Firm De script ion HFG Advisors, Inc. (“HFG”), also doing business as HFG Advisors was founded in August 2014 and is an investm ent advisor registered with the Securities and Exchange Com m ission or SEC. On April 1, 2021, Richard “Rick” D. Prim e, sold 100% of his ownership interest in Prim e Wealth Managem ent Inc., to HFG Trust, LLC, thus m aking Prim e Wealth Managem ent a wholly-owned subsidiary of HFG Trust, LLC (“HFG Trust”). HFG Trust LLC, is a Washington State lim ited liability com pany which received its Trust charter from the State of Washington Departm ent of Financial Institutions, Division of Banks, and is a wholly owned subsidiary of Com m unity First Bank. HFG is a fee based investm ent m anagem ent and financial planning firm . HFG does not act as a custodian of client assets. The client always m aintains asset control. HFG also provides financial planning services such as tax planning, tax preparation, legacy planning, educational planning, and financial budgeting for a fee to clients. An evaluation of each client's initial situation is provided to the client, often in the form of a net worth statem ent, risk analysis or sim ilar docum ent. Periodic reviews are also com m unicated to provide rem inders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily com m unicated to the client unless im m ediate changes are recom m ended. HFG will create and m anage socially conscious investm ent portfolios when desired by clients who feel it is im portant to reflect their values through their investm ents. Other professionals (e.g., lawyers, accountants, insurance brokers and agents, etc.) are engaged directly by the client on an as-needed basis. Under CCR Section 260.238(k), HFG, its representatives or any of its em ployees will disclose to the clients all m aterial conflicts of interest. Type s of Advisory Se rvice s HFG provides investm ent supervisory services, also known as asset m anagem ent services and furnishes financial planning. ASSET MANAGEMENT HFG offers com prehensive asset m anagem ent services on a wrap and non-wrap fee basis as described in Appendix A. ERISA PLAN SERVICES HFG provides services to qualified retirem ent plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred com pensation plans. HFG m ay act as either a 3(21) or 3(38) advisor: Limited Scope ERISA 3(21) Fiducia ry. HFG m ay serve as a lim ited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their investm ent decisions on a non-discretionary basis. As an investm ent advisor HFG has a fiduciary duty to act in the best interest of the client. The plan sponsor is still ultim ately responsible for the decisions m ade in their plan, though using HFG can help the plan sponsor delegate liability by following a diligent process. HFG offers the following services to the Plan and the Plan participants: 1. Fiduciary Services are: a. Provide non-discretionary investm ent advice to the Client about asset classes and investm ent alternatives available for the Plan in accordance with the Plan’s investm ent policies and objectives. Client will m ake the final decision regarding the initial selection, retention, rem oval and addition of investm ent options. b. Assist the Client with the selection of a broad range of investm ent options consistent with ERISA Section 404(c) and the regulations there under. c. Assist the Client in the developm ent of an investm ent policy statem ent (“IPS”). The IPS establishes the investm ent policies and objectives for the Plan. Client shall have the ultim ate responsibility and authority to establish such policies and objectives and to adopt and am end the IPS. d. Meet with Client on a periodic basis to discuss the reports and the investm ent recom m endations. e. Provide non-discretionary investm ent advice to the Plan Sponsor with respect to the selection of a qualified default investm ent alternative for participants who are autom atically enrolled in the Plan or who have otherwise failed to m ake investm ent elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5). f. Assist in m onitoring investm ent options by preparing periodic investm ent reports that docum ent investm ent perform ance, consistency of fund m anagem ent and conform ance to the guidelines set forth in the IPS and m ake recom m endations to m aintain, rem ove or replace investm ent options. 2. Non-fiduciary Services are: a. Assist in the education of Plan participants about general investm ent inform ation and the investm ent alternatives available to them under the Plan. Client understands HFG’s assistance in education of the Plan participants shall be consistent with and within the scope of the Departm ent of Labor’s definition of investm ent education (Departm ent of Labor Interpretive Bulletin 96-1). As such, HFG is not providing fiduciary advice as define by ERISA to the Plan participants. HFG will not provide investm ent advice concerning the prudence of any investm ent option or com bination of investm ent options for a particular participant or beneficiary under the Plan. b. Assist in the group enrollm ent m eetings designed to increase retirem ent plan participation am ong the em ployees and investm ent and financial understanding by the em ployees. c. HFG m ay provide these services or, alternatively, m ay arrange for the Plan’s other providers to offer these services, as agreed upon between HFG and Client. 