Five Talents Financial Management Group, LLC (FTFMG) is a limited liability corporation organized in the state of Iowa. Gregory Bendinger, Donald Boyd, II, Jeff Jergens and Edward Modglin are the firm’s Owner/Members. Mr. Bendinger, is also the firm’s Chief Compliance Officer. FTFMG is currently registered as an investment adviser with the United States Securities and Exchange Commission (“SEC”), under the Investment Advisers Act of 1940, Rule 203A-2(c) since August 2020. FTFMG is “notice filed” in the state if Iowa and other states as required by state rules and regulations. Investment Adviser Representatives (IAR) of FTFMG that are responsible for giving investment advice must have a FINRA Series 7 License and NASAA Series 66, NASAA Series 65 License or an investment adviser representatives licensing equivalent, such as CFP® designation. FTFMG offers a number of investment advisory services. In addition to the investment advisory services offered under this Form ADV Part 2A Disclosure Brochure FTFMG also provides wealth management services under FTFMG’s Wrap Fee Program. For information on FTFMG’s Wealth Management Programs please review FTFMG’s Wrap Fee Program Brochure. FTFMG Fiduciary Statement - FTFMG is a “fiduciary” under ERISA or section 4975 of the Code (to the extent applicable) with respect to any investment advice that FTFMG provides in connection with Retirement Accounts and holdings. When providing any such fiduciary advice to a client FTFMG adheres to the standards of care of “Impartial Conduct Standards”. FTFMG also provides investment advice that is in the client’s “Best Interest.” Advice meeting the “Best Interest” standard is advice that reflects the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on your investment objectives, risk tolerance, financial circumstances, and needs, without regard to the financial or other interests of FTFMG. The compensation that FTFMG receives for their services is not excessive or unreasonable within the meaning of ERISA section 408(b)(2) or section 4975(d)(2). Statements by FTFMG to you about services subject to this Disclosure will not be materially misleading at the time they are made. FTFMG is now in the process of closing out that wrap fee program and will no longer sponsor a wrap fee program. FTFMG will not accept new accounts in that wrap fee program and we will amend our Form ADV to withdraw it from our registration filings once the last account has been closed or transferred out of that program. See Item 4 on page 5. FTFMG offers other investment advisory and financial industry services in addition to this Wealth Management Wrap Fee Program. For information on these other investment advisory and financial industry services please review FTFMG’s Form ADV Part 2A Disclosure Brochure. A. Wealth Management Wrap Fee Program Services FTFMG’s provides consolidated Portfolio Management Services and Financial Planning Services through our Wealth Management Wrap Fee Program. I. Portfolio Management Programs FTFMG provides Portfolio Management Services, defined as giving continuous advice to clients based on their individual needs through FTFMG’s Wealth Management Wrap Fee accounts. FTFMG obtains financial information on an Investor Profile Questionnaire and other new account documents from prospective clients to determine the suitability of establishing Wealth Management Wrap Fee accounts and to determine the appropriate Portfolio Management strategies that are specific for each client account that is established with FTFMG. Investment Discretion - Clients provide written authorization to FTFMG to use limited discretionary trading authority to buy, sell and direct investments within their accounts, including reinvestment of proceeds from assets sold and income attributable to their account, in cash, cash equivalents, bonds, shares of common or preferred stock, unit investment trusts, ETF’s, mutual funds, options, variable annuity sub-accounts, or other alternative securities selected by FTFMG and FTFMG IAR for their accounts. Clients appoint FTFMG and FTFMG’s IAR as their agent and attorney-in-fact with respect to this limited discretionary trading authorization. Clients may impose restrictions on investing in certain securities or types of securities. This limited discretionary trading authorization shall remain in full force and effect and be relied upon by FTFMG and FTFMG IARs until a written notice of termination or change is received by FTFMG from a client. Under no circumstance will FTFMG and FTFMG IAR effect transactions for clients which FTFMG believes will violate state or federal law, rules or regulations, or any regulatory or self-regulating body rules or regulations. Clients may also place limits on the purchase of certain securities in their accounts. FTFMG Brokerage and Custodian Relationships - FTFMG considers a number of factors including, without limitation, best execution, the overall direct net economic impact on account assets (including commissions which may not be the lowest available, but which will not be higher than the generally prevailing competitive range) the financial stability of the Broker-Dealer and Custodian, the efficiency with which the transaction is effected, the ability to effect the transaction where complicating factors are involved, the availability of the Broker-Dealer and Custodian to stand ready to execute possible difficult transactions in the future, and other matters involved in the receipt of brokerage and research services. FTFMG has a Broker-Dealer/Custodian arrangement with LPL Financial, a SEC registered broker/dealer, member FINRA and SIPC. All variable annuities managed within Portfolio Management Program accounts are held at the corresponding insurance company’s custodian of record. FTFMG will recommend LPL to clients for custody and brokerage services. There is no direct link between FTFMG, LPL and the investment advice FTFMG gives to clients, although FTFMG receives economic benefits through