A. Description of the Advisory Firm FRG Family Wealth Advisors LLC (hereinafter “FRG”) is a Limited Liability Company organized in the State of Washington. The firm was formed in June 2009 as Financial Resources Group.com LLC, and the principal owners are Benjamin Dale Johnson and Jimmy Shanggee Wu. The firm changed its name in 2018 to FRG Family Wealth Advisors LLC. B. Types of Advisory Services Portfolio Management Services FRG offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. FRG creates an investment profile for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following:
•Investment strategy •Personal investment goals
•Asset selection•Asset allocation
•Risk tolerance
•Options
•Regular portfolio monitoring FRG evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. FRG 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 profile, which is given to each client. FRG seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of FRG’s economic, investment or other financial interests. To meet its fiduciary obligations, FRG attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client

portfolios, and accordingly, FRG’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 FRG’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Services Limited to Specific Types of Investments FRG generally limits its investment advice to mutual funds, fixed income securities, equities, ETFs and non-U.S. securities. FRG may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions FRG will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by FRG on behalf of the client. FRG may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. 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 FRG from properly servicing the client account, or if the restrictions would require FRG to deviate from its standard suite of services, FRG reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. FRG does not participate in wrap fee programs. E. Assets Under Management FRG has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $245,446,667.00 $321,434,327.00 December 31, 2022