103 Advisory Group was approved as a registered investment advisor with the U.S. Securities and Exchange Commission in April 2022. The firm is a limited liability company (LLC) formed under the laws of the State of Illinois.
• Richard J. Milton is the Managing Member and 100% owner of 103 Advisory Group. Full details of his education and business background are provided at Item 19 of this Disclosure Brochure.
• 103 Advisory Group was initially approved as a Registered Investment Adviser in June 2021. Introduction The investment advisory services of 103 Advisory Group are provided to you through an appropriately licensed individual who is an investment adviser representative of 103 Advisory Group (referred to as your investment adviser representative throughout this brochure). Description of Advisory Services The following are descriptions of the primary advisory services of 103 Advisory Group. Please understand that a written agreement, which details the exact terms of the service, must be signed by you and 103 Advisory Group before we can provide you the services described below. Asset Management Services – 103 Advisory Group offers asset management services, which involves 103 Advisory Group providing you with continuous and ongoing supervision over your specified accounts. You must appoint our firm as your investment adviser of record on specified accounts (collectively, the “Account”). The Account consists only of separate account(s) held by qualified custodian(s) under your name. The qualified custodians maintain physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account. The Account is managed by 103 Advisory Group based on your financial situation, investment objectives and risk tolerance. We actively monitor the Account and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Account. We will need to obtain certain information from you to determine your financial situation and investment objectives. You will be responsible for notifying 103 Advisory Group of any updates regarding your financial situation, risk tolerance or investment objective and whether you wish to 103 Advisory Group LLC Page 6 Form ADV Part 2A Firm Brochure impose or modify existing investment restrictions; however we will contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance or investment objectives. We are always reasonably available to consult with you relative to the status of your Account. You have the ability to impose reasonable restrictions on the management of your accounts, including the ability to instruct 103 Advisory Group not to purchase certain securities. It is important that you understand that we manage investments for other clients and may give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you or actions taken for you. We are not obligated to buy, sell or recommend to you any security or other investment that we may buy, sell or recommend for any other clients or for our own accounts. Conflicts may arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed to be appropriate for your account(s) and other accounts advised by our firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit. Financial Planning & Consulting Services - 103 Advisory Group offers financial planning services, which involve preparing a written financial plan covering specific or multiple topics. When providing financial planning and consulting services, our role is to find ways to help you understand your overall financial situation and help you set financial objectives. We also provide modular written financial plans which only cover those specific areas of concern mutually agreed upon by you and 103 Advisory Group. A modular written financial plan is limited or segmented and does not involve the creation of a full written financial plan. You should be aware that there are important issues that may not be taken into consideration when your investment adviser representative develops his or her analysis and recommendations under a modular written financial plan. Written financial plans prepared by 103 Advisory Group do not include specific recommendations of individual securities. We also offer consultations in order to discuss financial planning issues when you do not need a written financial plan. We also offer “as-needed” consultations, which are limited to consultations in response to a particular investment or financial planning issue raised or request made by you. Under an “as-needed” consultation, it will be incumbent upon you to identify those particular issues for which you are seeking our advice or consultation on. Our financial planning and consulting services do not involve implementing any transaction on your behalf or the active and ongoing monitoring or management of your investments or accounts. You 103 Advisory Group LLC Page 7 Form ADV Part 2A Firm Brochure have the sole responsibility for determining whether to implement our financial planning and consulting recommendations. To the extent that you would like to implement any of our investment recommendations through 103 Advisory Group or retain 103 Advisory Group to actively monitor and manage your investments, you must execute a separate written agreement with 103 Advisory Group for our asset management services. Retirement Plan Rollover Recommendations - When 103 Advisory Group provides investment advice about your retirement plan account or individual retirement account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan account, roll over such investment/proceeds from the retirement plan account to a IRA or make a distribution from the retirement plan account, we acknowledge that 103 Advisory Group is a

“fiduciary” within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”) as applicable, which are laws governing retirement accounts. The way 103 Advisory Group makes money creates conflicts with your interests so 103 Advisory Group operates under a special rule that requires 103 Advisory Group to act in your best interest and not put our interest ahead of you. Under this special rule’s provisions, 103 Advisory Group must as a fiduciary to a retirement plan account or IRA under ERISA/IRC:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put the financial interests of 103 Advisory Group ahead of you when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that 103 Advisory Group gives advice that is in your best interest;
• Charge no more than is reasonable for the services of 103 Advisory Group; and
• Give Client basic information about conflicts of interest. To the extent we recommend you roll over your account from a current retirement plan account to an individual retirement account managed by 103 Advisory Group, please know that 103 Advisory Group and we 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 an IRA managed by 103 Advisory Group. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by 103 Advisory Group. 103 Advisory Group LLC Page 8 Form ADV Part 2A Firm Brochure Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to an 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 103 Advisory Group receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by 103 Advisory Group and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to a retirement plan account or IRA, we will act with 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 the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of 103 Advisory Group or our affiliated personnel. Financial Institution Consulting 103 Advisory Group also provides business development consulting services to financial institutions. Our Business Development consulting services including:
• Business development annual budgeting with Senior Management
• Business development ideas from non-competing trust departments.
• Prospect tracking (CRM) development
• Cross selling coaching
• Centers of influence campaign
• Community messaging
• Marketing materials review and support
• Monthly Business Development call with Bank Officers and Trust Professionals.
• Periodic visits to client’s office
• Annual Presentation to Bank Advisory Board 103 Advisory Group LLC Page 9 Form ADV Part 2A Firm Brochure Limits Advice to Certain Types of Investments 103 Advisory Group provides investment advice on the following types of investments:
• Mutual Funds
• Exchange Traded Funds (ETFs)
• Exchange-listed Securities
• Securities Traded Over-the-Counter
• Corporate Debt Securities
• Commercial Paper
• Certificates of Deposit
• Municipal Securities
• US Government Securities
• Options Contracts on Securities Although we generally provide advice only on the products previously listed, we reserve the right to offer advice on any investment instrument that may be suitable for each client’s specific circumstances, needs, goals and objectives. It is not our typical investment strategy to attempt to time the market, but we may increase cash holdings modestly as deemed appropriate based on your risk tolerance and our expectations of market behavior. We may modify our investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.) Tailor Advisory Services to Individual Needs of Clients 103 Advisory Group’s advisory services are always provided based on your individual needs. This means, for example, that when we provide asset management services, you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. Our financial planning and consulting services are always provided based on your individual needs. We will not enter into an investment adviser relationship with a prospective client whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. 103 Advisory Group LLC Page 10 Form ADV Part 2A Firm Brochure Client Assets Managed by 103 Advisory Group As of December 31, 2022, 103 Advisory Group has $143,677,119 of client assets under management to report as of the date of this Brochure. All assets are managed on a discretionary basis.