A. Description of the Advisory Firm PFG Private Wealth Management, LLC (hereinafter “PFGPWM”) is a Limited Liability Company organized in the State of Florida. The firm was formed in November 2015, and the principal owners are Jeffrey Douglas Perry and Robert Montgomery Perry. B. Types of Advisory Services Portfolio Management Services PFGPWM offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. PFGPWM creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring PFGPWM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. PFGPWM will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. PFGPWM seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of PFGPWM’s economic, investment or other financial interests. To meet its fiduciary obligations, PFGPWM attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, PFGPWM’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is PFGPWM’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Pension Consulting Services

PFGPWM offers ongoing consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans) based on the demographics, goals, objectives, time horizon, and/or risk tolerance of the plan’s participants. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Workshops and Seminars PFGPWM offers financial planning workshops to attendees at a charge. Services Limited to Specific Types of Investments PFGPWM generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), commodities and non-U.S. securities, although PFGPWM primarily recommends mutual funds and ETFs to a majority of its clients. PFGPWM may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions PFGPWM offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent PFGPWM from properly servicing the client account, or if the restrictions would require PFGPWM to deviate from its standard suite of services, PFGPWM reserves the right to end the relationship. D. Wrap Fee Programs Wrap fee programs are investment programs where the investor pays one stated fee that includes management fees and trading fees. PGFPWM does not participate in wrap fee programs. E. Assets Under Management PFGPWM has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $239,232,836 $374,919 December 31, 2022