EPG Wealth Management LLC (“EPG”) was established as a Registered Investment Adviser in 2019. Through independently owned limited liability companies, Alex Reffett and David Curry, are the principal owners of EPG. EPG uses a variety of models, each with different investment objectives and asset allocation guidelines. The models are managed by an investment committee which has an investment philosophy driven by the Prudent Investor Rule. The Prudent Investor Rule provides guidance to investment managers regarding the standards for managing an investment portfolio in a fiduciary relationship. This standard requires the exercise of reasonable care, skill, and caution, and is to be applied to investments not in isolation but in the context of the portfolio and as a part of an overall investment strategy, which should incorporate risk and return objectives reasonably suitable to the portfolio. In implementing the Prudent Investor Rule, we implement five basic principles: 1. Sound diversification is fundamental to risk management and is therefore ordinarily required of the Investment Committee. 2. Risk and return are so directly related that the Investment Committee has a duty to analyze and make conscious decisions concerning the levels of risk appropriate to the purposes, distribution requirements, and other circumstances of the Portfolio. 3. The Investment Committee has a duty to avoid fees, transaction costs, and other expenses that are not justified by needs and realistic objectives of the Portfolio. 4. The fiduciary duty of impartiality requires a balancing of the elements of return between production of income and the protection of purchasing power. 5. The Investment Committee may have a duty as well as having the authority to delegate as prudent investors would. The portfolio construction process begins by using fundamental analysis to seek out individual assets or asset classes that are trading below “Intrinsic Value.” Intrinsic value is the value of an enterprise as defined by prudent investment analysis. The investment analysis focuses on stocks which exhibit an “Economic Moat.” This is the competitive advantage that a business possesses over companies in the same industry. (The stronger the moat, the larger and more sustainable the competitive advantage.) Factor analysis is used to emphasize asset class characteristics showing the most promise for future returns. Factor analysis helps in determining what asset classes to invest, i.e., whether to invest more in large cap stocks or small cap stocks, value stocks or growth stocks, global stocks or domestic stocks, stocks, or bonds, etc. The investment committee, overseen by the CIO, meets regularly to discuss both macro and micro issues. Based on the research, supported by data, we will consider our current exposures and discuss and/or challenge our current investment thesis to make sure it stands up to rigor. ADVISORY MANAGED ACCOUNT SOLUTIONS – CREST ACCOUNTS EPG provides advisory services, giving continuous advice based on the client’s individual needs. Through personal discussions in which goals and objectives based upon the client’s personal objectives are established, the Advisor will develop a personal investment policy, which will include recommended model allocations based upon an investment objective questionnaire and manage the portfolio according to the criteria. Most accounts are managed on a discretionary basis, meaning that the advisor has discretion over what securities to buy and sell. However, clients may elect to have their account managed on a non-discretionary basis, meaning that the client must consent to each trade in the account. This trading discretion and any limitations on it will be set forth in the client agreement. The services provided are the same regardless of the account structure selected. Depending on the client’s investment objectives, the advisor may manage and provide advice on mutual funds, stocks, bonds, exchange traded funds (ETFs), LPs, and options. Alternative investments may be recommended to qualified investors based on the client’s objectives and risk tolerance. Alternative investments could include real estate, Private Equity, Hedge Funds, Commodities, etc. Alternative Investments can provide diversification benefits to traditional portfolios of stocks and bonds. Advisory Managed Account Solutions accounts are offered through Peak, a wrap fee program and Crest, a non-wrap fee program. In a Peak account, the client pays a single fee that covers the advisory services and the execution of transactions through NFS. Clients that anticipate trading primarily in equities and ETFs are typically recommended to open a wrap fee account; clients that anticipate trading in mutual funds with little or no anticipated trading in equities and ETFs will be recommended to open a non-wrap fee account. More information regarding the services and fees of the Peak accounts are separately disclosed in the Peak Wrap Fee Brochure, which is available upon request. In a Crest account, clients pay an advisory fee plus additional transaction- based charges (see Item 5 for more information on fees). Several other factors influence the selection of the account structure, including but not limited to the account size; anticipated trading frequency; anticipated types of securities to be traded; and long-term investment goals. PORTFOLIO MANAGEMENT Portfolio Management is based on the individual objectives of each client portfolio and may or may not represent the overall objectives of the clients’ total investment assets. EPG recommends and employs various investment strategies. Portfolio Management accounts are designed to provide discretionary management by an Investment Advisor Representative of the firm. EPG assists each Portfolio Management client in formulating investment objectives and manages the account within established guidelines regarding, among other matters, diversification and designation of securities that are purchased. Portfolio Management accounts may be custodied at Fidelity Institutional Wealth Services (“FIWS”), or Charles Schwab & Co. (“Schwab”) For these accounts, each portfolio is tailored to a client’s particular investment needs and circumstances. This includes discretionary investment management in accounts based on the client’s investment needs and a risk strategy (from conservative to aggressive), which is selected in conjunction with the client and incorporated into the account agreement. Under the terms of the agreement with the client, the Advisor will:
• Establish the investor’s risk profile, investment objectives and time horizon through personal discussions with the client.
