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................... 8 Methods of Analysis .................................................................................................................................. 8 Investment Strategies ............................................................................................................................... 9 Primarily Recommend One Type of Security ............................................................................................ 9 Risk of Loss ............................................................................................................................................... 9 Item 9 – Disciplinary Information ................................................................................................................. 10 Item 10 – Other Financial Industry Activities and Affiliations ...................................................................... 10 Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading ............................... 11 Code of Ethics Summary ........................................................................................................................ 11 Affiliate and Employee Personal Securities Transactions Disclosure .................................................... 11 Item 12 – Brokerage Practices .................................................................................................................... 12 Brokerage Recommendations................................................................................................................. 12 Directed Brokerage ................................................................................................................................. 13 Soft Dollar Benefits ................................................................................................................................. 14 Block Trading Policy ................................................................................................................................ 14 Agency Cross Transactions .................................................................................................................... 14 Item 13 – Review of Accounts..................................................................................................................... 14 Account Reviews and Reviewers ............................................................................................................ 14 Statements and Reports ......................................................................................................................... 14 Item 14 – Client Referrals and Other Compensation .................................................................................. 15 Item 15 – Custody ....................................................................................................................................... 15 Item 16 – Investment Discretion ................................................................................................................. 16 Item 17 – Voting Client Securities ............................................................................................................... 16 Item 18 – Financial Information ................................................................................................................... 17 Customer Privacy Policy Notice .................................................................................................................. 17 Business Continuity Plan ............................................................................................................................ 18 Wold Financial Group LLC Page 3 Form ADV Part 2A Firm Brochure  Item 4 – Advisory Business Wold Financial Group is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”) and is a limited liability company (LLC) formed under the laws of the State of Minnesota. • Ryan Wold is the Managing Member and majority owner of Wold Financial Group. Introduction The investment advisory services of Wold Financial Group are provided to you through an appropriately licensed individual who is an investment adviser representative of Wold Financial Group (referred to as your investment adviser representative throughout this brochure). Description of Advisory Services The following are descriptions of the primary advisory services of Wold Financial Group. Please understand that a written agreement, which details the exact terms of the service, must be signed by you and Wold Financial Group before we can provide you the services described below. Asset Management Services – Wold Financial Group offers asset management services, which involves Wold Financial Group providing you with continuous and ongoing supervision over your specified accounts. You must appoint our firm as your investment adviser of record on specified accounts (collectively, the “Account”). The Account consists only of separate account(s) held by qualified custodian(s) under your name. The qualified custodians maintain physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account. The Account is managed by us based on your financial situation, investment objectives and risk tolerance. We actively monitor the Account and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Account. We will need to obtain certain information from you to determine your financial situation and investment objectives. You will be responsible for notifying us of any updates regarding your financial situation, risk tolerance or investment objective and whether you wish to impose or modify existing investment restrictions; however we will contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance or investment objectives. We are always reasonably available to consult with you relative to the status of your Account. You have the ability to impose reasonable restrictions on the management of your accounts, including the ability to instruct us not to purchase certain securities. It is important that you understand that we manage investments for other clients and may give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you or actions taken for you. We are not obligated to buy, sell or recommend to you any security or other investment that we may buy, sell or recommend for any other clients or for our own accounts. Wold Financial Group LLC Page 4 Form ADV Part 2A Firm