Portfolio Resources Advisor Group, Inc. (hereinafter referred to as “PRAG” and/or “the firm” and/or “we”) was established in April 2007 and approved as a Registered Investment Adviser in December 2007. Antonio Camejo is the President and a 33.33% owner. Jose M. Maraver, and Inversiones Sosabas, a foreign entity, are each 33.33% owners of PRAG. ADVISORY SERVICES – TYPES OF CLIENTS PRAG provides administrative, investment supervisory and portfolio management services to individuals, qualified investors, trusts, estates, charitable organizations, corporations, and business entities. PRAG utilizes various advisory programs offered through Envestnet Asset Management, Inc. (“Envestnet”), and/or other independent money management technology platforms ("Management Platforms") that PRAG may utilize in the future. PRAG also has investment management agreements with First Affirmative Financial Network (FAFN) and other independent third-party managers, included also in the term “Management Platforms” in this Brochure. PRAG is responsible for all advice, and suitability of such advice, regarding these accounts. A full description of the specific managers recommended to a particular client is provided in the PRAG Investment Management Agreement (IMA), the Statement of Investment Selection (SIS) agreement, and/or through individual manager Form ADV’s. PRAG provides discretionary account management in which the client is provided with on-going investment advice and monitoring with respect to their securities holdings. PRAG will manage the account according to the client’s objectives and restrictions as outlined in an Investment Policy Statement (IPS) or Statement of Investment Selection (SIS). Custodians utilized for the programs below include Pershing LLC., Schwab Institutional, Folio Investments, Inc., and any other custodian with whom PRAG may establish a relationship in the future. PRAG also provides administrative advisory services to third- party independent RIAs, such as billing and performance reporting, through its relationship with various technology platforms. On occasion, PRAG advisors hold client seminars and/or educational workshops to discuss investment issues and opportunities. Such client presentations are previously approved by the firm’s compliance department and are free of charge to clients. Seminars or workshops are advertised in various media publications including the use of email and the internet. Such advertising requires prior approval by the firm. Any interested party is welcome to attend. Pershing LLC. provides custody, transaction, and banking services through PRAG’s affiliated broker-dealer, Portfolio Resources Group, Inc. (“PRG”). The firm presently offers the following types of advisory services: I. Managed Account Solutions (Wrap Fee Program) II. Non-Wrap Fee Programs III. PRAG Investment Consulting (PRAG-IC) IV. Financial Planning TYPES OF ADVISORY SERVICES (TYPES OF INVESTMENTS): I. Managed Accounts Solutions (Wrap Fee Program) The “Wrap Fee Programs” offered are typically through third party money management platforms such as Envestnet Asset Management, Inc., First Affirmative Financial Network (FAFN), and other management platforms that PRAG may utilize in the future. Wrap Fee Programs are sponsored by PRAG under the Management Platforms in the same manner as described in this document. PRAG receives advisory fees for its portfolio management services as described in Appendix 1 of its Form ADV Part 2A (Wrap Fee Program Brochure). PRAG will deliver Investment Management Agreement (IMA) Disclosure Documents or a Statement of Investment Selection (SIS) for details on fee structure and account services. These programs function under a “wrap-fee” billing program which means that there is one total fee covering the cost of the portfolio manager, platform fees, transaction (custodial) costs, fees imbedded in certain types of securities, and the advisor (PRAG) fee. Management Platforms, acting as billing service providers calculate the “Program Wrap Fee”, and give instructions to custodians to debit from the Clients account the fees due. Either Management Platforms pay the applicable parties, or the custodian pays PRAG and PRAG then pays the applicable parties. “Program Wrap Fee” includes the cost of Sub- Managers, Model Providers, reporting and billing, the Advisory fee (PRAG’s Advisory fee), and the custodian fee. There are no additional charges to the client other than the program wrap-fee the client agrees to for the investment program selected on the Management Platforms, unless otherwise disclosed in the IMA/SIS and agreed to by the client. The custodian that executes transactions and holds securities, and the technology management platform that provides performance reporting and other functions, sometimes have minimum fees that can impact the asset-based fee (expressed in basis points, percentages or flat fee) that is charged for a particular program. Minimum fees become effective if the account assets under management fall below the recommended minimum investment size. Minimum fees need to be considered when selecting an investment program. Depending on the amount of funds available for investment, minimum fees can raise the percentage cost of assets under management of a particular program. These programs are as follows:
• Separately Managed Accounts (SMA): In this program, assets are managed by institutional and/or independent money managers. In some cases, the program includes manager due diligence by the Management Platform (for “approved managers” only), assistance in evaluating separate account managers, and provides access to a wide range of managers and investment disciplines, including available managers not directly approved by Management Platforms (“available managers”). The program also includes professional money management, performance reporting, and associated services and support.