• Set a relevant asset allocation policy for the investor.
• Diversify among asset classes and styles.
• Rebalance the investor portfolio as deemed necessary by the Advisor.
• Report and review investment results from time to time. Reviews may include client’s performance in light of identified needs and objectives. They will be conducted on a continuous or periodic basis, as agreed upon by the client and in the Agreement with the client.
• Recommend changes in the client’s investments, investment strategy or objectives. Recommendations may be given in connection with the review of the client’s current investments or the client’s financial needs, or objectives as identified by the client.
• Report the current status of client holdings on a periodic basis. THIRD PARTY ASSET MANAGEMENT CONSULTING SERVICES EPG Wealth offers access to third-party asset managers who offer a wide range of asset classes and strategies through which our clients can invest. Our investment adviser representatives will typically recommend and assist the client in selecting these third-party managers and will consult with the client regarding those services. The third-party managers recommended by EPG Wealth will typically manage accounts using investment discretion, meaning that the client is not required to approve every proposed transaction. The client grants discretion to the third- party manager in a separate agreement between the client and the third-party manager. EPG Wealth may assist clients by recommending that assets be allocated among multiple managers, but EPG does not have discretion to select the manager or to allocate or re-allocate the client’s assets. Whenever a client selects the services of a third-party manager, the client will receive a disclosure brochure similar to this one describing the manager and the services it provides. The client may also receive a disclosure brochure or a brochure supplement describing each individual portfolio manager selected. Clients should read these disclosure brochures carefully before deciding whether to select a particular portfolio manager. The list of third-party managers recommended by EPG Wealth changes from time to time, at EPG Wealth’s discretion. RETIREMENT PLANNING EPG Wealth provides Retirement Plan consulting services to plans and plan fiduciaries as described below. The appropriate Plan Fiduciary(ies) designated in the Plan documents (e.g., the plan sponsor or named fiduciary) will (i) make the decision to retain our firm; (ii) agree to the scope of the services that we will provide; and (iii) make the ultimate decision as to accepting any of the recommendations that we may provide. The Plan Fiduciaries are free to seek independent advice about the appropriateness of any recommended services for the Plan. Retirement Plan consulting services may be offered individually or as part of a comprehensive suite of services. ERISA sets forth rules under which Plan Fiduciaries may retain investment advisers for various types of services with respect to Plan assets. EPG Wealth acts as a fiduciary under ERISA Section 3(21). As such, EPG Wealth works with clients to recommend the investment choices for a plan among which the plan participants may select. EPG Wealth does not have discretion over plan investments, and Retirement Plan clients will retain control of the plan’s investments and will approve the fund lineup. With respect to any account for which EPG Wealth meets the definition of a fiduciary under Department of Labor rules, EPG Wealth acknowledges that both EPG Wealth and its Related Persons are acting as fiduciaries. Additional disclosure may be found elsewhere in this Brochure or in the written agreement between EPG Wealth and Client. Under ERISA Section 3(21), EPG Wealth offers the following fiduciary services:
• Development of Investment Policy Statement
• Recommendations for selecting and monitoring the Plan’s investments.