its participation in LPL’s advisory accounts custody and brokerage services that are typically not available to retail investors. These benefits include the following products and services (provided without cost or at a discount):  Duplicate client statements and confirmations;  Research related products and tools; consulting services;  Access to a trading desk serving advisor participants;  Access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts);  The ability to have advisory fees deducted directly from client accounts; and  Access to an electronic communications network for client order entry and account information; access to mutual funds with no transaction fees and to certain institutional money managers; and discounts on compliance, marketing, research, technology, and practice management products or services provided to FTFMG by third party vendors. FTFMG does not have discretionary authority to choose either the Broker/Dealer used for transactions, or the commission rates paid. Some of the products and services made available by LPL may benefit FTFMG but may not directly benefit client accounts. These products or services may assist FTFMG in managing and administering client accounts, including accounts not maintained at LPL. Other services made available by LPL are intended to help FTFMG manage and further develop its business enterprise. Clients should be aware, however, that the receipt of economic benefits by FTFMG creates a conflict of interest and may indirectly influence FTFMG’s choice or recommendation of LPL for custody and brokerage services. Trading – FTFMG allocates trades to clients in a fair and equitable manner that will be applied consistently to all clients. Personal accounts of FTFMG, its IAR and family members will not be treated more favorably than any other client account. FTFMG will make every attempt to completely fill all block order trades. All variable annuities managed within the Portfolio Management Program by FTFMG will have their variable annuity sub-account transactions processed through the Custodian of record for the variable annuity. Trading Error Corrections - It is FTFMG’s policy to ensure clients are made whole following a trade error. Specifically, when a trade error occurs in a client account that results in a loss, FTFMG will reimburse the client. If the trade error was made in a client account resulting in a gain, LPL will keep the gain. If the trade error was made in a block trading account and client funds were not at risk and the trade results in a gain, LPL will keep the gain unless the custodian keeps the gain. Reports and Statements - Clients may receive periodic performance reports from FTFMG describing account performance and holdings. Clients will receive a monthly account statement from LPL showing the account activity as well as positions held in the account at

month’s end, when there is activity in the account. No less than on a quarterly basis, client will receive a statement from LPL for transactions and holdings. Custody - FTFMG does not act as a qualified custodian. All FTFMG Wrap Fee client accounts are maintained at LPL which is a qualified custodian. However, under SEC and state rules FTFMG has custody of client assets due to our ability to deduct fees from client accounts. LPL sends account statements directly to clients. Clients should carefully review those statements. Wealth Management Fee Schedule - FTFMG charges an annual fee of up to 2.00% of total assets under management, through the portfolio management services and wrap fee program described above. All WAI wealth management fees are negotiable, and the final fee schedule is included as part of the Wealth Management Wrap Fee Program Investment Advisory Agreement. All FTFMG Wealth Management Fees are negotiable. Wealth Management Fees will be calculated and paid in advance at the beginning of each quarter. Wealth Management Fees will be based on the Quarter Ending Balance (QEB) of the Client’s account assets under management at the end of the previous quarter. The QEB does not take into account securities that are not priced, nor does it count days when the account has a zero balance. Wealth Management Fees will be automatically deducted from the account. An account that is opened mid-period will be charged an initial Wealth Management Fee that includes a portion of the fee that is pro-rated for the number of days that the account is open in the first Quarter. Wealth Management Fees will be noted on Client’s monthly Custodian statement. Client provide FTFMG with written authorization to deduct all Wealth Management Fees and trade execution charges from client’s account at the Broker-Dealer and Custodian. Client may have Wealth Management Fees paid from other accounts or custodians, or be billed directly by invoice, in such cases Wealth Management Fee deductions will be noted as zero on the client’s monthly Custodian statements. FTFMG will at all times use the Wealth Management Fee billing procedures noted above. Wealth Management Wrap Fee Program Fee Structure - Although clients do not pay a transaction charge for transactions in a Wealth Management Wrap Fee Program account, clients should be aware that FTFMG pays LPL transaction charges for those transactions. The transaction charges paid by FTFMG vary based on the type of transaction (e.g., mutual fund, equity or ETF) and for mutual funds based on whether or not the mutual fund pays 12b-1 fees and/or recordkeeping fees to LPL. Transaction charges paid by the Advisor for equities and ETFs are $9. For mutual funds, the transaction charges range from $0 to $26.50. Because FTFMG pays the transaction charges in Wealth Management Wrap Fee Program accounts, there is a conflict of interest in cases where the mutual fund is offered at both $0 and $26.50. Clients should understand that the cost to Advisor of transaction charges may be a factor that FTFMG considers when deciding which securities to select and how frequently to place