A. Firm Description PAX Financial Group, LLC, dba PAX Financial Group (“PAX” and/or the “firm”) is a registered investment adviser with the U.S. Securities and Exchange Commission (“SEC”) offering portfolio management services and retirement plan consulting services for individuals and high net worth individuals (together with their trusts and estates) and small businesses, corporations and their pension and profit sharing plans (each referred to as a “Client”). PAX has been in business since 2007 and was originally founded by Darryl Lyons, Joseph Schuetze, and Andres Gutierrez. PAX is organized as a Texas Limited Liability Company (“LLC”), with principal owners Darryl Lyons and Joseph Schuetze owning approximately 75% of the partnership interests. The remaining owners primarily include current investment adviser representatives, agents, and employees of PAX. PAX is also an insurance agency licensed with the Texas Department of Insurance. Our insurance group operates under the name PAX Financial Group Insurance Services, a registered DBA. Our investment adviser representatives (or IARs) may also be registered as insurance agents. B. Advisory Services PAX offers the following advisory services, which are described in further detail below. ▪ Investment Management ▪ Wrap Fee Program ▪ Third-Party Separate Account Management ▪ Financial Planning and Consultation ▪ Retirement Plan Consulting ▪ Business PIVOT Planning Our advisory services are tailored to the individual needs of each Client. Each Client’s investment objective, risk tolerance, liquidity needs, and other financial data will be taken into consideration. Accounts are reviewed on a regular basis and rebalanced as necessary according to each Client’s investment profile. PAX may, at his/her sole discretion, decline to assist the Client with the implementation of investment strategies or purchasing of securities that have not been recommended or those securities PAX deems not to be in the Client’s best interest. When providing a consolidated financial summary of accounts to Clients, data included may contain information about accounts for which PAX does not manage or advise the Client. As such, no inference should be drawn that PAX serves as the adviser on all securities listed on these consolidated financial summaries. B.1. Investment Management PAX provides discretionary and non-discretionary fee-based investment management services for compensation. PAX’s investment management services are predicated on the Client's investment objectives, goals, tolerance for risk, and other personal and financial circumstances. PAX will analyze each Client's current investments, investment objectives, goals, age, time horizon, financial circumstances, investment experience, investment restrictions and limitations, and risk tolerance and implement a portfolio consistent with such investment objectives, goals, risk tolerance and related financial circumstances. In addition, PAX may utilize third-party software to analyze individual security holdings and separate account managers utilized within the Client’s portfolio. For discretionary investment management, PAX receives a limited power of attorney to effect securities transactions on behalf of its Clients that include securities and strategies described in Item 8 of this brochure. PAX’s engagement with a Client will include, as appropriate, the following: ▪ Providing assistance in reviewing the Client's current investment portfolio against the Client's personal and financial circumstances as disclosed to PAX in response to a questionnaire and/or in discussions with the Client and reviewed in meetings with PAX. ▪ Analyzing the Client's financial circumstances, investment holdings and strategy, and goals. ▪ Providing assistance in identifying a targeted asset allocation and portfolio design. ▪ Implementing and/or recommending individual equity and fixed income securities, mutual funds and ETFs. ▪ Reporting to the Client on a quarterly basis or at some other interval agreed upon with the Client, information on contributions and withdrawals in the Client's investment portfolio, and the performance of the Client's portfolio measured against appropriate benchmarks (including benchmarks selected by the Client). ▪ Proposing changes in the Client's investment portfolio in consideration of changes in the Client's personal circumstances, investment objectives and tolerance for risk, the performance record of any of the Client's investments, and/or the performance of any fund retained by the Client. ▪ If the Client’s portfolio and personal circumstances, investment objectives, and tolerance for risk make such advice appropriate, providing recommendations to hedge a Client’s portfolio through the use of derivative strategies, to generate additional income through the use of covered call option writing strategies involving exchange listed or OTC options, and/or to monetize or hedge concentrated stock positions. Clients have the right to provide the firm with any reasonable investment restrictions that should be imposed on the management of their portfolio, and should promptly notify the firm in writing of any changes in such restrictions or in the Client's personal financial circumstances, investment objectives, goals and tolerance for risk. PAX will remind Clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the Client’s account. PAX will also contact Clients at least annually to determine whether there have been any changes in a Client's personal financial circumstances, investment objectives and tolerance for risk. B.2. Third-Party Separate Account Management PAX may recommend that all or a portion of Client assets in an account be managed by third- party manager(s). For such arrangements, the Client will grant PAX written authorization to use discretion in selecting or changing a strategy within a third-party manager relationship or changing the third-party manager entirely without prior notice. In most cases, the Client pays the third-party manager an investment management fee out of account assets directly that is separate from PAX’s fee. For certain Client assets, PAX makes available the investment management services of approved third-party sub-advisers. Each sub-adviser is granted discretionary investment authority over assets that PAX assigns to the sub-adviser in accordance with the specific strategy or model that is selected for management. Any