General Information Colton Groome Financial Advisors, LLC (formerly “CG Advisory Services, LLC”) was founded in 2003. CGFA is a wholly-owned subsidiary of Groome Holdings, LLC (doing business as Colton Groome Financial, and hereinafter referred to as “CG”), which is managed by G. Tatum Groome and Matthew L. Groome. CGFA offers the following services, each of which is more fully described below:
• Investment Advisory Services;
• Financial Planning Services; and
• Retirement Plan Consulting Services. Investment Advisory Services Financial Profile and Investment Plan CGFA provides discretionary and non-discretionary Investment Advisory Services to individuals and high net worth individuals, retirement plans (including defined contribution plans, 401(k) plans, 403(b) plans, 457 plans and profit-sharing plans) and their participants, charitable organizations, trusts, estates, endowments, foundations, corporations and other business entities. At the outset of each client relationship, CGFA spends time with the client, asking questions, discussing the client’s investment experience and financial circumstances, and broadly identifying major goals of the client. Based on its reviews, CGFA generally develops with each client:
• a financial outline for the client based on the client’s financial circumstances and goals, and the client’s willingness to take investment risk (the “Financial Profile”); and
• the client’s investment objectives and guidelines (the “Investment Plan”) The Financial Profile is a reflection of the client’s current financial picture and a look to the future goals of the client. The Investment Plan outlines the types of investments CGFA will make or recommend on behalf of the client based on CGFA’s own research and analysis in order to meet those goals. The elements of the Financial Profile and the Investment Plan are discussed periodically with each client, but are not necessarily written documents. The Investment Plan will be updated from time to time when requested by the client, or when determined to be necessary or advisable by CGFA based on updates to the client’s financial or other circumstances. It is the responsibility of the client to notify CGFA of any changes to their financial situation or objectives or any other factors that may impact the client’s Financial Profile. Portfolio Management To implement the client’s Investment Plan, CGFA will manage the client’s investment portfolio on a discretionary or a non-discretionary basis pursuant to an investment advisory agreement with the client. As a discretionary investment adviser, CGFA will have the authority to supervise and direct the portfolio without prior consultation with the client. Clients who choose a non-discretionary arrangement must be contacted prior to the execution of any trade in the account(s) under management. This may result in a delay in executing recommended trades, which could adversely affect the performance of the portfolio. This delay also normally means the affected account(s) will not be able to participate in block trades, a practice designed to enhance the execution quality, timing and/or cost for all accounts included in the block. In a non-discretionary arrangement, the client retains the responsibility for the final decision on all actions taken with respect to the portfolio. Notwithstanding the foregoing, clients may request certain reasonable restrictions on CGFA in the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship, with written notice to CGFA. Each client should note, however, that restrictions, if accepted by CGFA, may adversely affect the composition and performance of the client’s investment portfolio. Each client should also note that his or her investment portfolio is treated individually by giving consideration to each purchase or sale for the client’s account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance may differ, and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar clients of CGFA. Separate Account Managers CGFA may recommend or select one or more third party investment advisers or model portfolio providers (each a “Manager”), when appropriate and in accordance with the client’s Investment Plan. Having access to various Managers offers a wide variety of manager styles, and provides the opportunity to utilize more than one Manager for the portfolio. Factors that CGFA considers in recommending/selecting Managers generally includes the client’s stated investment objective(s), management style, performance, risk level, reputation, financial strength, reporting, pricing and research. The Manager(s) may be granted discretionary or non-discretionary trading authority to provide investment supervisory services for all or a portion of the portfolio. Other Managers may be engaged to provide research and trading signals to CGFA in connection with certain model portfolios offered by the Manager. Where a Manager has been engaged to provide non-discretionary investment advice, CGFA will typically receive the Manager’s recommendations and thereafter effect trades on behalf of the Portfolio as determined by CGFA; however, CGFA may allow the Manager to effect trades in the Portfolio if CGFA determines it is in the client’s best interests to do so. Although, CGFA retains the authority to terminate the Manager’s relationship or to add new Managers without specific client consent, clients are typically consulted prior to the engagement or termination of any Manager when it is practicable to do so. CGFA may utilize Managers through one or more direct relationships, where CGFA contracts directly with a Manager to provide sub-advisory, research or signal services to a client portfolio. However, under certain circumstances, the client will select one or more Managers recommended by CGFA and the client, and not CGFA, will enter into a separate agreement which each Managers.
