A. Firm Information Silver Grove Financial Group, Inc. d/b/a Silver Grove Advisory Services,(“Silver Grove Advisory Services” or the “Advisor”) is a registered investment advisor with the SEC, which is organized as a Corporation under the laws of the State of New York. Silver Grove Advisory Services was founded in February 2013 and became registered as an investment advisor in March 2017. The Advisor is owned and operated by Jason J. Weber (Founder and President) and Ryan D. Seufert (Founder and Vice President) (collectively herein the “Principal Officers”). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Silver Grove Advisory Services. B. Advisory Services Offered Silver Grove Advisory Services offers investment advisory services to individuals, high net worth individuals, trusts, estates and other businesses in the State of New York and other states (each referred to as a “Client”). Investment Management Services - Silver Grove Advisory Services provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. Silver Grove Advisory Services works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy based on an understanding of the Client’s overall financial picture. Silver Grove Advisory Services will then construct a portfolio, consisting of low‐ cost, diversified mutual funds and/or exchange‐traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds or options contracts to meet the needs of its Clients. The Advisor may retain certain types of investments based on a Client’s legacy portfolio construction. Silver Grove Advisory Services’ investment strategy[ies] is primarily long‐term focused, but the Advisor may buy, sell or re‐allocate positions that have been held less than one year to meet the objectives of the Client or due to market conditions. Silver Grove Advisory Services will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Silver Grove Advisory Services evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Silver Grove Advisory Services may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Silver Grove Advisory Services may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Silver Grove Advisory Services may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Silver Grove Advisory Services accept or maintain custody of a Client’s funds or securities, except for authorized deduction of the Advisor’s fees. All Client assets will be managed within their designated brokerage account or pension account, pursuant to the Client’s investment advisory agreement. Please see Item 12. Use of Independent Managers ‐ Silver Grove Advisory Services may recommend that a Client utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) described below for all or a portion of a Client’s investment portfolio. In such instances, the Client may be required to authorize and enter into an advisory agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide investment management and related services. The Advisor may also assist in the development of the initial policy recommendations and managing the ongoing Client relationship. The Advisor will perform initial and ongoing oversight and due diligence over the selected Independent Manager[s] to ensure the Independent Managers’ strategies and target allocations remain aligned with its Clients’ investment objectives and overall best interests. LPL Financial Sponsored Advisory Programs – Silver Grove provides advisory services through programs sponsored by LPL Financial LLC (LPL), a registered investment adviser and broker‐dealer. Below is a brief description of each LPL advisory program available to [Advisor].
• Manager Access Select Program Under this program, the Advisor will select a third‐party portfolio manager (Portfolio Manager) for the client from a list of Portfolio Managers made available by LPL. The Portfolio Manager manages client’s assets on a discretionary basis. P a g e | 5
• Optimum Market Portfolios Program (OMP) Under this program, Advisor will have discretion to select a mutual fund asset allocation portfolio designed by LPL consistent with the client’s investment objective. LPL will have discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client.
• Personal Wealth Portfolios Program (PWP) Under this program, Advisor will have discretion to select an asset allocation model portfolio based on client’s investment objective. Advisor will also have discretion to select third party money managers (PWP Advisors), mutual funds and ETFs within each asset class of the model portfolio. LPL will act as the overlay portfolio manager on all PWP accounts and will be have discretion to purchase and sell mutual funds, ETFs and equity and fixed income securities.
• Model Wealth Portfolios Program (MWP) Under this program, Advisor will have discretion to select a model portfolio designed by LPL’s Research Department consistent with the client’s stated investment objective. LPL’s Research Department or third‐party portfolio strategists are responsible for selecting the mutual funds or ETFs within a model portfolio and for making changes to the mutual funds or ETFs selected.
