A. TKG Advisors, LLC dba Kotys Wealth Professionals (“KWP”) was founded in 2013. Wesley Kotys is KWP’s Founder and serves as its Chief Executive Officer and Chief Compliance Officer. Mr. Kotys is also the sole trustee of KWP’s owner, the Wesley M. Kotys Revocable Trust dated April 5, 2023. B. As discussed below, KWP provides investment supervisory services, also known as asset management services, and to the extent specifically requested by a client, furnishes financial planning and investment advice through consultations. ASSET MANAGEMENT KWP offers discretionary and non-discretionary asset management services to advisory clients on a fee basis. The client can also engage KWP to provide services limited to the management of the investment sub accounts of variable annuity products previously purchased by the client on a fee basis. INVESTMENT ADVISORY SERVICES The client can engage KWP to provide discretionary or non-discretionary investment advisory services on a fee basis. KWP’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under KWP’s management. Before engaging KWP to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement with KWP setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. KWP’s annual investment advisory fee shall include investment advisory services, and, for clients with assets under KWP’s management exceeding $500,000, financial planning and consulting services. For clients with less than $500,000 in assets under KWP’s management, KWP may determine to charge a $750 minimum planning fee in addition to the client’s standard investment advisory fee, if the client elects to receive such financial planning and/or consulting services. In the event that the client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of KWP), KWP may determine to charge for such additional services pursuant to a stand-alone Financial Planning Agreement (see below). Please Note: KWP believes that it is important for the client to address financial planning issues on an ongoing basis. KWP’s advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to address financial planning issues with KWP. To commence the investment advisory process, an investment adviser representative will first ascertain each client’s investment objectives and then allocate and/or recommend that the client allocate investment assets consistent with the designated investment objectives. Once allocated, KWP provides ongoing monitoring and review of account performance and asset allocation as compared to client investment objectives, and may rebalance and/or may recommend that clients rebalance accounts as necessary based on such reviews. CASH MANAGEMENT Clients may also engage KWP to provide cash management services. KWP’s annual fee for cash management services is based upon a percentage (%) of the market value of the assets placed in the cash management program, in accordance with the client’s Cash Management Agreement. KWP shall generally invest cash management assets in short term bonds, exchange-traded funds, certificates of deposit (CDs), United States Treasuries, structured notes, and mutual funds. KWP imposes a $100,000 minimum investment for cash management services, which asset minimum may be waived or reduced by KWP, at its sole discretion. VARIABLE ANNUITY MANAGEMENT The client can also engage KWP to provide investment advisory services through its Variable Annuity Management Program (the “VA Program”). Under the VA Program, KWP allocates client investment assets on a fee basis, among the investment subaccounts of variable annuity products previously purchased by the client. Once allocated, KWP provides ongoing monitoring and review of subaccount performance, asset allocation, and client investment objectives. ERISA PLAN SERVICES KWP provides service to qualified and non-qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit sharing plans, cash balance plans, and deferred compensation plans. KWP may act as either: ERISA 3(21) Fiduciary. KWP typically acts as a 3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using KWP can help mitigate that plan sponsor’s liability by following a diligent process. ERISA 3(38) Investment Manager. KWP can also act as an ERISA 3(38) Investment Manager in which it has discretionary management and control of a given retirement plan’s assets. KWP would then become solely responsible and liable for the selection, monitoring and replacement of the plan’s investment options and, to the extent requested by the plan, the ongoing management of discretionary investment allocation models made available to plan participants. In such engagements, KWP will serve as an investment fiduciary as that term is defined under ERISA. KWP will generally provide services on an “assets under management” fee basis per the terms and conditions of an Investment Advisory Agreement between the Plan and the Firm. QUALIFIED PLAN CONSULTING SERVICES KWP offers Qualified Plan Consulting Services to individuals relative to 401(k) plan assets maintained by the client in conjunction with the retirement plan established by the client’s employer. KWP will meet with the client for information gathering initially and then every quarter thereafter for review and recommendations. Every quarter, KWP will review the investment options available within the plan and make investment recommendations to the client based on the investment options available and the client’s financial objectives. It is ultimately the clients’ decision to execute the recommendations made by KWP. KWP’s ability shall be limited to the allocation of the assets among the investment alternatives available through the plan. KWP will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify KWP of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. FINANCIAL PLANNING AND CONSULTING KWP offers financial consulting on specific topics or as a plan for an hourly fee described in Item 5 below. Goal Specific Planning For a modular or goal specific plan, the client may select any one of the following financial planning modules at an hourly fee:
• Retirement Planning
• Succession Planning
• Education Planning
• Estate Planning
• Insurance Planning
• Investment Planning
• Accumulation Planning
• Survivor Needs
• Disability Income
• Long Term Care
• Cash Flow Analysis
• Debt Management
• Tax Planning
• Major Purchase Planning