• Unified Managed Accounts (UMA) and Multi- Manager Account (MMA) Programs: These programs combine multiple investment styles facilitating diversification within an individually managed account. The program includes professional money management, manager due diligence, and performance reporting. Additionally, the UMA and MMA may include Management Platforms as overlay portfolio manager to manage the asset allocation of the account and coordinate trading across investment sleeves.
• Third Party Strategist-ETF/Mutual Fund Wrap Program: In this program, assets are allocated across a range of mutual funds or ETFs. Clients may select one or more asset allocation portfolio strategies consisting of either mutual funds or exchange- traded funds (ETFs). Accounts are managed on a discretionary basis. Management Platforms develop portfolio asset allocation, selects the underlying funds populating the respective model strategy and annually rebalances the client’s account to the original allocation. This program offers investment strategies including Aggressive Equity, Growth Equity, Balanced with Growth, Balanced, Equity Income and Income portfolios.
• Impact Investing Wrap-Fee Program (PRAG-SRI Wrap): Portfolios managed under social and environmentally responsible or Impact Investing criteria (SRI), such as the High Impact Wrap-Fee Program, managed by Thomas Moser. It takes into consideration the individual objectives of each client but may or may not represent the overall objectives of the client’s total investment assets. PRAG advisors have access to and may employ various investment strategies utilizing managers who either screen their investments or base their entire investment approach on SRI criteria. PRAG has a management agreement with First Affirmative Financial Network (FAFN), an advisory firm that specializes in SRI investing solutions. PRAG advisors have access to the strategies and managers under the FAFN network. PRAG participates in the management fees of the High Impact Wrap-Fee program. Therefore, the firm, the portfolio managers, or its advisors could be motivated to recommend these PRAG strategies over those of other managers. However, this potential conflict of interest is mitigated by the fact that, as fiduciaries, the firm, the portfolio managers, and all PRAG advisors are ethically obligated to make investment recommendations only in the best interests

of the client irrespective of any other consideration. II. Non-wrap-fee programs Non-wrap-fee programs are also available. In these programs, the custodial or transaction portion of the fees is charged on a transactional basis, rather than as a fixed cost based on assets under management. This approach may make sense for managing fixed income portfolios, for example, where the number of transactions is smaller in number than in an equity portfolio. These non-wrap-fee portfolios utilize custodians such as Pershing, o r Schwab Institutional to provide brokerage, custody, and related services to client accounts. Custodians such as Schwab, and/or Management Platforms, do not determine suitability of advice for any client. PRAG is responsible for all advice and suitability of such advice regarding these accounts. The Program may cost a client more or less than purchasing the services separately. Factors bearing on the relative cost of the Program that would be relevant when considering the alternative of purchasing the services offered in the Program separately include the trading activity in a client's account and the corresponding brokerage commissions that would be charged for execution of trades, and the fees charged for investment advisory services. Management Platforms provide third-party, arms-length, independent performance reporting and billing under these programs. The programs are as follows:
• Advisor Directed Models/Representative as Portfolio Manager: PRAG advisors are provided a set of tools to construct and manage model portfolios. This program allows selected financial advisors to manage client portfolios for a fee plus custodial transaction fees. PRAG will enter into an Investment Management Agreement with the client, under which PRG and its clearing firm, Pershing LLC., or Schwab Institutional provide services in association with Envestnet Asset Management, Inc.