Brochure  Conflicts may arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed to be appropriate for your account(s) and other accounts advised by our firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit. Consulting Services We offer consultations in order to discuss financial planning issues when you do not need a written financial plan. We offer a one-time consultation, which covers mutually agreed upon areas of concern related to investments or financial planning. We also offer “as-needed” consultations, which are limited to consultations in response to a particular investment or financial planning issue raised or request made by you. Under an “as-needed” consultation, it will be incumbent upon you to identify those particular issues for which you are seeking our advice or consultation on. Our consulting services do not involve implementing any transaction on your behalf or the active and ongoing monitoring or management of your investments or accounts. You have the sole responsibility for determining whether to implement our consulting recommendations. Limits Advice to Certain Types of Investments Wold Financial Group provides investment advice on the following types of investments: • Mutual Funds • Exchange Traded Funds (ETFs) • Exchange-listed Securities • Corporate Debt Securities • Municipal Securities Although we generally provide advice only on the products previously listed, we reserve the right to offer advice on any investment product that may be suitable for each client’s specific circumstances, needs, goals and objectives. It is not our typical investment strategy to attempt to time the market, but we may increase cash holdings modestly as deemed appropriate based on your risk tolerance and our expectations of market behavior. We may modify our investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.) Tailor Advisory Services to Individual Needs of Clients Wold Financial Group LLC Page 5 Form ADV Part 2A Firm Brochure  Wold Financial Group’s advisory services are always provided based on your individual needs. This means, for example, that when we provide asset management services, you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. Our consulting services are always provided based on your individual needs. When providing consulting services, we work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. We will not enter into an investment adviser relationship with a prospective client whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. Client Assets Managed by Wold Financial Group As of December 31, 2024, Wold Financial Group managed $172,468,251 of client assets; $172,468,251 is managed on a discretionary basis and $0 is managed on a non- discretionary basis. Item 5 – Fees and Compensation In addition to the information provided in Item 4 – Advisory Business, this section provides additional details regarding our firm’s services along with descriptions of each service’s fees and compensation arrangements. It should be noted that lower fees for comparable service may be available from other sources. The exact fees and other terms will be outlined in the agreement between you and Wold Financial Group. Asset Management Services Fees charged for our asset management services are charged based on a percentage of assets under management, billed in advance on a quarterly calendar basis and calculated based on daily average balance of your account as of the last business day of the previous billing period. Fees are prorated (based on the number of days service is provided during the initial billing period) for your account opened at any time other than the beginning of the billing period. If asset management services are commenced in the middle of the billing period, then the prorated fee for that billing period will be billed in advance at the beginning of that billing period. The asset management services continue in effect until terminated by either party (i.e., Wold Financial Group or you) by providing written notice of termination to the other party. When fees are billed in advance, Wold Financial Group will prorate the final fee payment based on the number of days services are provided during the final period. The amount of client assets on the termination date will be used to determine the final fee payment. Fees charged for our asset management services are negotiable based on the type of client, the complexity of the client's situation, the composition of the client's account (i.e., equities versus mutual funds), the potential for additional account deposits, the relationship of the client with the investment adviser representative, and the total amount of assets under management for the client. The annual fee for asset management services will range between 0.50% and 1.25%. Wold Financial Group LLC Page 6 Form ADV Part 2A Firm Brochure  The asset management fee to be charged will be specified in your client agreement. Wold Financial Group believes that its annual fee is reasonable in relation to: (1) services provided and (2) the fees charged by other investment advisers offering similar services/programs. However, our annual investment advisory fee may be higher than that charged by other investment advisers offering similar services/programs. In addition to our compensation, you may also incur charges imposed at the mutual fund level (e.g., advisory fees and other fund expenses). The investment advisory fees can be deducted from your account and paid directly to our firm by the qualified custodian(s) of your account. When you have the investment advisory fees deducted from your account, you must authorize the qualified custodian(s) of your account to deduct fees from your account and pay such fees directly to Wold Financial Group. You should review your account statements received from the qualified custodian(s) and verify that appropriate investment advisory fees are being deducted. The qualified custodian(s) will not verify the accuracy of the investment advisory fees deducted. Brokerage expenses and/or transaction fees charged by the qualified custodian are billed directly to you by the qualified custodian. Wold Financial Group does not receive any portion of such commissions or fees from you or the qualified custodian. In addition, you will incur certain charges imposed by third parties other than Wold Financial Group in connection with investments made through your account