• Divorce Planning For a financial plan, the client will receive an analysis on any or all of the above modules in order to analyze their complete financial picture. In addition, planning for unique situations such as the sale of a business, managing stock options, or receiving a windfall/inheritance may be included in a comprehensive financial plan. The client retains full discretion to accept or reject any of KWP’s planning recommendations. If the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through KWP. Financial plans will generally be completed and delivered inside of ninety (90) days. MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent requested by a client, KWP may provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. KWP will generally provide such consulting services inclusive of its advisory fee set forth at Item 5 below (exceptions could occur based upon assets under management, extraordinary matters, special projects, stand- alone planning engagements, etc. for which KWP may charge a separate or additional fee). Please Note: KWP believes that it is important for the client to address financial planning issues on an ongoing basis. KWP’s advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to address financial planning issues with KWP. KWP does not serve as a law firm, accounting firm, or insurance agency, and no portion of KWP’s services should be construed as legal, accounting, or insurance implementation services. Accordingly, KWP does not prepare estate planning documents, tax returns, nor does it offer or sell insurance products. To the extent requested by a client, KWP may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance agents, etc.), including KWP’s representatives acting in their capacity as licensed insurance agents (See disclosure at Item 10.C below) . Clients are reminded that they are under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation made by KWP or its representatives. Also, the recommendation by KWP that a client consider the purchase of an insurance product from a KWP representative presents a potential conflict of interest, however, this conflict of interest is mitigated where KWP representatives do not sell insurance commission-based products. Please Note: If the client engages any unaffiliated professional, recommended or otherwise, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional(s) (i.e., attorney, accountant, insurance agent, etc.), and not KWP, shall be responsible for the quality and competency of the services provided. Custodian Charges-Additional Fees. As discussed below at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, KWP generally recommends that Charles Schwab & Co., Inc. (“Schwab”) serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Schwab charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker- dealer/custodian (while certain custodians, including Schwab, do not currently charge fees on individual equity or ETF transactions, others do). Please Note: there can be no assurance that Schwab will not change its transaction fee pricing in the future. Please Also Note: Schwab may also assess fees to clients who elect to receive trade confirmations and account statements by regular mail rather than electronically. When beneficial to the client, individual fixed-income and/or equity transactions may be effected through broker-dealers with whom KWP and/or the client have entered into arrangements for prime brokerage clearing services, including effecting certain client transactions through other SEC registered and FINRA member broker-dealers (in which event, the client generally will incur both the transaction fee charged by the executing broker-dealer and a “trade-away” fee charged by Schwab). These fees/charges are in addition to KWP’s investment advisory fee at Item 5 below. KWP does not receive any portion of these fees/charges. ANY QUESTIONS: KWP’s Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding the above. Data Aggregation Platforms. KWP, in conjunction with the services provided by ByAllAccounts, Orion, eMoney, Riskalyze, and/or other data aggregation platforms may also provide 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 KWP (the “Excluded Assets”). The client and/or their other advisors that maintain trading authority, and not KWP, shall be exclusively responsible for the investment performance of the Excluded Assets. Unless otherwise specifically agreed to, in writing, KWP’s service relative to the Excluded Assets is limited to reporting only. The sole exception to the above shall be if KWP is specifically engaged to monitor and/or allocate the assets within the client’s 401(k) account maintained away at the custodian directed by the client’s employer. As such, except with respect to the client’s 401(k) account (if applicable), KWP does not maintain any trading

authority for the Excluded Assets. Rather, the client and/or the client’s designated other investment professional(s) maintain supervision, monitoring and trading authority for the Excluded Assets. If KWP were asked to make a recommendation as to any Excluded Assets, the client is under absolutely no obligation to accept the recommendation, and KWP shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. In the event the client desires that KWP provide investment management services for the Excluded Assets, the client may engage KWP to do so pursuant to the terms and conditions of the Investment Advisory Agreement between KWP and the client. The eMoney platform also provides access to other types of information and applications including financial planning concepts and functionality, which should not, in any manner whatsoever, be construed as services, advice, or recommendations provided by KWP. Finally, KWP shall not be held responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the eMoney platform without KWP’s assistance or oversight. Client Obligations. In performing its services, KWP shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify KWP if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising KWP’s previous recommendations and/or services. Authorized Agents. In an attempt to enhance services to its clients, KWP has entered into an arrangement with an unaffiliated registered investment adviser (G&S Capital, LLC; CRD: 171033) (“G&S”) for the provision of certain back-office services. Pursuant to this arrangement, certain representatives of G&S have executed documents to become authorized agents of KWP. This arrangement gives such G&S representatives the ability to implement trades on behalf of KWP, at KWP’s direction. Per the terms of this arrangement, no representative of G&S is entitled to make any investment decisions or trades on behalf of any KWP client without prior instruction from an appropriate KWP representative. Retirement Rollovers – No Obligation / Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If KWP recommends that a client roll over their retirement plan assets into an account to be managed by KWP, such a recommendation creates a conflict of interest if KWP will earn a new (or increase its current) advisory fee as a result of the rollover. If KWP provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), KWP is acting as a fiduciary 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. No client is under any obligation to rollover or transfer retirement plan assets to an account