• Guided Wealth Portfolios (GWP) Under this program, Advisor will assist client in establishing an account managed through an algorithm‐based investment program (“robo‐advisory” program) of Xulu, Inc., doing business as Future Advisor, an SEC registered investment adviser. Investment recommendations for accounts in this program are based on model portfolios constructed by LPL. A model portfolio will be assigned to the client’s account based on the client’s investment objectives. SEI Sponsored Advisory Programs – Silver Grove may recommend asset allocation and managed programs through SEI Investments Management Corporation, a registered investment adviser who serves as the Independent Manager for the client’s account. Through the SEI advisory programs, Silver Grove provides the following services:
• Assist the client to evaluate and determine one or more of the SEI programs
• Assist the client to determine the asset allocation model best suited to each client’s investment objectives and risk tolerance. Clients may accept, reject or modify asset allocations.
• Make changes to the selected asset allocation and/or selected managers (i.e. hire and fire managers) as Silver Grove deems appropriate Orion Portfolio Solutions Sponsored Advisory Programs Silver Grove may recommend advisory programs available through Orion Portfolio Solutions, a registered investment adviser. Under this program, Silver Grove will have discretion to select a model portfolio designed by third‐party portfolio strategists (Independent Managers). The strategists are responsible for selecting the mutual funds or ETFs within a model portfolio and for making changes to the mutual funds or ETFs selected. Betterment, LLC Advisory Program – Silver Grove may recommend that certain Clients establish an account with Betterment, LLC, a registered investment adviser that will serve as the Independent Manager for the Client’s account. Betterment provides an online wealth management service through an automated, algorithm‐based investment program (“robo‐ advisory” services). Robo‐advisors use technology to deliver similar services as traditional advisors, but generally only offer portfolio management and do not get involved in a Client’s personal situation, such as taxes and retirement or estate planning. Through this program, Silver Grove assists clients in choosing portfolios of exchange‐traded funds managed by Betterment on a discretionary basis. A client can obtain some of Betterment’s services directly from Betterment without paying an additional fee to Silver Grove. The Client, prior to entering into an agreement with unaffiliated investment manager[s] or investment platform[s], will be provided with the Independent Manager's Form ADV 2A (or a brochure that makes the appropriate disclosures). The Independent Manager will implement the portfolio and be responsible for the discretionary trading of the Client’s accounts, including the purchase and sale of investments and the automatic rebalancing back to targets. Financial Planning Services - Silver Grove Advisory Services will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals, objectives and financial situation. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including P a g e | 6 but not limited to, investment planning, retirement planning, personal savings, education savings and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation

rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Silver Grove Advisory Services may also refer Clients to an accountant, attorney or other specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad‐hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of the contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations may pose a conflict between the interests of the Advisor and the interests of the Client. For example, a recommendation to engage the Advisor for investment management services or to increase the level of investment assets with the Advisor would pose a conflict, as it would increase the advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to affect the transaction through the Advisor. We offer Estate Planning services as part of our ongoing financial planning services for our clients to assist with general information as it applies to reviews of existing plans, gathering information needed to provide to outside firms in the creation of documents, and updating existing plans for clients. Depending on the client needs and desires for estate planning document review, preparation, or updates we will engage with a third-party scrivener service or estate planning attorneys. For clients engaging in financial planning services, there is no separate fee for estate planning services. However, the client’s ongoing or one-time financial planning fees may be higher if we anticipate at the start of the engagement that estate planning services are needed as part of their comprehensive financial planning arrangement. Retirement Plan Consulting Services - Silver Grove offers consulting services to retirement plan sponsors in some or all the following areas as agreed upon between the plan sponsor and Silver Grove as selected by the plan sponsor in the client agreement.
• Investment Policy Statement – assist the plan sponsor in developing or revising the plan’s investment policy statement based upon its objectives and constraints.
• Service Provider Liaison –may assist the Plan by acting as a liaison between the Plan and service providers, product sponsors and/or vendors. In such cases, Silver Grove shall act only in accordance with instructions from the Client on investment or Plan administration matters and shall not exercise judgment or discretion.
• Investment Monitoring – perform ongoing monitoring of investments and/or investment managers based on written guidance provided by the plan.