• Direct Relationships. When CGFA engages a Manager directly to provide discretionary or non- discretionary advisory services for a client portfolio, it will enter into a Sub-Advisory Agreement with the Manager on behalf of all or a portion of a client’s portfolio. The Manager will then have either discretionary authority to manage the client’s portfolio (or portion thereof), or the Manager will make recommendations to CGFA on a non-discretionary basis, in each case in accordance with the Manager’s strategy that CGFA has selected for the client. Other Managers may be engaged pursuant to a research, signal or model portfolio agreement, pursuant to which the Manager will provide research and trading signals to CGFA in connection with certain model portfolios offered by the Manager. CGFA’s fees do not include: custodial or transaction costs paid to the client’s custodian, brokers or other third-party consultants; fees or taxes on brokerage accounts and securities transactions; wire fees; or fees and expenses charged by mutual funds, exchange traded funds (“ETFs”) or other investment pools to their shareholders (collectively, “Funds”) (generally including a management fee and fund expenses, as described in each Fund’s prospectus or offering materials). Clients should review the statements they receive from their custodian carefully, and promptly notify CGFA of any discrepancies. Please see Item 5 – Fees and Compensation for additional information. Certain clients may request that CGFA hold assets in a client’s portfolio that are not subject to management by CGFA as an accommodation to the client. If CGFA agrees to hold such assets in a client portfolio, CGFA typically will not charge a management fee with respect to such assets. Clients that enter into such arrangements with CGFA should understand that they will not receive the benefits of CGFA’s management services with respect to the unmanaged asset, which means that CGFA will have no obligation to manage, make any recommendation with respect to, monitor or otherwise consider any such asset, even during periods of adverse market conditions or when CGFA otherwise believes that such actions or recommendations

are likely to benefit the client or avoid adverse consequences. Clients will remain responsible for any custodial, transaction or other third-party fees and expenses associated with such unmanaged assets. Services to Retirement Plan Participants CGFA may also provide investment advice directly to plan participants, on a non-discretionary basis. In such a case, CGFA will provide participants with diversification strategies and investment recommendations, and the participants will have the sole responsibility to execute the transactions. In some cases, CGFA may, after approval of the client, instruct the record-keeper or third-party administrator to execute recommendations on the client’s behalf. From time to time, CGFA will also meet with plan participants to provide general investment education, which may include basic information regarding insurance products, annuities, inflation, risk, diversification and asset allocation. Financial Planning Services CGFA also offers Financial Planning Services to clients. Financial Planning Services are typically provided in conjunction with the management of a client’s portfolio, in connection with the creation of the client’s Financial Profile and Investment Plan but may be offered as a stand-alone service for a separate fee. CGFA currently offers four levels of Financial Planning Services, “Concierge”, “Securing Retirement”, “GPS” (Guided Planning Services) and “Investment Management Services”, which include varying levels of services. Information regarding each service level is available from CGFA but is subject to change. CGFA’s Financial Planning Services normally address areas such as general cash flow planning, retirement planning, education planning, “windfall” planning, estate and wealth transfer planning, special needs planning, asset management, tax planning, insurance needs analysis and asset allocation. The goal of this service is to assess the financial circumstances of the client in order to develop a financial plan for the client. To create this plan, CGFA will typically gather information on the client’s financial data and goals, which may include information on the client’s family, employment, property, investments, businesses, insurance, income, expenses, savings, retirement goals, risk tolerance and the client’s objectives related to the foregoing. It is however the responsibility of the client to notify CGFA of any changes to their financial situation or objectives or any other factors that could impact the client’s financial plan. In all matters, CGFA’s Financial Planning Services are analytical and advisory only and do not include legal, tax, accounting or other professional services unless specifically stated. CGFA’s