4(A) Description of the Advisory Firm Bravias Capital Group, LLC (“BCG” or the “Firm”) is a limited liability company organized in the state of New York with its principal office and place of business located in the state of New Jersey (“New Jersey”). BCG’s registration as an investment adviser became effective with New Jersey became effective in October 2017. In July of 2023, the Firm transitioned to registration as an investment adviser with the Securities and Exchange Commission1. BCG is wholly owned by Mr. Richard Zeitz, President and CEO. The Firm provides discretionary investment management services and financial planning services to clients. The “Description of Advisory Services” below provides more detailed information about these services. 4(B) Description of Advisory Services Investment Management Services (“IMS”) are the Firm’s core offering. IMS clients receive Financial Planning Services (“FPS”) and no additional charge. For this reason, the Firm believes that their IMS offering presents the best value for clients that have a need for investment management and financial planning. Alternatively, clients that do not have a need or interest in BCG’s IMS offering may engage the Firm for stand-alone FPS on a fee basis. IMS or stand-alone FPS (collectively, the “Services”) are available to clients. A detailed description of the Services is covered in the sections that follow. 4(B)1 Investment Management Services BCG provides discretionary and non-discretionary investment management of client accounts which entails the ongoing supervision of client assets. In other words, Firm continuously monitors client accounts, makes recommendations, and executes transactions when and if appropriate. For more detailed information, please see “Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss”, “Material Risks of Securities”. 4(C)1 Investment Management Services Tailored to the Individual Needs of Each Client BCG’s Investment Management Services are tailored to the individual needs of each client. At the onset of the investment management relationship, the Firm will discuss personal financial circumstances, current investments, goals, risk tolerance, and time horizon. Clients may also impose investment restrictions on the management of their accounts. Reasonable restrictions may be applied at the asset class level, sector, or industry level, or restrict the purchase of individual securities. The IAR managing the relationship will be responsible for assisting the Client in creating a custom-tailored portfolio and establishing restrictions. 1 Neither registration with the Securities and Exchange Commission nor any state securities authority is intended to imply any level of skill or training. 4(B)2 Financial Planning Services BCG’s standard practice is to provide Investment Management Services and Financial Planning Services to its clients. In other words, the Firm does not generally provide stand-alone FPS to clients without IMS. However, BCG does offer stand-alone FPS if desired by clients or when appropriate. BCG’s Financial Planning Services entail the review and management of client financial resources based upon an analysis of individual client needs. Financial plans may be holistic, covering the totality of a client situation or modular, covering only select topics as agreed. Topics covered in a financial plan may include one or more of the following modules:
• Cash Flow/Balance Sheets Review and develop a personal cash flow statement. This information may be utilized to identify the capacity for future wealth accumulation and anticipate future cash flow needs
• Income Planning Coordination of pensions, social security, passive income, annuity income, and income produced by investments defined contribution plans
• Educational Funding Review of funding alternatives, including analysis and explanation of § 529 college saving plans
• Review of Assets Held Away A comprehensive review of personal investments, including both full service and self-directed accounts/assets. The review and analysis may cover asset allocation,

management fees, risk tolerance, desired goals, and integration of investments and its associated strategy
• Insurance Planning Includes an inventory of insurance policies, including life insurance, long-term care (if you have reached a certain age), and annuities. You may also receive an analysis of your needs and your family’s needs in the event of your death or need for long-term care.
• Personal Catastrophic Planning An examination of various risks to clients and their families’ financial security, including recommendations to help protect against associated risks
• Retirement Planning Analysis of current/or projected qualified retirement benefits, including company-sponsored plans such as thrift savings plans, 401(k) plans, 403(b) plans, 457 plans, profit sharing, and pension plans. An analysis of Social Security and its benefits may also be provided.
• Tax Planning An Individual or business tax analysis and strategy; this may include consultation with an independent tax professional. BCG does not provide tax advice. We urge you to consult with your tax adviser before the implementation of any tax strategy.
• Estate Management and Wealth Transfer This may include asset protection and wealth preservation, estate and income tax on the estate, efficient titling, and transfer to beneficiaries. A discussion may consist of an evaluation by a contracted estate and tax attorney. BCG does not provide legal advice. We urge you to consult with a tax and estate planning attorney before the implementation of any estate planning or wealth transfer strategy.
• Philanthropy Analysis, organization, and development of gifting strategies that benefit the charity, donor, and the donor’s family. If appropriate, BCG may consult with an independently contracted philanthropy specialist. Financial planning services generally recommend the implementation of the financial plan through the purchase and sale of securities, insurance, and annuity products. BCG may also recommend its investment management services (please see “4(B)2 – Investment Management Services”) to implement part of its financial plan, implementation of the financial plan through the purchase and sale of securities and insurance products by recommending and utilizing its affiliated insurance agency, Bravias Financial LLC. Since financial planning generally recommends additional products and services offered by BCG or Bravias Financial LLC, a conflict exists between the interests of BCG and its clients. Clients are under no obligation to act upon BCG’s recommendations, and if the client elects to act on any recommendations, clients are under no obligation to effect transactions through the investment adviser. For more information on material conflicts of interest, please refer to the following Items: “Item 5 – Fees and Compensation”, “Item 10 – Other Financial Industry Activities and Affiliations”, and “Item 12 – Brokerage Practices”. 4(C)2 Financial Planning Services Tailored to the Individual Needs of Each Client By its very nature, all financial planning services offered by BCG are tailored to the specific needs of each client. 4(B)3 Educational Seminars and Webinars Periodically, BCG contacts educational seminars and webinars (“Seminars”) on various financial planning topics, including retirement planning and employee benefits. No fees are charged for the Seminars. Seminars include educational materials and allow attendees to ask questions. Note, Seminars are impersonal in nature and do not address the specific needs of, or make recommendations to participants. Furthermore, participants are never under any obligation to engage BCG for any of its advisory services. 4(D) Wrap Fee Programs BCG is not a participant in a wrap fee program, nor does the Firm offer any wrap fee programs. 4(E) Assets Under Management The amount of client assets managed by BCG totaled $170,415,442 as of December 31, 2023. $170,413,592 are managed on a discretionary basis, and $1,849 are managed on a non-discretionary basis. (Please see “Item 16 – Investment Discretion for more information).