• Impact Investing Non-Wrap Fee Program (PRAG-SRI- Non-Wrap): Portfolios managed under social, environmental, and sustainability criteria, such as the High Impact Non-Wrap Fee Program, take into consideration the individual objectives of each client, but may or may not represent the overall objectives of the client’s total investment assets. PRAG advisors have access to and may employ various investment strategies utilizing managers who either screen their investments or base their entire investment approach on SRI and sustainability criteria. Managed accounts are designed to provide discretionary management by an Advisor Representative of the firm and/or SRI sub-managers. PRAG assists each PRAG-SRI account client in formulating investment objectives and manages the account within established guidelines regarding, among other matters, diversification and designation of securities that may be purchased. III. PRAG Investment Consulting (PRAG-IC) Selected Registered Investment Advisors (RIAs) are evaluated by the firm for client use. PRAG-IC services may include assisting clients in identifying their investment objectives and matching personal and financial data with a select list of investment managers that meet the PRAG-IC minimum quantitative and qualitative criteria. The intent of the program is to have a selected list of high quality and recognizable independent investment management firms from which one or more managers are selected to handle the day-to-day management of client accounts. Managers selected for use by clients under the PRAG-IC program need to meet several quantitative and qualitative criteria. Among the criteria that may be considered are the manager’s experience, assets under management, performance record, client retention, the level of client services provided, investment style, buy and sell disciplines, capitalization level and the general investment process. Each advisor must have a client profile that outlines the client’s stated objectives and risk tolerance. There is the potential for a conflict of interest in that PRAG could be motivated to recommend its sponsored Programs to clients, however, PRAG “approved” managers are evaluated with the same criteria and parameters as any other manager on recommending investment to clients. When recommending outside investment managers, the firm first analyzes the client's existing portfolio, if applicable, to determine the investment style that will best facilitate the desired diversification of the portfolio. The firm then identifies strategies or managers that exhibit the desired investment attributes. The firm helps the client measure the performance of the managers by making comparisons to appropriate benchmarks. Depending on client objectives, the firm may advocate an active or passive investment strategy using a diversified approach. Each Client’s account is managed on the basis of the Client’s financial situation and stated investment objectives, in accordance with the Client’s reasonable investment restrictions imposed by Client on the management of the assets in the account. Clients will be contacted at least annually by their Advisor Representative in order to confirm whether there have been any changes to the Client’s financial situation, investment objectives or if the Client would like to impose or modify investment restrictions on the account. The firm utilizes a team approach in designing and supervising client portfolios, including a strategic relationship with independent money management technology platforms such as Envestnet Asset Management, Inc., a nd First Affirmative Financial Network (FAFN), PRAG offers FINRA & SIPC member broker/dealers s u c h a s Portfolio Resources Group, Inc., a n d Schwab Institutional as possible custodial relationships. The firm has access to independent consultants and financial publications to obtain information a b o u t companies and managers. The firm also uses research materials prepared by others, academic studies, third-party databases, and other publicly available information. The firm may at any time terminate the relationship with an advisor that manages clients’ assets. Factors involved in the termination of an advisor may include a failure to adhere to management style or clients’ objectives, a material change in the professional staff of the advisor, unexplained poor performance, dispersion of client account performance, or the firm’s decision to no longer include the advisor as one of its approved program managers. IV. Financial Planning Upon specific request by the client, the Firm may provide either financial consulting or a comprehensive financial plan tailored to meet the client’s needs and investment objectives as described by the client. These services may include, but are not limited to, the following: identification of financial goals, preparation of financial condition statements, stock option exercising strategies, cash flow, net worth, and income tax projections, insurance analysis, education funding options, retirement planning, retirement plan distribution strategies, estate tax analysis and planning, business planning, charitable planned giving, and asset allocation analysis. During meetings with the client the investment philosophy, risk tolerance and investment objectives are discussed. When appropriate, the firm encourages clients to use the services of an estate attorney and makes clear that the firm does not render legal, accounting, or tax advice. The firm will a l s o not advise the client or act for the client in any legal proceedings, including bankruptcies, involving securities held or previously held, or the issuers of those securities. The firm will not vote proxies for securities held in client accounts. As of August 31, 2023, PRAG held $107,846,099 million in regulatory discretionary assets under management. As of that same date, PRAG did not hold any non-discretionary assets under management. PRAG also provides administrative services such as performance reporting to $293.7 million in non-discretionary assets as of August 31, 2023, and PRAG’s affiliated broker/dealer, Portfolio Resources Group, Inc. (PRG) held $1.4 billion in total client assets.