Firm Description Turner Financial Group, Inc. (“TFG” or “Firm”) was organized in May of 2001 and approved as a registered investment adviser in April of 2005. The firm was previously owned by Benny M. Turner and Gracie L. Turner. In July of 2021, the firm was purchased by Noble Alpha, LLC. Noble Alpha, LLC is owned by Andrew Tang. TFG also maintains three other office locations, doing business as (DBA): 1) Turner Financial Group, Inc., DBA GF Thomas Advisory Group 4040 Civic Center Drive, Suite 200 San Rafael, CA 94903 Phone: 415-459-5150 Fax = 415-459-5158 www.gfthomasadvisory.com 2) Turner Financial Group, Inc., DBA Seelan Wealth Strategies, LLC 8023 East 63rd Place, Suite 540, Tulsa, OK 74133 Phone 918-940-3802 Fax 918-615-3368 www.seelan.com 3) Turner Financial Group, Inc., DBA Andalus Capital, LLC. 33 South Service Road, Jericho, NY 11753 Phone 212-681-9762 www.andalus.capital Types of Advisory Services PERSONAL FINANCIAL PLANNING SERVICES TFG offers Concierge Planning Services as well as Comprehensive Planning Services. Other advisory services are available on an ad hoc basis. Concierge Financial Planning Services. This level of financial planning may include identification and analysis of financial problems, legacy planning, retirement planning, cash flow and income planning, social security planning, insurance & risk management planning, investment planning (securities), tax planning, trust funding, college planning and/or any number of individualized projects as requested by Clients. Concierge Planning Services can be further differentiated by goals as follows:
• Financial Project. A Financial Project provides an individual snapshot of one or more of the specific project areas listed above. Several Financial Projects can be provided as part of a single engagement.
• Financial Plan. This includes multiple Financial Projects based on individual Client needs and is integrated into a panoramic wide-angle snapshot of a Client’s broader financial positions and concerns. Goals are to reveal where one is financially and how one came to be there, as well as to suggest corrective actions designed to “change the financial picture”. While the resulting “Wide- Angle Financial Snapshot” denotes something larger and potentially more useful than the individual Financial Projects used to construct it (in the same way that a photo album is larger and potentially more useful than a single snapshot), it nonetheless remains a snapshot addressing only one point in a client’s financial history.
• Comprehensive Financial Planning Services. In contrast to Concierge Planning, Comprehensive Planning is a dynamic series of on-going decisions and actions based on complex interactions between Clients and their advisors. Thus, rather than describing a point in time that involves only the Client, Comprehensive Financial Planning describes a process that takes place over time involving multiple interactions between the Client and his/her advisors. Comprehensive Financial Planning includes integrating multiple Client related individual Financial Projects (or snapshots) into a well-crafted Wide-Angle Financial Snapshot (Plan) which is dynamically implemented with periodic reviews and modifications designed to keep it in sync with the ever-changing landscape of an individual’s financial and personal life.
• Implementation. Implementation adds transformative “action” to the planning process, “morphing” it from a powerless moment in time to a powerful action movie where change is actualized as the characters move through life. Implementation of a well-crafted financial plan is “the difference that makes a difference.”
• Annual Review. At the Client’s discretion, an annual review and plan update is available.
• Optimizer Service. TFG will review and analyze investment options available to Clients within their employer provided retirement accounts (401a, 401k, 403b, 457, etc.), self- directed investment or educational accounts (variable annuities, 527 plans, etc.), and make written account rebalancing recommendations quarterly (twice annually for 527 accounts); or more often if market conditions suggest it. Clients are responsible for trading or not trading their accounts as they believe appropriate. Recommendations are intended to help Clients minimize their risk while taking advantage of changing market conditions and trends by optimizing their potential for growth using only the limited investment options available to them within their employer provided retirement accounts. As a fiduciary, if a conflict of interest exists between the interests of the TFG and the interests of the Client, TFG will recommend what is in the best interest of the Client. However, the Client should be aware that they are under no obligation to act upon the TFG’s recommendation. The Client is under no obligation to affect the transaction through any recommendation made by TFG. Financial plans will generally be completed and delivered within ninety (90) days. ASSET MANAGEMENT SERVICES TFG offers discretionary direct asset management services to advisory Clients. Precision Portfolio Solutions uses various model portfolios designed and implemented by TFG and is designed to provide professional management of Client portfolios at a competitive cost. TFG will offer Clients ongoing portfolio management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The Client will authorize TFG discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. Portfolio Design and Construction. Portfolio models are made up of two types of accounts; accounts designed to primarily provide growth and accounts designed primarily to provide safety and income. Types of financial tools

used to populate the two account types can be quite different from one another as noted below.