• Investment performance measurement and analysis
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Recommendations for allocating and rebalancing model asset allocation portfolios; and
• Individualized investment advice to plan participants. RETIREMENT PLAN SERVICES FOR ERISA 3(38) PLANS EPG Wealth is not a fiduciary as defined under ERISA section 3(38), but does utilize a third- party investment manager, Brinker Capital Investments (“Brinker”), an SEC registered investment adviser, to serve as the fiduciary for 3(38) plans. In this role, EPG Wealth and its representatives act as a fiduciary under 3(21) with respect to its recommendation of Brinker to provide investment advisory services, (ii) assure that our representatives comply applicable law, with respect to its recommendation of Brinker, including assuring that our fee does not exceed a reasonable fee; and (iii) notify Brinker promptly in the event EPG is no longer in compliance with any applicable law. Brinker Capital Investments offers its “Retirement Plan Services” to our plan sponsors, by utilizing Brinker's Destinations investment strategies for tax-exempt accounts, as well as mutual fund and ETF evaluation and selection to sponsors of retirement plans covered by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and other qualified and non-qualified deferred compensation plans. The Retirement Plan Services is available to plans with at least $250,000 of investable assets. The Retirement Plan Services Program is provided in conjunction with a recordkeeping service provider, who may also provide Plan administration (the “recordkeeper”) and generally is a broker dealer or investment advisory firm. In the Retirement Plan Services Program, the Plan sponsor enters into both (i) an investment advisory agreement with Brinker, and (ii) a separate administrative and recordkeeping services agreement with the recordkeeper. Pursuant to the investment advisory agreement, the third-party adviser (Brinker) provides to the Plan sponsor and assists the Plan sponsor in selecting a group of investment strategies, which may include the Destinations Funds, which the Plan sponsor then makes available to Plan participants as investment options under the Plan. Brinker also provides the Plan sponsor with a participant questionnaire, which the Plan sponsor makes available to Plan participants to assist each Plan participant in determining his or her investment goals and objectives and risk tolerance and in selecting a suitable investment strategy for the participant's Plan account. Brinker implements certain investment strategies selected by the Plan sponsor and made available to Plan participants. Brinker has full discretion in selecting the funds to be included in the asset allocation models used to implement the investment strategies. Brinker reviews the models on a periodic basis and updates and rebalances the models from time to time in accordance with the related investment strategy, considering the performance of the funds, market conditions and other factors it deems appropriate, and electronically transmits changes to the models to the recordkeeper. The recordkeeper is responsible for executing trades in the Plan participants' accounts to reflect changes in the models provided by Brinker. Brinker also offers evaluation and selection services to identify a limited number of unaffiliated mutual funds and/or ETFs in which Plan participants may invest their Plan accounts. Plan sponsors who elect this additional service authorize Brinker to select additional funds. If a Plan sponsor elects the additional fund evaluation service, Brinker is authorized to select, add, remove and/or replace funds available for purchase by Plan participants consistent with any written investment policy approved by the Plan sponsor and provided to Brinker and with any requirements under ERISA, based upon Brinker's evaluation of each fund's performance, market conditions and other factors it deems appropriate. Plan sponsors can, however, specify securities which cannot be purchased. If Brinker adds a new fund or replaces a fund on the additional fund list, Brinker will notify the Plan sponsor sufficiently in advance of such action to enable the Plan sponsor to provide any notice to Plan participants required under ERISA. The Plan sponsor is responsible for delivering to Plan participants any change notice required under ERISA informing such Plan participants how their accounts will be invested as of the change if the Plan participant fails to provide affirmative investment directions. Brinker is responsible for monitoring the relevant data on the performance of each mutual fund, ETF and Destinations model and provides periodic reporting on the performance of each fund and Destinations model. RETIREMENT PLAN ROLLOVER RECOMMENDATIONS To the extent we recommend you roll over your account from a current retirement plan to an individual retirement account (“Rollover IRA”), managed by EPG please know that EPG and our investment adviser representatives have a conflict of interest. We can earn increased investment advisory fees by recommending that you roll over your account at the retirement plan to a Rollover IRA managed by EPG. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to a Rollover IRA managed by EPG. Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to a Rollover IRA which is a conflict of interest because our recommendation that you open an IRA account to be managed by our firm can be based on our economic incentive and not based exclusively on whether or not moving the IRA to our management program is in your overall best interest. We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in EPG receiving unreasonable compensation related to the rollover of funds from the retirement plan to a Rollover IRA, and (iii) fully disclose compensation received by EPG and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to a Rollover IRA and refrain from making any materially misleading statements regarding such rollover. FINANCIAL PLANNING EPG offers advice in the form of a Financial Plan. Clients will receive a written financial plan, providing the client with a detailed financial plan designed to achieve their stated financial goals and objectives. In general, the plan will address any or all of the following:
• Personal: Family records, budgeting, personal liability, estate information and financial goals
• Tax and Cash Flow: Income tax spending analysis and planning for past and future years.
• Death and Disability: Cash needs at death, income needs of surviving dependents, estate planning.
• Retirement: Strategies and investment plans to help client achieve their retirement goals
• Investments: Analysis of investment alternatives and their effect on a client’s portfolio. Information on clients will be gathered by in-depth personal interviews and review of personal financial information. Gathering data concerning current financial status, future requirements, risk appetite and goals is essential. Based upon this thorough review, a written plan is prepared for the client providing the client with a detailed financial plan designed to achieve their stated financial goals and objectives. It is recommended that the client review this plan with tax accountants, attorneys, and other professional service providers. Clients are not under any obligation to engage EPG when considering implementation of advisory recommendations. The implementation of any or all recommendations is solely at the discretion of the client and can be implemented through another RIA. In addition to the aforementioned services, EPG offers investment data storage and periodic comprehensive reporting services which can incorporate all of the client’s investment assets, including those investment assets that are not part of the assets managed by EPG (the “Excluded Assets”). Should the client utilize these reporting services, the client acknowledges and understands that with respect to the Excluded Assets, EPG’s service is limited to reporting and data storage services only and does not include investment management, review, or monitoring services, nor investment recommendations or advice. As such, EPG will not be responsible for the investment performance of the Excluded Assets. If the client requests EPG to provide investment management services with respect to the Excluded Assets, the client may engage EPG to do so for a separate and additional fee. Each client has the ability to impose reasonable restrictions on the management of his/her account, including the designation of particular securities or types of securities that should not be purchased for the account, or that should be sold if held in the account. If a client’s instructions are unreasonable or an Investment Advisor Representative believes that the instructions are inappropriate for the client, EPG will notify the client that, unless the instructions are modified, it will cancel the instructions in the client’s account. A client will not be able to provide instructions that prohibit or restrict the Investment Adviser of an open-end or closed-end mutual fund or ETF with respect to the purchase or sale of specific securities or types of securities within the fund. As of December 31, 2023, EPG managed $642,643,943 in regulatory assets under management (RAUM), which means securities portfolios for which EPG provides continuous and regular supervisory or management services. All of the regulatory assets under management are done on a discretionary basis. The Firm had no non-discretionary assets. As of December 31, 2023, EPG had $131,447,297 in Assets Under Advisement which means these are assets on which EPG provides advice or consultation, but for which EPG does not have discretionary authority, and does not arrange or effect a transaction. These types of services may include consulting services where the assets are used for the informational purpose of gaining a full perspective of the client’s financial situation, but EPG is not actually placing the trade. It could also mean that these are assets for which EPG may monitor for a client on a non- discretionary basis and make recommendations but where the client is the party responsible for arranging or effecting the purchase or sale.