representatives can work with a client’s legal, accounting, tax, insurance or other professional advisors to ensure the coordination of all pieces involved in the financial planning and/or estate planning process at the client’s request. The financial plan may include specific financial and investment strategies as well as specific product recommendations, including equity, fixed income, insurance products, as well as asset allocation recommendations. At no time, however, is the client under any obligation to implement (with CGFA or with any other firm) any of the suggestions outlined in the financial plan. Rather, implementation of a client’s financial plan is solely at the client’s discretion. Certain information provided in connection with Financial Planning Services may include educational materials regarding the effect of taxes, which information is general in nature. However, clients should be aware that CGFA does not render tax, legal or accounting advice, and that CGFA does not prepare any legal documents for the implementation of any of its recommendations. Nothing recommended or outlined by CGFA should be used by a client as a substitute for competent legal, accounting or tax counsel provided by the client’s personal attorney, accountant and/or tax advisor. As part of its Financial Planning Services, CGFA can provide insurance reviews. These reviews are general in nature and are intended to provide a client with an understanding of the general amount of insurance coverage recommended for persons in comparable financial situations. Unless otherwise expressly requested by the client and agreed to by CGFA, these reviews will not include any recommendations about the client’s property or casualty policies (e.g., homeowner’s, automobile and similar policies). Clients should be aware that risk management through the use of insurance coverage is important, and CGFA strongly recommends that each client review each area of potential and/or actual coverage need with the client’s insurance agent to ensure that adequate coverage exists. Retirement Plan Services CGFA offers discretionary and non-discretionary consulting services to 401(k) and other employer- sponsored retirement plans (“Retirement Plan Services”). When engaged to provide Retirement Plan Services, CGFA will typically work with the plan trustees or fiduciaries to provide one or more the following initial and ongoing services:
• Establishment of an Investment Policy Statement
• Analysis, review, and recommendation of investment selections
• Annual plan review
• Attendance at annual investment committee meeting
• Coordination of plan participant communication
• Educational meetings for employees
• Continuing individual participant support The actual terms of any engagement, including the Retirement Plan Services to be provided, will be negotiated between CGFA and the plan. As of 12/31/2023 CGFA provided retirement plan consulting services to plans with assets of $581,400,097. General Consulting Services In addition to the foregoing services, CGFA provides general consulting services to clients in certain cases. These services are typically provided in conjunction with Financial Planning Services or Retirement Plan Consulting Services, as and when requested by the client and agreed to by CGFA. CGFA will introduce a third-party service provider to assist the client with participation in securities class action lawsuits pertaining to the assets under CGFA’s management. CGFA would then provide trade data and other necessary information to the third-party service provider, which would research class action cases and complete and calculate the applicable proof of claim. The third-party service provider would then file the applicable proof of claim with the claims administrator, verify payment received from the claims administrator and distribute the payment to the client minus a twelve and one-half percent (12.5%) contingency fee of securities class action settlements collected. Otherwise, if clients choose not to engage in the class action monitoring, filing, and recovery services provided by the third-party service provider, clients will be exclusively responsible for voting in all legal proceedings or other type events pertaining to the assets under CGFA’s management including, but not limited to, class action lawsuits. 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 1 of the Employee Retirement Income Act (ERISA) and 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 out 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 a level fee that is reasonable for our services; and Give you basic information about conflicts of interest. Type and Value of Assets Currently Managed As of 12/31/2023 CGFA had $339,655,442 in regulatory assets under management for its clients on a discretionary basis and $11,192,366 in regulatory assets under management for its non-discretionary clients.