managed by KWP, whether it is from an employer’s plan or an existing IRA. Cash Sweep Accounts. Account custodians generally require that cash proceeds from account transactions or cash deposits be swept into and/or initially maintained in the custodian’s sweep account. The yield on the sweep account is generally lower than those available in money market accounts. To help mitigate this issue, KWP shall generally purchase a higher yielding money market fund available on the custodian’s platform with cash proceeds or deposits, unless KWP reasonably anticipates that it will utilize the cash proceeds to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to, the amount of dispersion between the sweep account and a money market fund, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. Please Note: The above does not apply to the cash component maintained within KWP’s actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager, and cash balances maintained for fee billing purposes. Please Also Note: The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any of KWP’s unmanaged accounts. Cybersecurity Risk. The information technology systems and networks that KWP and its third-party service providers use to provide services to KWP’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in KWP’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and KWP are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although KWP has established its processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that KWP does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Margin Accounts: Risks/Conflict of Interest. KWP does not recommend the use of margin for investment purposes. A margin account is a brokerage account that allows investors to borrow money to buy securities and/or for other non-investment borrowing purposes. The broker/custodian charges the investor interest for the right to borrow money and uses the securities as collateral. By using borrowed funds, the customer is employing leverage that will magnify both account gains and losses. Should a client determine to use margin, KWP will include the net value of the margined assets when computing its advisory fee. Please Note: The use of margin can cause significant adverse financial consequences in the event of a market correction. Cash Positions. Depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), KWP may maintain cash and cash equivalent positions (such as money market funds, etc.) for defensive and liquidity purposes. Unless otherwise agreed in writing, all such cash positions are included as part of assets under management for purposes of calculating KWP’s advisory fee. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, KWP’s advisory fee could exceed the interest paid by the client’s money market fund. Please Note: In addition to fees attributable to cash positions within a client’s advisory account, clients who maintain assets in KWP’s cash management program shall be assessed a fee on the cash management account value in accordance with the client’s Cash Management Agreement. ANY QUESTIONS: KWP’s Chief Compliance Officer, Wesley Kotys, remains available to address any questions that a client or prospective may have regarding the above fee billing practice. Non-Discretionary Services Limitations. KWP generally provides its investment advisory services on a discretionary basis and only accepts non- discretionary authority in very limited circumstances, generally as a client accommodation. Clients that determine to engage KWP on a non-discretionary investment advisory basis must be willing to accept that KWP cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event that KWP would like to make a transaction for a client’s account, and client is unavailable, KWP will be unable to effect the account transaction (as it would for its discretionary clients) without first obtaining the client’s consent. Use of Mutual Funds and Exchange Traded Funds. While KWP may recommend allocating investment assets to mutual funds and exchange traded funds that are not available directly to the public, KWP may also recommend that clients allocate investment assets to publicly-available mutual funds and exchange traded funds that the client could obtain without engaging KWP as an investment adviser. However, if a client or prospective client determines to allocate investment assets to publicly-available mutual funds without engaging KWP as an investment adviser, the client or prospective client would not receive the benefit of KWP’s initial and ongoing investment advisory services. In addition to KWP’s investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Portfolio Activity. KWP has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, KWP will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, mutual fund manager tenure, style drift, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when KWP determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by KWP will be profitable or equal any specific performance level(s). Clients remain subject to the fees described in Item 5 below during periods of portfolio inactivity. Client Retirement Plan Assets. If requested to do so, KWP can provide investment advisory services relative to 401(k) plan assets maintained by the client in conjunction with the retirement plan established by the client’s employer. In such event, KWP shall allocate (or recommend that the client allocate) the retirement account assets among the investment options available on the 401(k) platform. KWP’s ability shall be limited to the allocation of the assets among the investment alternatives available through the plan. KWP will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify KWP of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Unless expressly indicated by the KWP to the contrary, in writing, the client’s 401(k) plan assets shall be included as assets under management for purposes of KWP calculating its advisory fee. Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by KWP) will be profitable or equal any specific performance level(s). Disclosure Statement. A copy of KWP’s written Brochure as set forth on Part 2 of Form ADV, along with the Form CRS Relationship Summary, shall be provided to each client before, or contemporaneously with, the execution of the Investment Advisory Agreement or Financial Planning Agreement. C. Prior to providing investment advisory services, an investment adviser representative will discuss with each client, their particular investment objective(s). The goals and objectives for each client are documented in our client files. Investment strategies are then created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. D. KWP does not participate in a wrap fee program. E. As of December 31, 2023, KWP had $223,430,054 in client assets under management on a discretionary basis.