including, but not limited to, mutual fund sales loads, 12(b)-1 fees and surrender charges, variable annuity fees and surrender charges, IRA and qualified retirement plan fees, and charges imposed by the qualified custodian(s) of your account. Management fees charged by Wold Financial Group are separate and distinct from the fees and expenses charged by investment company securities that may be recommended to you. A description of these fees and expenses are available in each investment company security’s prospectus. Consulting Services Consulting services are provided to asset management clients of Wold Financial Group without an additional charge. Item 6 – Performance-Based Fees and Side-By-Side Management Performance-based fees are defined as fees based on a share of capital gains on or capital appreciation of the assets held in a client’s account. Item 6 is not applicable to this Disclosure Brochure because we do not charge or accept performance-based fees. Item 7 – Types of Clients Wold Financial Group generally provides investment advice to the following types of clients: Wold Financial Group LLC Page 7 Form ADV Part 2A Firm Brochure  Individuals • • High net worth individuals • Trusts, estates, or charitable organizations • Corporations or business entities other than those listed above You are required to execute a written agreement with Wold Financial Group specifying the particular advisory services in order to establish a client arrangement with Wold Financial Group. Minimum Investment Amounts Required There are no minimum investment amounts or conditions required for establishing an account managed by Wold Financial Group. However, all clients are required to execute an agreement for services in order to establish a client arrangement with Wold Financial Group. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Wold Financial Group uses the following methods of analysis in formulating investment advice: Fundamental – This is a method of evaluating a security by attempting to measure its intrinsic value by examining related economic, financial and other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect the security's value, including macroeconomic factors (like the overall economy and industry conditions) and individually specific factors (like the financial condition and management of a company). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security's current price in hopes of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short). Fundamental analysis is considered to be the opposite of technical analysis. Fundamental analysis is about using real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be used for just about any type of security. The risk associated with fundamental analysis is that it is somewhat subjective. While a quantitative approach is possible, fundamental analysis usually entails a qualitative assessment of how market forces interact with one another in their impact on the investment in question. It is possible for those market forces to point in different directions, thus necessitating an interpretation of which forces will be dominant. This interpretation may be wrong, and could therefore lead to an unfavorable investment decision. Technical – This is a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security's intrinsic value, but instead use charts and other tools to identify patterns that can suggest future activity. Technical analysts believe that the historical performance of stocks and markets are indications of future performance. Technical analysis is even more subjective than fundamental analysis in that it relies on proper interpretation of a given security's price and trading volume data. A decision might be made Wold Financial Group LLC Page 8 Form ADV Part 2A Firm Brochure  based on a historical move in a certain direction that was accompanied by heavy volume; however, that heavy volume may only be heavy relative to past volume for the security in question, but not compared to the future trading volume. Therefore, there is the risk of a trading decision being made incorrectly since future trading volume is an unknown. Technical analysis is also done through observation of various market sentiment readings, many of which are quantitative. Market sentiment gauges the relative degree of bullishness and bearishness in a given security, and a contrarian investor utilizes such sentiment advantageously. When most traders are bullish, then there are very few traders left in a position to buy the security in question, so it becomes advantageous to sell it ahead of the crowd. When most traders are bearish, then there are very few traders left in a position to sell the security in question, so it becomes advantageous to buy it ahead of the crowd. The risk in utilization of such sentiment technical measures is that a very bullish reading can always become more bullish, resulting in lost opportunity if the money manager chooses to act upon the bullish signal by selling out of a position. The reverse is also true in that a bearish reading of sentiment can always become more bearish, which may result in a premature purchase of a security. There are risks involved in using any analysis method. Investment Strategies Wold Financial Group uses the following investment strategies when managing client assets and/or providing investment advice: Tactical asset allocation. Allows for a range of percentages in each asset class (such as Stocks = 40-50%). The ranges establish minimum and maximum acceptable percentages that permit the investor to take advantage of market conditions within these parameters. Thus, a minor form of market timing is possible, since the investor can move to the higher end of the range when stocks are expected to do better and to the lower end when the economic outlook is bleak. Strategic asset allocation. Calls for setting target allocations and then periodically rebalancing the portfolio back to those targets as investment returns skew the original asset allocation percentages. The concept is akin to a “buy and hold” strategy, rather than an active trading approach. Of course, the strategic asset allocation targets may change over time as the client’s goals and needs change and as the time horizon for major events such as retirement and college funding grow shorter. Primarily Recommend One Type of Security We do not primarily recommend one type of security to