authority of the sub-adviser only applies to the specific assets within the Client’s custodial account for which sub-adviser has been appointed as the discretionary manager. Each sub- adviser shall not have any Client facing responsibilities and will rely on instructions PAX provides on behalf of such Client. The sub-advisor will not provide investment advice or have any advisory responsibility to the Client beyond the assets for which it is appointed as sub-adviser. The terms of services provided by each sub-adviser are directed in accordance with a separate written agreement entered into between PAX and the sub-adviser. PAX has a financial incentive to refer Clients to approved sub-advisers rather than managing the assets on its own or referring them to another third-party manager, creating a conflict of interest. When PAX refers Clients to approved sub-advisers, it receives various incentives which benefit PAX but not all PAX Clients, which may include some or all of the following: ▪ Certain technology implementation fees incurred by PAX in connection with PAX’s use of the sub-adviser’s technology solutions will be reduced or waived entirely if a predetermined number of PAX Client subscribe to PAX’s guidance services which utilize such technology solutions. ▪ Certain technology implementation fees incurred by PAX in connection with PAX’s use of the sub-adviser’s technology solutions will be reduced if a predetermined number of PAX’s Client’s assets are placed in investment models or in mutual funds or exchange- traded funds available through such sub-adviser or one of its affiliates. Goldman Sachs Personal Financial Management Service Offering In an effort to enhance the quality and breadth of services that PAX provides to its Clients, PAX utilizes a suite of digitally powered technology solutions offered by GSPFM, a division of Goldman Sachs (“GSPFM”). GSPFM provide access to its technology platform to PAX which includes use of certain technology platforms, training relating to use of such technology platform, and if elected by PAX certain clerical document and data compilation services. GSPFM is not in any way involved in, or responsible for, the individual investment management or guidance provided to Clients. PAX pays GSPFM a flat fee for its technology implementation services and fees calculated per percentage-basis formula in accordance with the volume of Clients for whom PAX utilizes such services and/or products. As such, for certain services offered, Clients indirectly contribute to the payment of cost of services paid to GSPFM. Relating to the cost for services, PAX is financially incentivized to refer Clients to GSPFM portfolios in order to reduce its costs of utilizing its platform, creating a conflict of interest. Financial incentives are described herein. When PAX refers Clients to approved GSPFM, it receives various incentives which benefit PAX but not all PAX Clients, which may include some or all of the following: ▪ Certain technology implementation fees incurred by PAX in connection with PAX’s use of GSPFM’s technology solutions will be reduced or waived entirely if a predetermined number of PAX Client subscribe to PAX’s guidance services which utilize such technology solutions. ▪ Certain technology

implementation fees incurred by PAX in connection with PAX’s use of GSPFM’s technology solutions will be reduced if a predetermined number of PAX’s Client’s assets are placed in investment models or in mutual funds or exchange-traded funds available through GSPFM or one of its affiliates. ▪ Clients are advised that if PAX does not meet a predetermined threshold of production utilizing services or technology solutions offered by GSPFM, as applicable, GSPFM may terminate its sub-advisory relationship with PAX. To address this conflict, if the Client does not want to invest their assets with GSPFM as the Sub-Manager or receive PAX financial guidance services that require access to the GSPFM platform, the Client may discuss alternative options with PAX. ▪ If PAX invests $15,000,000 or more in Goldman Sachs Asset Management managed US registered 1940 Act mutual funds (“GSAM Mutual Funds”), PAX will receive a quarterly credit equal to $6,250 for every $15,000,000 of assets invested in GSAM Mutual Funds on the date of the applicable invoice. The total credit may not exceed the total quarterly invoiced amount for the CX Use Fee as specified on the fee schedule. GSPFM will measure eligibility for and apply the credit, if any, on a quarterly basis against the annual fees due and owing. GSPFM reserves the right to terminate the credit program at any time. As a result of this arrangement, PAX has an economic incentive to recommend GSAM Mutual Funds. SMArtX Advisory Solutions PAX has entered into a relationship with SMArtX Advisory Solutions (“SMArtX”), where SMArtX sub-advises PAX client accounts and provides access to a platform in which PAX may utilize various programs offered by SMArtX. The SMArtX platform makes available model portfolios offered by one or more third-party strategists. Through the sub-advisory agreement with PAX, SMArtX will provide discretionary investment advisory services with respect to the assets held in the client’s account in accordance with the client’s objectives and PAX’s direction and/or discretion. B.4. Financial Planning and Consultation PAX will conduct an evaluation of the Client’s specific circumstances to determine the items necessary to improve their retirement and/or financial outlook. PAX may use third-party software to gather Client data to evaluate their probability of retiring within their desired goal. Clients who choose this service receive an analysis, assessment, evaluation, suggestion, and/or recommendations from the advisor tailored to the Client’s stated goals, individual needs, and/or objectives. Information and documents are gathered from the Client, as appropriate, during the initial meeting. The analysis, assessment, evaluation, suggestion, and/or recommendations to the Client will be provided during the second meeting and generally address, but is not limited to, the following areas: ▪ Individual/Household Considerations: Goals, objectives, family circumstances and/or obligations. ▪ Cash Flow and Tax Considerations: current and future cash flow needs, budgeting, asset location strategies and tax planning. ▪ Risk Management: Insurance review, retirement income