transactions in a Wealth Management Wrap Fee Program account. In many instances, LPL makes available mutual funds in a Wealth Management Wrap Fee Program account that offer various classes of shares, including shares designated as Class A Shares and shares designed for advisory programs, which can be titled, for example, as “Class I,” “institutional,” “investor,” “retail,” “service,” “administrative” or “platform” share classes (“Platform Shares”). The Platform Share class offered for a particular mutual fund in Wealth Management Wrap Fee Program in many cases will not be the least expensive share class that the mutual fund makes available, and was selected by LPL in certain cases because the share class pays LPL compensation for the administrative and recordkeeping services LPL provides to the mutual fund. Client should understand that another financial services firm may offer the same mutual fund at a lower overall cost to the investor than is available through Wealth Management Wrap Fee Program. In other instances, a mutual fund may offer only Class A Shares, but another similar mutual fund may be available that offers Platform Shares. Class A Shares typically pay LPL a 12b-1 fee for providing brokerage-related services to the mutual funds. Platform Shares generally are not subject to 12b-1 fees. As a result of the different expenses of the mutual fund share classes, it is generally more expensive for a client to own Class A Shares than Platform Shares. An investor in Platform Shares will pay lower fees over time, and keep more of his or her investment returns than an investor who holds Class A Shares of the same fund. FTFMG has a financial incentive to recommend Class A Shares in cases where both Class A and Platform Shares are available. Although the client will not be charged a transaction charge for transactions, FTFMG pays LPL a per transaction charge for mutual fund purchases and sales in the account. FTFMG generally does not pay transaction charges for Class A Share mutual fund transactions accounts, but generally do pay transaction charges for Platform Share mutual fund transactions. The cost to FTFMG of transaction charges generally may be a factor FTFMG considers when deciding which securities to select and whether or not to place transactions in the account. The lack of transaction charges to FTFMG for Class A Share purchases and sales, together with the fact that Platform Shares generally are less expensive for a client to own, present a significant conflict of interest between FTFMG and the client. Clients should understand this conflict and consider the additional indirect expenses borne as a result of the mutual fund fees. Wealth Management Wrap Fee Program Termination – A Wealth Management Wrap Fee Program Agreement may be terminated by FTFMG or client effective upon receipt of written notice to the other party. Upon termination, client shall receive a refund of any Wealth Management Fee not already earned by the FTFMG. FTFMG will advise LPL to deliver securities and funds they hold as instructed by client unless client requests that the securities and funds be liquidated or maintained at LPL. If an account is liquidated, proceeds will be payable to client upon settlement of all transactions in the account. Termination of a Wealth Management Wrap Fee Program Agreement will not affect the liabilities or obligations of the parties arising out of transactions initiated prior to termination. When this Wealth Management Wrap Fee Brochure is not provided to a client at least 48 hours prior to signing an agreement with FTFMG, the client will have five business days to cancel the agreement without penalty. Assets Under Management– As of December 31, 2023 FTFMG had $181,099,621 of assets under discretionary management. FTFMG does not manage assets on a non-discretionary basis. B. General Advisory Fee Disclosure Fees paid by clients in FTFMG’s Wealth Management Wrap Fee Program may be more than or less than the cost of purchasing the same services, separately or similar services elsewhere. FTFMG’s Wealth Management Fees are negotiable. C. Other Fees, Expenses and Charges Clients may incur certain charges imposed by third parties other than FTFMG in connection with investments placed in the account, including but not limited to:  IRA and Qualified Retirement Plan Fees, and other custodial fees.  Mutual fund and variable annuity internal expenses, commissions, sales loads, 12(b)-1 fees, trail fees and surrender charges.  The purchase of mutual fund shares in client’s account can result in certain processing and mailing charges that are not incurred when shares are purchased directly from the mutual fund company.  Broker-Dealer and Custodian ticket charges, fees, expenses, and mark-up/mark-down charges are separate and distinct from the fee charged by FTFMG. D. Referral Advisor Relationships FTFMG may establish relationships with unaffiliated registered investment advisers that offer a variety of investment advisory programs and services that include asset management programs, separate account portfolio management programs, asset allocation programs, wrap fee programs and financial planning services. If a client is referred to one of these unaffiliated registered investment advisers, FTFMG may receive referral fees from the unaffiliated registered investment adviser. FTFMG will, at all times, be in compliance with the rules and regulations under state law, and if it applies, the Investment Advisers Act of 1940, 17 CFR Section 275.206(4)-1regarding these relationships. FTFMG does not have any referred client accounts from other investment advisers. FTFMG may compensate marketing/advertising service providers or professional networking associations to generate potential client leads. These service providers and associations may only be compensated by FTFMG or FTFMG IARs for generating potential leads. FTFMG does not compensate these service providers or associations based on leads that become clients.