clients. Instead, we recommend any product that may be suitable for each client relative to that client’s specific circumstances and needs. Risk of Loss Past performance is not indicative of future results. Therefore, you should never assume that future performance of any specific investment or investment strategy will be profitable. Investing in securities (including stocks, mutual funds, and bonds, etc.) involves risk of loss. Further, depending on the different types of investments there may be varying degrees of risk. You should be prepared to bear investment loss including loss of original principal. Wold Financial Group LLC Page 9 Form ADV Part 2A Firm Brochure  Because of the inherent risk of loss associated with investing, our firm is unable to represent, guarantee, or even imply that our services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. There are certain additional risks associated with investing in securities through our investment management program, as described below: • Market Risk – Either the stock market as a whole, or the value of an individual company, goes down resulting in a decrease in the value of client investments. This is also referred to as systemic risk. • Equity (stock) market risk – Common stocks are susceptible to general stock market fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change. If you held common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater risk than if you held preferred stocks and debt obligations of the issuer. • Company Risk. When investing in stock positions, there is always a certain level of company or industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk and can be reduced through appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. • Fixed Income Risk. When investing in bonds, there is the risk that the issuer will default on the bond and be unable to make payments. Further, individuals who depend on set amounts of periodically paid income face the risk that inflation will erode their spending power. Fixed-income investors receive set, regular payments that face the same inflation • ETF and Mutual Fund Risk – When investing in an ETF or mutual fund, you will bear additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds. You will also incur brokerage costs when purchasing ETFs. • Management Risk – Your investment with our firm varies with the success and failure of our investment strategies, research, analysis and determination of portfolio securities. If our investment strategies do not produce the expected returns, the value of the investment will decrease. Item 9 – Disciplinary Information Item 9 is not applicable to this Disclosure Brochure because there are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of our business or integrity. Item 10 – Other Financial Industry Activities and Affiliations Wold Financial Group LLC Page 10 Form ADV Part 2A Firm Brochure  Wold Financial Group is not and does not have a related person that is a broker/dealer, municipal securities dealer, government securities dealer or broker, an investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), another investment adviser or financial planner, a futures commission merchant, commodity pool operator, or commodity trading advisor, a banking or thrift institution, an accountant or accounting firm, a lawyer or law firm, an insurance company or agency, a pension consultant, a real estate broker or dealer, and a sponsor or syndicator of limited partnerships. We are an independent registered investment adviser and only provide investment advisory services. We are not engaged in any other business activities and offer no other services except those described in this Disclosure Brochure. Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading Code of Ethics Summary According to the Investment Advisers Act of 1940, an investment adviser is considered a fiduciary and has a fiduciary duty to all clients. Wold Financial Group has established a Code of Ethics to comply with the requirements of Section 204(A)-1 of the Investment Advisers Act of 1940 that reflects its fiduciary obligations and those of its supervised persons. The Code of Ethics also requires compliance with federal securities laws. The Code of Ethics covers all individuals that are classified as “supervised persons”. All employees, officers, directors and investment adviser representatives are classified as supervised persons. Wold Financial Group requires its supervised persons to consistently act in your best interest in all advisory activities. Wold Financial Group imposes certain requirements on its affiliates and supervised persons to ensure that they meet the firm’s fiduciary responsibilities to you. The standard of conduct required is higher than ordinarily required and encountered in commercial business. This section is intended to provide a summary description of the Code of Ethics of Wold Financial Group. If you wish to review the Code of Ethics in its entirety, you should send us a written request and upon receipt of your request, we will promptly provide a copy of the Code of Ethics to you. Affiliate and Employee Personal Securities Transactions Disclosure Wold Financial Group or supervised persons of the firm buy and sell for their personal accounts, investment products identical to those recommended to clients. This creates a conflict of interest. It is the express policy of Wold Financial Group that all persons associated in any manner with our firm must place clients’ interests ahead of their own when implementing personal investments. As is required by our internal procedures manual, Wold Financial Group and its supervised persons will not buy or sell securities for their personal account(s) where their decision is derived, in whole or in part, by information obtained as a result of employment or association with our firm unless the information is also available to the investing public upon reasonable inquiry. We are now and will continue to be in compliance with applicable state and federal rules and regulations. To mitigate conflicts of interest that can occur when access persons manage their personal accounts at the same time Wold Financial Group manages client accounts, we have developed written supervisory procedures that include personal investment and trading policies for our representatives, employees and Wold Financial Group LLC Page 11 Form ADV Part 2A Firm Brochure  