analysis, risk tolerance review, and retirement probability analysis. ▪ Retirement Planning: future income deficiency planning, savings strategies, needs and wants analysis. ▪ Investment Analysis: model portfolio construction, investment and asset review, align strategies with objectives and goals. Upon request, PAX can provide consultative and administrative services regarding Client’s investment and financial concerns on assets not managed by PAX, including advice on non- securities matters. Clients working with PAX who request an insurance solution for their health, life, long-term care, or disability insurance needs will be directed to one of our representatives who is a licensed insurance agent. PAX and its representative may receive commissions or fees as a result of this referral. Please see Item 10.C. for detailed information and conflicts of interest. Clients are advised that when PAX recommends its own services, it has a conflict of interest because it will be compensated if these services are implemented. Thus, implementation of the recommendations is entirely at the Client’s discretion and they may, of course, select a third- party provider. B.5. Retirement Plan Consulting PAX offers Retirement Plan Consulting services to Plan Sponsors of 401(k)s, profit sharing and retirement plans (“Plans”), those subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), as amended, and other employee retirement plans that are not subject to ERISA, such as Simple IRAs. These Plans are participant-directed and trustee-directed Plans and are governed by a separate Investment Fiduciary & Retirement Plan Consulting Agreement. PAX offers the following services to Plan sponsors and their employees: ▪ Administrative Support
• Acting as a liaison between the Plan and Service Providers, product sponsors or vendors
• Ongoing guidance, for consideration and selection by Sponsor, of participant- directed defined contribution plan investment options to be made available by the Plan
• Plan Design Consultation which includes assisting plan sponsor in reviewing objectives and options available through various plans
• Education or training for the Sponsor with regard to various matters, including plan features, retirement readiness matters, servicing and maintaining the Plan
• Fiduciary training and/or education periodically or upon reasonable request for Sponsor
• Assistance in enrolling Plan Participants in the Plan, including conducting an agreed upon number of enrollment meetings. As part of such meetings, IAR’s may provide participants with additional information about the Plan, which may include information on the benefits of Plan participation, the benefits of increasing Plan contributions, the impact of pre-retirement withdrawals on retirement income, the terms of the Plan and the operation of the Plan ▪ Oversight of Relationship with Service Provider
• Assist Sponsor with selection, monitoring and replacement of Service Providers
• Assist Sponsor with review of Covered Service Providers (“CSP”) and fee benchmarking services
• Assist Sponsor with plan review and oversight
• Coordinate and assist with CSP replacement and conversion (if applicable) ▪ Investments
• Periodic review of investments in the context of plan objectives
• Provide investment literature upon requests and/or during education meetings for Sponsor and Plan Participants
• Provide literature for online account access to investments upon requests ▪ Participant Services (Group Sessions)
• Facilitate group enrollment meetings
• Coordinate employee education regarding plan investments and fees
• Assist Plan Participants in understanding plan benefits, retirement readiness and impact of increasing deferrals The actual services to be provided shall be agreed upon by PAX and Plan sponsor prior to engagement and documented in the Investment Fiduciary & Retirement Plan Consulting Agreement. PAX may provide nondiscretionary fiduciary services to Participant-Directed Plan Sponsor relationships. When providing the Nondiscretionary Fiduciary Services, Advisor will solely be making recommendations to Sponsor, and Sponsor retains full discretionary authority or control over assets of the Plan and all final decision-making responsibilities regarding the implementation, acceptance, or rejection of any advice from Advisor. B.6. Business PIVOT Planning PAX offers Business PIVOT Planning to Clients who are in a process of business exit planning. Through this engagement, PAX provides services, tools, and information relating to the following: ▪ the amount of potential proceeds sufficient to provide Client with liquidity to obtain future goals; ▪ a reasonable value for the business; ▪ contingency planning and planning for post-sale quality of life; and ▪ development of a team to assist in Client’s next steps. The Client will participate in five (5) scheduled meetings following submission of required data to PAX. At the completion of the engagement, PAX will provide the Client with a written summary of the plan, copies of all the tools completed, and defined action items for implementation (“Deliverables”). C. Client-Tailored Services and Client-Imposed Restrictions Each Client’s account will be managed on the basis of the Client’s financial situation and investment objectives and in accordance with any reasonable restrictions imposed by the Client on the management of the account—for example, restricting the type or amount of security to be purchased in the portfolio. D. Wrap Fee Programs Other than Retirement Plan Consulting Services and Business PIVOT Planning, PAX offers its investment management services exclusively on a wrap fee basis as a wrap program sponsor. Under our wrap program, you will receive investment advisory services and the execution of securities brokerage transactions for a single specified fee. Participation in a wrap program may cost you more or less than purchasing such services separately. We adhere to our fiduciary duty when trading in your accounts. Trades are made only on the basis of the account’s stated investment objectives, and without concern to the firm’s trading costs and firm’s expenses. For information on this program, please refer to Appendix 1 of Part 2A: PAX Financial Group Wrap Fee Program Brochure. E. Client Assets Under Management As of December 31, 2023, the firm had $600,061,833 of discretionary assets and $0 non- discretionary assets under management.