• Investment Recommendations – recommend specific investments for plan sponsor to consider within the plan or to make available to plan participants (if applicable), and/or recommend replacement investments if an existing investment is deemed no longer suitable by the plan sponsor. All decisions regarding investment options to be made available to plan participants for purchase are the responsibility of the plan sponsor.
• Investment Education – Provide education on general investment product types and strategies.
• Performance Reports – Provide performance reports generated through a Silver Grove approved performance reporting vendor.
• 404(c) Assistance – assist plan in identifying investment options under the “broad range” requirement of ERISA 404(c)
• Non‐Discretionary Model Portfolios ‐ IAR will recommend, for consideration and approval by Client, asset allocation target‐date or risk‐based model portfolios for the Plan to make available to plan participants, and (ii) funds from the line‐up of investment options chosen by the Client to include in such model portfolios.
• Qualified Default Investment Alternative (QDIA) Assistance – assist client in identifying an investment alternative within the definition of QDIA under ERISA
• Education Services to Plan Sponsor – provide training for members of the plan sponsor or any plan committee with regard to their services, including education with respect to their fiduciary responsibilities.
• Participant Enrollment – assist and/or provide resources to assist the plan in enrolling plan participants in the plan, including facilitating agreed upon enrollment meetings and providing participants with information about the plan such as terms and operation of the plan, benefits of plan participation, benefits of increasing plan contributions, and impact of preretirement withdrawals on retirement income
• Participant Education – facilitate individual or group investment education meetings for plan participants providing information about investment options under the plan such as investment objectives and historical performance, explaining investment concepts such as diversification and risk and return, and providing guidance as to how to determine investment time horizon and risk tolerance. This will not include individualized investment advice for any participant.
• Changes in Investment Options – assist in making changes to investment options under the plan upon the plan sponsor’s direction. Silver Grove P a g e | 7 will have no discretion over the changes made or be involved in trade execution.
• Vendor Analysis – assist plan with the preparation, distribution and evaluation of Requests for Proposals, finalist interviews and conversion support if applicable.
• Benchmarking Services – provide plan with comparisons of plan data such as fees, services, participant enrollment and participant contributions levels to data from the plan’s prior years and/or similar plans.
• Fee Assessment – assist plan in identifying fees and other costs incurred by the plan for investment management, recordkeeping, participant education, participant communication and/or other services provided. The plan sponsor is responsible for determining whether to implement any recommendations provided by Silver Grove. Silver Grove does not take discretion with respect to plan assets and Silver Grove does not provide individualized advice to participants in the plan. Silver Grove and their IAR’s may also provide clients investment advice on a more limited basis on one or more isolated areas of concern such as estate planning, real estate, retirement planning, or any other similar specific topic. In Addition, Silver Grove may provide advice on non‐securities matters in connection with the rendering of estate planning, insurance, real estate, maximizing social security benefits and/or annuity advice. C. Written Acknowledgement of Fiduciary Status 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 interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. D. Client Account Management – Prior to engaging Silver Grove Advisory Services to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that defines the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – Silver Grove Advisory Services, in connection with the Client, may develop a statement that summarizes the Client’s investment goals and objectives along with the broad strategy[ies] to be employed to meet the objectives.
• Asset Allocation – Silver Grove Advisory Services will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance of risk for each Client.
• Portfolio Construction – Silver Grove Advisory Services will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Silver Grove Advisory Services will provide investment management and ongoing oversight of the Client’s investment portfolio. E. Wrap Fee Programs For certain accounts, Silver Grove Advisory Services includes securities transaction fees together with its investment advisory fees. Including these fees into a single asset‐based fee is considered a “Wrap Fee Program”. The Advisor customizes its investment management services for its Clients. The Advisor sponsors the Silver Grove Advisory Services Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid its own transaction fees. Please see Appendix 1 –Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure. F. Assets Under Management As of December 2023, Silver Grove Advisory Services manages discretionary assets under management of $256,404,965