their immediate family members (collectively, supervised persons): • Supervised persons cannot prefer their own interests to that of the client. • Supervised persons cannot purchase or sell any security for their personal accounts prior to implementing transactions for client accounts. • Supervised persons cannot buy or sell securities for their personal accounts when those decisions are based on information obtained as a result of their employment unless that information is also available to the investing public upon reasonable inquiry. • Supervised persons are prohibited from purchasing or selling securities of companies in which any client is deemed an “insider”. • Supervised persons are discouraged from conducting frequent personal trading. • Supervised persons are generally prohibited from serving as board members of publicly traded companies unless an exception has been granted by the Chief Compliance Officer of Wold Financial Group. Any Supervised person not observing our policies is subject to sanctions up to and including termination. Item 12 – Brokerage Practices If Wold Financial Group assists in the implementation of any recommendations, we are responsible to ensure that the client receives the best execution possible. Best execution does not necessarily mean that clients receive the lowest possible commission costs but that the qualitative execution is best. In other words, all conditions considered, the transaction execution is in your best interest. When considering best execution, we look at a number of factors besides prices and rates including, but not limited to: • Execution capabilities (e.g., market expertise, ease/reliability/timeliness of execution, responsiveness, integration with our existing systems, ease of monitoring investments) • Products and services offered (e.g., investment programs, back office services, technology, regulatory compliance assistance, research and analytic services) • Financial strength, stability and responsibility • Reputation and integrity • Ability to maintain confidentiality We exercise reasonable due diligence to make certain that best execution is obtained for all clients when implementing any transaction by considering the back office services, technology and pricing of services offered. Brokerage Recommendations Wold Financial Group may recommend/require that clients establish brokerage accounts with the Schwab Institutional division of Charles Schwab & Co., Inc (“Schwab”), a FINRA-registered broker-dealer, Member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. Although Wold Financial Group may recommend/require the clients establish accounts at Schwab, it is the client’s decision to custody assets with Schwab. Wold Financial Group is independently owned and operated Wold Financial Group LLC Page 12 Form ADV Part 2A Firm Brochure  and not affiliated with Schwab. Wold Financial Group may recommend additional unaffiliated broker- dealers to affect fixed income transactions. Schwab provides Wold Financial Group 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 advisors on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the advisor’s clients’ assets are maintained at Schwab Institutional. These services are not contingent upon Wold Financial Group 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 significantly higher minimum initial investment. Schwab Institutional also makes available to Wold Financial Group other products are services that benefit Wold Financial Group but may not directly benefit clients’ accounts. Many of these products and services may be used to service all or some substantial number of Wold Financial Group’ accounts, including accounts not maintained at Schwab. These products and services are provided to all registered investment advisory firms utilizing Schwab institutional as their custodial broker dealer and are not part of a formal soft dollar relationship with the firm. Schwab’s products and services that assist Wold Financial Group in managing and administering clients’ accounts include software and other technology that (i) provides access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of Wold Financial Group’s fees from some of its accounts; and (v) assist with back-office functions, recordkeeping and client reporting. Schwab Institutional also offers other services intended to help Wold Financial Group manage and further develop its business enterprise. These services may include: (i) compliance, legal and business consulting; (ii) publications and conferences on practice management and business succession; and (iii) access to employee benefits providers, human capital consultants and insurance providers. Schwab Institutional may discount or waive fees it would otherwise charge for some of these services or pay all or part of the fees of a third-party providing these services to Wold Financial Group. Schwab Institutional may also provide other benefits such as educational events or occasional business entertainment of Wold Financial Group personnel. While as a fiduciary, Wold Financial Group endeavors to act in its clients’ best interests, Wold Financial Group’s recommendation that clients maintain their assets in accounts at Schwab may take into account availability of some of the foregoing products and services and other arrangements not solely on the nature of cost or quality of custody and brokerage services provided by Schwab, which creates a conflict of interest. Directed Brokerage Clients should understand that not all investment advisors require the use of a particular broker/dealer or custodian. Some investment advisors allow their clients to select whichever broker/dealer the client decides. By requiring clients to use a particular broker/dealer, Wold Financial Group may not achieve the most favorable execution of client transactions and the practice requiring the use of specific broker/dealers may cost clients more money than if the client used a different broker/dealer or custodian. However, for compliance and operational efficiencies, Wold Financial Group has decided to Wold Financial Group LLC Page 13 Form ADV Part 2A Firm Brochure  require our clients to use broker/dealers and other qualified custodians determined by Wold Financial Group. Soft Dollar Benefits An investment adviser receives soft dollar benefits from a broker-dealer when the investment adviser receives research or other products and services