Vantage Consulting Group, Inc. (Vantage) is an SEC-registered investment adviser with its principal place of business located in Virginia Beach, Virginia. Vantage has been conducting business since 1985. Mark T. Finn serves as the firm's Chairman, CEO and CCO. He is the firm's majority shareholder.
As used in this brochure, the words "Vantage", "we," "our," and "us" refer to Vantage Consulting Group, Inc. and BV Partners, LLC, New Ventures Select Partners, LLC, New Ventures III Manager, LLC, Vantage Analytics, LLC, New Ventures aS Manager, LLC; New Ventures aS Manager II, LLC and New Ventures aS Adviser, LLC.
Vantage Consulting Group, Inc. offers the following advisory services to clients: INDIVIDUAL PORTFOLIO MANAGEMENT Vantage provides continuous advice to a client or making investments for a client based on the individual needs of the client. During our data-gathering process, Vantage determines the client's individual objectives, time horizons, risk tolerance, and liquidity needs. We review and discuss a client's prior investment history, and where appropriate family composition and background. Through personal discussions and correspondence with clients, goals and objectives based on the client's particular circumstances are established. Together we develop a client's personal investment policy and create and manage a portfolio based on that policy.
Vantage manages advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations.
Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors.
Our investment recommendations are not limited to any specific product or service offered by a broker- dealer, insurance company, fund manager, or investment advisor or manager, and will generally include advice regarding the following securities:
•Exchange-listed securities
•Securities traded over-the-counter
•Foreign issuers
•Warrants
•Corporate debt securities (other than commercial paper)
•Commercial paper
•Municipal securities
•Mutual fund shares
•United States governmental securities
•Options contracts on securities
•Options contracts on commodities
•Futures contracts on tangibles
•Futures contracts on intangibles
•Interests in partnerships investing in real estate
•Interests in partnerships investing in oil and gas interests
•Interests in partnerships investing in private equity
•Alternative investments 4
•Other Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability.
MANAGER OF MANAGERS PROGRAM (MOM) Vantage offers advisory management services to clients through our Manager of Managers Program ("MOM") on a discretionary basis. We provide the client with an asset allocation strategy developed through personal discussions and correspondence whereby the client's goals and objectives, time horizons, risk tolerance and liquidity needs are established. The asset allocation strategy is then drafted into the client's Investment Policy Statement.
Vantage performs management searches of various investment advisers (including partnerships, funds, and commodity pools/advisers). Based on the client's individual circumstances and needs (as exhibited in the client's Investment Policy Statement) we determine which investment adviser's ("adviser" or "asset manager") portfolio management style is appropriate for the client. Factors considered in making this determination include account size, risk tolerance, the opinion of each client and the investment philosophy of the selected asset manager. MOM clients should refer to selected asset managers' Firm Brochures or other disclosure document for a full description of the services they provide. Meetings with clients to review the account are on a regular basis (typically annually or quarterly) or as determined by the client. After an adviser is hired by the Vantage client, the adviser creates and manages the client's portfolio based on the client's individual needs in accordance with the guidelines or IPS.
On an ongoing basis, Vantage monitors the performance of the asset manager(s). If it is determined that a particular adviser is not providing sufficient management services to the client, or is not managing the client's portfolio in a manner consistent with that client's Investment Policy Statement, we will recommend and implement appropriate asset manager or program changes.
Periodically and as necessary, Vantage meets with the clients to review and update Investment Policy Statements. Vantage requests clients provide prompt notification of material changes in the client's personal and/or financial situation in order to determine whether a review and/or revision of the Investment Policy Statement is warranted.
PENSION CONSULTING SERVICES Vantage provides several discretionary and non-discretionary advisory services separately or in combination. While the primary clients for these services will be pension, profit sharing and 401(k) plans, we offer similar services, where appropriate, to individuals and trusts, estates and charitable organizations. Pension Consulting Services are comprised of four distinct services. Clients may choose to use any or all of these services.
Investment Policy Statement Preparation (hereinafter referred to as ''IPS''): Vantage will meet with the client representatives (in person or over the telephone) to determine an appropriate investment strategy that reflects the plan sponsor's stated investment objectives for management of the overall plan. Typically, Vantage will then draft a written IPS detailing the objectives, including a plan to achieve the goals. The IPS may also list the criteria for selection of investment vehicles as well as the procedures and timing for monitoring of investment performance.
5 Selection of Investment Vehicles: Vantage will assist plan sponsors in constructing appropriate asset allocations. We will review various investments best suited for ERISA accounts including mutual funds (both indexed and managed) to determine appropriate investments to implement the client's IPS. The number of investments to be recommended may be determined by the client, based on the IPS. Monitoring of Investment Performance: Vantage will continuously monitor and regularly report on client investments based on the procedures and schedules outlined in the IPS. Unless also serving as a Manager of Managers, Vantage will not have the discretionary authority to purchase or sell the investments for the account. Vantage will supervise the client's portfolio and make recommendations to the client as market factors and the client's

needs dictate.