3. HFG has no responsibility to provide services related to the following types of assets (“Excluded Assets”): a. Em ployer securities; b. Real estate (except for real estate funds or publicly traded REITs); c. Stock brokerage accounts or m utual fund windows; d. Participant loans; e. Non-publicly traded partnership interests; f. Other non-publicly traded securities or property (other than collective trusts and sim ilar vehicles); or g. Other hard-to-value or illiquid securities or property. Excluded Assets will n ot be included in calculation of Fees paid to HFG under this Agreem ent. HFG will not have discretion or custody, at any tim e, of client funds and/or securities. ERISA 3(38) Investment Ma na ger. HFG can also act as an ERISA 3(38) Investm ent Manager in which it has discretionary m anagem ent and control of a given retirem ent plan’s assets. HFG would then becom e solely responsible and liable for the selection, m onitoring and replacem ent of the plan’s investm ent options. 1. Fiduciary Services are:
• HFG has discretionary authority and will m ake the final decision regarding the initial selection, retention, rem oval and addition of investm ent options in accordance with the Plan’s investm ent policies and objectives.
• Assist the Client with the selection of a broad range of investm ent options consistent with ERISA Section 404(c) and the regulations thereunder.
• Assist the Client in the developm ent of an investm ent policy statem ent (“IPS”). The IPS establishes the investm ent policies and objectives for the Plan.
• Provide discretionary investm ent advice to the Plan Sponsor with respect to the selection of a qualified default investm ent alternative for participants who are autom atically enrolled in the Plan or who have otherwise failed to m ake investm ent elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5). 2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investm ent inform ation and the investm ent alternatives available to them under the Plan. Client understands the HFG’s assistance in education of the Plan participants shall be consistent with and within the scope of the Departm ent of Labor’s definition of investm ent education (Departm ent of Labor Interpretive Bulletin 96-1). As such, the HFG is not providing fiduciary advice as defined by ERISA to the Plan participants. HFG will not provide investm ent advice concerning the prudence of any investm ent option or com bination of investm ent options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollm ent m eetings designed to increase retirem ent plan participation am ong the em ployees and investm ent and financial understanding by the em ployees. HFG m ay provide these services or, alternatively, m ay arrange for the Plan’s other providers to offer these services, as agreed upon between HFG and Client. 3. HFG has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Em ployer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or m utual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and sim ilar vehicles); or
• Other hard-to-value or illiquid securities or property. Excluded Assets will n ot be included in calculation of Fees paid to the Adviser on the ERISA Agreem ent. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. Retirem ent Plan Rollover Recom m endations When HFG provides investm ent advice about your retirem ent plan account or individual retirem ent account (“IRA”) including whether to m aintain investm ents and/or proceeds in the retirem ent plan account, roll over such investm ent/proceeds from the retirem ent plan account to a IRA or m ake a distribution from the retirem ent plan account, we acknowledge that HFG is a “fid u cia ry” within the m eaning of Title I of the Em ployee Retirem ent Incom e Security Act (“ERISA”) and/or

the Internal Revenue Code (“IRC”) as applicable, which are laws governing retirem ent accounts. The way HFG m akes m oney creates conflicts with your interests so HFG operates under a special rule that requires HFG to act in your best interest and not put our interest ahead of you. Under this special rule’s provisions, HFG m ust act as a fiduciary to a retirem ent plan account or IRA under ERISA/IRC:
• Meet a professional standard of care when m aking investm ent recom m endations (e.g., give prudent advice);
• Never put the financial interests of HFG ahead of you when m aking recom m endations (e.g., give loyal advice);
• Avoid m isleading statem ents about conflicts of interest, fees, and investm ents;
• Follow policies and procedures designed to ensure that HFG gives advice that is in your best interest;