in exchange for client securities transactions or maintaining an account balance with the broker-dealer. Wold Financial Group does not have a formal soft dollar agreement with a broker-dealer or a third-party. Block Trading Policy Wold Financial Group provides investment management services for various clients, and does not participate in aggregate trading. If the Firm ever chooses to do so, we will establish the proper policies and procedures. In any given situation, our firm attempts to allocate trade executions in the most equitable manner possible, taking into consideration client objectives, current asset allocation and availability of funds using price averaging, proration and consistently non-arbitrary methods of allocation. Agency Cross Transactions Our associated persons are prohibited from engaging in agency cross transactions, meaning we cannot act as brokers for both the sale and purchase of a single security between two different clients and cannot receive compensation in the form of an agency cross commission or principal mark-up for the trades. Item 13 – Review of Accounts Account Reviews and Reviewers Managed accounts are reviewed at least quarterly. While the calendar is the main triggering factor, reviews can also be conducted at your request. Account reviews will include investment strategy and objectives review and making a change if strategy and objectives have changed. Reviews are conducted by Stephanie Wright, with reviews performed in accordance with your investment goals and objectives. Our consulting services do not include monitoring the investments of your account(s), and therefore, there is no ongoing review of your account(s) under such services. Statements and Reports For our asset management services, you are provided with transaction confirmation notices and regular quarterly account statements in writing directly from the qualified custodian. You are encouraged to always compare any correspondence, reports or statements provided by us against the account statements delivered from the qualified custodian. When you have questions about your account statement, you should contact our firm and the qualified custodian preparing the statement. Wold Financial Group LLC Page 14 Form ADV Part 2A Firm Brochure  Item 14 – Client Referrals and Other Compensation Wold Financial Group does not directly or indirectly compensate any person for client referrals. The only compensation received from advisory services is the fees charged for providing investment advisory services as described in Item 5 of this Disclosure Brochure. Wold Financial Group receives no other forms of compensation in connection with providing investment advice. We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisers whose clients maintain their accounts at Schwab. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). The availability of Schwab’s products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. Please see Item 5, Fees and Compensation, Item 10, Other Financial Industry Activities and Affiliations and Item 12, Brokerage Practices, for additional discussion concerning other compensation. Item 15 – Custody Custody, as it applies to investment advisors, has been defined by regulators as having access or control over client funds and/or securities. In other words, custody is not limited to physically holding client funds and securities. If an investment adviser has the ability to access or control client funds or securities, the investment adviser is deemed to have custody and must ensure proper procedures are implemented. Wold Financial Group is deemed to have custody of client funds and securities whenever Wold Financial Group is given the authority to have fees deducted directly from client accounts. However, this is the only form of custody Wold Financial Group will ever maintain. It should be noted that authorization to trade in client accounts is not deemed by regulators to be custody. For accounts in which Wold Financial Group is deemed to have custody, we have established procedures to ensure all client funds and securities are held at a qualified custodian in a separate account for each client under that client’s name. Clients or an independent representative of the client will direct, in writing, the establishment of all accounts and therefore are aware of the qualified custodian’s name, address and the manner in which the funds or securities are maintained. Finally, account statements are delivered directly from the qualified custodian to each client, or the client’s independent representative, at least quarterly. Clients should carefully review those statements and are urged to compare the statements against reports received from Wold Financial Group. When clients have questions about their account statements, they should contact Wold Financial Group or the qualified custodian preparing the statement. Standing Letters of Authorization On February 21, 2017, the SEC issued a no‐action letter (“Letter”) with respect to the Rule 206(4) ‐2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a standing letter of instruction (SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguards in conjunction with our custodian: Wold Financial Group LLC Page 15 Form ADV Part 2A Firm Brochure  • The client provides instructions to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. • The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. • The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization and provides a transfer of funds notice to the client promptly after each transfer. • The client has the ability to terminate or change the instruction to the client’s qualified custodian. • The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. • The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. • The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Item 16 – Investment Discretion When providing asset management services, Wold Financial Group maintains trading authorization over your Account and can provide management services on a discretionary basis. When discretionary authority is granted, we will have the authority to determine the type of securities and the amount of securities that can be bought or sold for your portfolio without obtaining your consent for each transaction. If you decide to grant trading authorization on a non-discretionary basis, we will be required to contact you prior to implementing