Employee Communications: For pension, profit sharing and 401(k) plan clients wherein there are individual accounts with plan participants exercising control over assets in their own account (''self-directed plans''), Vantage may provide educational support designed for the plan participants. The nature of the topics to be covered will be determined by Vantage and the client under the guidelines established in ERISA Section 404(c). The educational support will NOT provide plan participants with individualized, tailored investment advice or individualized, tailored asset allocation recommendations.
SELECTION AND MONITORING OF THIRD-PARTY MONEY MANAGERS Vantage offers advisory management services to our clients through our Selection and Monitoring of Third-Party Money Managers. Vantage provides the client with an asset allocation strategy developed through personal discussions and correspondence whereby goals and objectives based on the client's particular circumstances are established. This asset allocation strategy is drafted into the client's Investment Policy Statement ("IPS").
Based on the client's individual circumstances and needs (as exhibited in the client's IPS), Vantage performs management searches of various investment advisers to identify the portfolio management style appropriate for the client. Factors considered in making this determination include account size, risk tolerance, the opinion of each client and the investment philosophy of the selected adviser. The selected adviser's Firm Brochure or other disclosure document is reviewed for understanding of the services offered. Vantage meets with clients to review their account at least annually or as requested by the client. After an adviser is hired by the Vantage client, the adviser creates and manages the client's portfolio based on the client's individual needs in accordance with the guidelines or IPS.
Vantage monitors the performance of the selected investment adviser(s). If Vantage determines that an adviser(s) is not providing sufficient management services to the client, or is not managing the client's portfolio in a manner consistent with the client's guidelines or IPS, Vantage may recommend the client terminate the adviser and replace with a different adviser and/or program sponsor. Vantage assists the client in selecting a new investment adviser and/or program. However, any move to a new investment adviser and/or program is solely at the discretion of the client.
6 CONSULTING SERVICES Clients can also retain Vantage to provide investment advice/services on a more focused basis. This may include advice on an isolated area(s) of concern such as estate planning, retirement planning, model building and implementation, trading, fund accounting, selection and identification of investment managers, including due diligence and risk assessment for clients/funds, signal provider services or other investment related topic. Vantage also provides specific consultation and/or administrative services regarding investment and financial concerns of the client.
PRIVATE INVESTMENT FUNDS Vantage serves as the general partner, managing member, or manager of and/or the investment adviser to, certain private investment funds. As used in this section, the term "the Adviser" includes both Vantage; and BV Partners, LLC, New Ventures III Manager, LLC, New Ventures aS Manager, LLC, New Ventures Select Partners, LLC, New Ventures aS Manager II, LLC, New Ventures aS Adviser, LLC and Vantage Analytics, LLC, which are identified as "Relying Advisers" in Part 1A of Vantage's Form ADV (see Schedule R).
Vantage bases its advice to such private investment funds on the investment objective and restrictions (if any) set forth in the applicable offering memorandum, organizational documents, investment management agreement, and/or subscription agreements, as the case may be (each and collectively, the "Governing Documents").
Such funds are available for investment only by institutional investors and other sophisticated, high- net-worth investors, who meet the eligibility requirements of the applicable fund set forth in its Governing Documents. Each such fund is exempt from registration as an investment company under the U.S. Investment Company Act, as amended (the "Investment Company Act"), under Section 3(c)(1) or 3(c)(7) thereof.
REGISTERED INVESTMENT COMPANIES (MUTUAL FUNDS) Vantage provides investment subadvisory services to Registered Investment Companies (Exchange Traded Funds, "ETFs"). Vantage manages each ETF to the investment strategy and restrictions described in the prospectus of such ETF. Vantage does not provide tailored investment advisory services to the individual investors in the ETF.
ERISA Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best 7 interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest. We benefit financially from the accounts that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. AMOUNT OF MANAGED ASSETS As of 12/31/2023, Vantage managed $463,233,353 of discretionary client's assets in 15 accounts. As of 12/31/2023, Vantage did not manage non-discretionary client assets. As of 12/31/2023, Assets Under Advisement* were $1,749,327,779 in 12 accounts. As of 12/31/2023 total discretionary assets under management and assets under advisement were $2,212,561,131 in 28 accounts. *Assets under advisement are accounts where Vantage provides pension consulting or other services which may include, but are not limited to, asset allocation, portfolio evaluation, and risk management. Assets under advisement are not defined as regulatory assets under management.