• Charge no m ore than is reasonable for the services of HFG; and
• Give Client basic inform ation about conflicts of interest. To the extent we recom m end you roll over your account from a current retirem ent plan account to an individual retirem ent account m anaged by HFG, please know that HFG and our investm ent adviser representatives have a conflict of interest. We can earn increased investm ent advisory fees by recom m ending that you roll over your account at the retirem ent plan to an IRA m anaged by HFG. We will earn fewer investm ent advisory fees if you do not roll over the funds in the retirem ent plan to an IRA m anaged by HFG. Thus, our investm ent adviser representatives have an econom ic incentive to recom m end a rollover of funds from a retirem ent plan to an IRA which is a conflict of interest because our recom m endation that you open an IRA account to be m anaged by our firm can be based on our econom ic incentive and not based exclusively on whether or not m oving the IRA to our m anagem ent program is in your overall best interest. We have taken steps to m anage this conflict of interest. We have adopted an im partial conduct standard whereby our investm ent adviser representatives will (i) provide investm ent advice to a retirem ent plan participant regarding a rollover of funds from the retirem ent plan in accordance with the fiduciary status described below, (ii) not recom m end investm ents which result in HFG receiving unreasonable com pensation related to the rollover of funds from the retirem ent plan to an IRA, and (iii) fully disclose com pensation received by HFG and our supervised persons and any m aterial conflicts of interest related to recom m ending the rollover of funds from the retirem ent plan to an IRA and refrain from m aking any m aterially m isleading statem ents regarding such rollover. When providing advice to your regarding a retirem ent plan account or IRA, our investm ent advisor representatives will act with the care, skill, prudence, and diligence under the circum stances then prevailing that a prudent person acting in a like capacity and fam iliar with such m atters would use in the conduct of an enterprise of a like character and with like aim s, based on the investm ent objectives, risk, tolerance, financial circum stances, and a client’s needs, without regard to the financial or other interests of HFG or our affiliated personnel. Tax Advisory and Preparation Services Tax return preparation services are offered to HFG clients for an additional fee. Services can include:
• Individual incom e tax
• Trust tax returns
• Business tax returns
• Estate tax returns These services are provided as an additional service. The tax preparation fee is in addition to the client’s wealth m anagem ent fee. In lim ited circum stances, at HFG’s discretion, tax preparation services are included as part of the standard wealth m anagem ent fee being charged to a client (HFG, in its sole discretion, can waive or negotiate fees). No client is under any obligation to engage HFG for tax preparation services. FINANCIAL PLANNING AND CONSULTING If financial planning services are applicable, HFG offers the packages below. One-tim e consultation services: Services for one-tim e consultations include but are not lim ited to:
• A thorough review of all applicable topics including: Scop e of Se rvice s
• Personal Incom e and Net Worth Report(s) • Business Financial Advice
• Asset Allocation and Investm ent Analysis • Business Retirem ent/Succession Plannin
• General Analysis and Planning • Strategic Tax Advice
• Education Planning • Real Estate Analysis
• Retirem ent Planning and Analysis • Corporate Retirem ent Plan Review
• Estate Planning • Risk Managem ent
• Stock Options and Concentrated Stock Positions
• Social Security Analysis
• Insurance Planning • Tax Preparation Financial plans will be com pleted and delivered inside of forty-five (45) days dependent upon tim ely client delivery of required docum entation. Clients m ay term inate advisory services with thirty (30) days written notice. Ongoing consultation services: When ongoing services are required HFG will provide services to help the client clearly identify goals, set a fram ework for success, and ensure that you have an accountability partner to help keep you on track to a successful financial future. Ongoing consulting services will be offered on the Scope of Services above. Clients that participate in the ongoing services program can expect the following:
• One quarterly m eeting up to 60 m inutes in person, via telephone or online interface to determ ine financial goals and values, what the client’s current financial picture looks like (including assets, debts, incom e and spending), and what current lim itations or hurdles the client m ay be facing. Client shall be responsible for providing a com pleted Client profile or other required docum ents prior to this m eeting, at this m eeting or within a reasonable tim e after this m eeting.