changes in your account. Therefore, you will be contacted and required to accept or reject our investment recommendations including: • The security being recommended • The number of shares or units • Whether to buy or sell Once the above factors are agreed upon, we will be responsible for making decisions regarding the timing of buying or selling an investment and the price at which the investment is bought or sold. If your accounts are managed on a non-discretionary basis, you need to know that if we are not able to reach you or you are slow to respond to our request, it can have an adverse impact on the timing of trade implementations and we may not achieve the optimal trading price. You will have the ability to place reasonable restrictions on the types of investments that may be purchased in your Account. You may also place reasonable limitations on the discretionary power granted to Wold Financial Group so long as the limitations are specifically set forth or included as an attachment to the client agreement. Item 17 – Voting Client Securities Wold Financial Group LLC Page 16 Form ADV Part 2A Firm Brochure  Proxy Voting Wold Financial Group does not vote proxies on behalf of Clients. We have determined that taking on the responsibilities for voting client securities does not add enough value to the services provided to you to justify the additional compliance and regulatory costs associated with voting client securities. Therefore, it is your responsibility to vote all proxies for securities held in Account. You will receive proxies directly from the qualified custodian or transfer agent; we will not provide you with the proxies. You are encouraged to read through the information provided with the proxy-voting documents and make a determination based on the information provided. You may contact us at 612- 347-7825 should you have any questions regarding the proxy voting process. Item 18 – Financial Information This Item 18 is not applicable to this brochure. Wold Financial Group does not require or solicit prepayment of more than $1200 in fees per client, six months or more in advance. Therefore, we are not required to include a balance sheet for the most recent fiscal year. We are not subject to a financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients. Finally, Wold Financial Group has not been the subject of a bankruptcy petition at any time. No Arrangement with Issuer of Securities Wold Financial Group and its management do not have any relationship or arrangement with any issuer of securities. Customer Privacy Policy Notice Regulation S-P, Privacy of Consumer Financial Information, requires financial institutions, including Wold Financial Group, to provide notice to current clients and prospective clients about their policies and practices concerning the collection and use of customer, non-public information. This privacy policy notice is given to all prospective clients of Wold Financial Group upon entering into a contract with Wold Financial Group and annually thereafter. Privacy Disclosure Statement. A primary goal of Wold Financial Group is to protect the privacy of its clients. Wold Financial Group does not sell the personal information of clients to anyone. To conduct regular business, Wold Financial Group may collect nonpublic personal information from clients. This information is provided by clients to Wold Financial Group on applications and other forms provided by clients to Wold Financial Group as well as transactions with the firm, our affiliates, or others. Wold Financial Group may enter into contracts with outside third parties so that Wold Financial Group can assist its clients in servicing their accounts. In order to do this, Wold Financial Group will disclose personal information to companies that help Wold Financial Group process transactions for client accounts (for example, executing client trades at through a broker/dealer). However, Wold Financial Group does not share or disclose any nonpublic customer information except as allowed or required by law. In addition to sharing information in order to provide financial services to clients, Wold Financial Wold Financial Group LLC Page 17 Form ADV Part 2A Firm Brochure  Group may be required to disclose personal information to cooperate with regulators or law enforcement authorities, to resolve customer disputes, or for risk control. Information Safeguarding. Wold Financial Group has implemented strict policies and procedures aimed at protecting the sensitive nature of client information. Wold Financial Group restricts access to client information to only those members of Wold Financial Group that must provide products and services to clients in order to service client accounts. Wold Financial Group has implemented physical, electronic, and procedural safeguards aimed at meeting Wold Financial Group’s duty to protect nonpublic client information. If you have any questions concerning Wold Financial Group’s customer privacy policy or concerns about your personal information please feel free to contact us at 612-347-7825. Business Continuity Plan Wold Financial Group has a business continuity and contingency plan in place designed to respond to significant business disruptions. These disruptions can be both internal and external. Internal disruptions will impact our ability to communicate and do business, such as a fire in the office building. External disruptions will prevent the operation of the securities markets or the operations of a number of firms, such as earthquakes, wildfires, hurricanes, terrorist attack or other wide-scale, regional disruptions. Our continuity and contingency plan has been developed to safeguard employees’ lives and firm property, to allow a method of making financial and operational assessments, to quickly recover and resume business operations, to protect books and records, and to allow clients to continue transacting business. The plan includes the following: • Alternate locations to conduct business; • Hard and electronic back-ups of records; • Alternative means of communications with employees, clients, critical business constituents and regulators; and • Details on the firms’ employee succession plan Our business continuity and contingency plan is reviewed and updated on a regular basis to ensure that the policies in place are sufficient and operational. Wold Financial Group LLC Page 18 Form ADV Part 2A Firm Brochure