• One quarterly m eeting up to 45 m inutes to deliver financial planning recom m endations, action item s, and a prioritized “to-do” list.
• One quarterly check-in phone call or e-m ail up to 30 m inutes for accountability, encouragem ent and to address ongoing services. California Code of Regulations, 10 CCR Section 260.235.2, requires that any conflict of interest which exists between the interests of the investm ent advisor and the interests of the client when offering financial planning services be disclosed. The client is under no obligation to act upon the investm ent advisor’s recom m endation. If the client elects to act on any of the recom m endations, the client is under no obligation to effect the transaction through HFG. Client m ay cancel within five (5) business days of signing Agreem ent without any obligation. Referral Of Third-Party Money Managers HFG offers advisory services by referring clients to a third-party m oney m anager offering asset m anagem ent and other investm ent advisory services. The third- party m anagers are responsible for continuously m onitoring client accounts and m aking trades in client accounts when necessary. As a result of the referral, we are paid a portion of the fee charged and collected by the third-party m oney m anagers in the form of solicitor fees. Each solicitation arrangem ent is perform ed pursuant to a written solicitation agreem ent and is in com pliance with SEC Rule 206(4)-3 and applicable state securities rules and regulations. We are available to answer questions that you m ay have regarding your account and act as the com m unication conduit between you and the third-party m oney m anager. The third-party m oney m anager m ay take discretionary authority to determ ine the securities to be purchased and sold for your account. We do not have any trading authority with respect to your designated account m anaged by the third-party m oney m anager. Although we review the perform ance of num erous third-party investm ent adviser firm s, we enter into only a select num ber of relationships with third-party investm ent adviser firm s that have agreed to pay us a portion of the overall fee charged to our clients. Therefore, HFG has a conflict of interest in that it will only recom m end third-party investm ent advisors that will agree to com pensate us for referrals of our clients. Clients are advised that there m ay be other third-party m anaged program s not recom m ended by our firm , that are suitable for the client and that m ay be m ore or less costly than arrangem ents recom m ended by our firm . No guarantees can be m ade that a client’s financial goals or objectives will be achieved by a third-party investm ent adviser recom m ended by our firm . Further, no guarantees of perform ance can ever be offered by our firm (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more details.) SEMINARS AND WORKSHOPS HFG holds sem inars and workshops to educate the public on different types of investm ents and the different services they offer. The sem inars are educational in nature and no specific investm ent or tax advice is given. Clie n t Ta ilore d Se rvice s a n d Clie n t Im pose d Re st rict ion s The goals and objectives for each client are docum ented in our client files. Investm ent strategies are created that reflect the stated goals and objective. Clients m ay im pose restrictions on investing in certain securities or types of securities. Agreem ents m ay not be assigned without written client consent. Wra p Fe e Progra m s HFG sponsors a wrap fee program . The client pays one fee to HFG which includes HFG’s Managem ent Fee and the transaction costs associated with the transactions. More inform ation is available in the Form ADV Part 2, Appendix 1. Clie n t Asse t s Un d e r Ma n a ge m e n t As of Decem ber 31, 2023, HFG has $250,160,836 of assets under m anagem ent. $3,171,019 m anaged on a non-discretionary basis and $246,989,817 are m anaged on a discretionary basis.