• Accounts Primarily Designed to Provide Growth. Growth models are generally constructed using financial tools designed to promote capital appreciation.
• Accounts Primarily Designed to Provide Principal Preservation and Income. Principal preservation and income models generally are constructed using a combination of tools designed to limit investment risk and/or provide income. TFG also provides sub-advisory services and provides customized investment advisory solutions to third party unaffiliated investment advisers. TFG works with each third-party unaffiliated investment adviser to identify appropriate investment mandates as well as risk tolerance in order to create a portfolio allocation or set of allocations using investment strategies. TFG will have responsibility for:
• Iindividualized client investment portfolio analysis and proposal generation.
• Initial allocation trade instructions based upon the client’s investment objective, risk tolerance, time horizon and taxation needs.
• Ongoing analysis of accounts to ensure client allocations continue to meet the client’s investment goals, objectives, risk tolerance and cash needs. Necessary adjustments are made via trade instructions.
• Assist with client meetings and reviews. In addition, TFG will also offer the following services to third party unaffiliated investment advisers: 1. Administration and aggregation 2. Administration for accounts managed. 3. Proposal generation TFG will provide a questionnaire or similar tools to third party unaffiliated investment adviser to determine the Client’s risk profile, investment time horizon, financial circumstances, and investment objectives. TFG will calculate advisory fees and monitor compliance with the client’s profile. TFG also offers non-discretionary asset management services to Clients on assets not held with TFG’s custodian. TFG will meet with the Client for information gathering initially and then every quarter thereafter for review and recommendations. TFG will review the investment options available within the account 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 TFG. SELECTION OF OTHER ADVISERS TFG may at times utilize the services of third-party money managers to manage Client accounts. In such circumstances, TFG receives referral fees from the third-party money manager. TFG acts as the liaison between the Client and the third-party money manager in return for an ongoing portion of the advisory fees charged by the third-party money manager. TFG is responsible for:
• Helping the Client complete the necessary paperwork of the third-party money manager.
• Providing ongoing support services to the Client.
• Updating the third-party money manager with any changes in Client status which is provided to TFG by the Client.
• Reviewing quarterly account statements provided by the third-party money manager; and
• Delivering the Form ADV Part 2, Privacy Notice and any other required documents of the third-party money manager to the Client. Clients placed with third party money managers will be billed in accordance with the third- party money manager’s fee schedule which will be disclosed to the Client prior to signing an agreement. When referring Clients to a third-party money manager, the Client’s best interest will be the primary determining factor for the TFG. TFG acts as the liaison between the Client and the third-party money manager in return for an ongoing portion of the advisory fees charged by the third-party money manager. TFG helps the Client complete the necessary paperwork of the third-party money manager, provides ongoing services to the Client, will provide the third-party money manager with any changes in Client status as provided to TFG by the Client and review statements provided by the third-party money manager on a quarterly basis. These practices represent conflicts of interest because TFG is paid a Referral Fee for recommending the third-party money managers and may choose to recommend a particular third-party money manager based on the fee TFG is to receive. This conflict is mitigated by disclosures, procedures, and the TFG’s Fiduciary obligation to act in the best interest of Clients. Clients are not required to accept any recommendation of third-party money managers given by TFG and have the option to receive investment advice through other money managers of their own choosing. For example, TFG has entered into a Referral Arrangement/Contract with Absolute Capital Management, LLC (ABSCAP) CRD# 121484 and reviews the same on an annual basis. TFG recommends some of our clients engage Absolute Capital Management, LLC “Absolute Capital” to manage all or a portion of their assets. Absolute Capital offers the programs below. The Funds. A Client Account investing in portfolios that consist solely of the Absolute Capital Mutual Funds (“the Funds”), a group of mutual funds managed by the Absolute Capital. Investment Management. Client will authorize Absolute Capital with discretionary authority to allocate the account into the investment options available at the custodian that are consistent with the Program(s) the client has selected and to continue to make reallocations according to the Program strategy over time. Clients have the authority to impose reasonable restrictions on Absolute Capital’s management of their accounts. SEMINARS AND WORKSHOPS TFG holds seminars and workshops to educate the public on different types of investments and the different services they offer. The seminars are educational in nature and no specific investment or tax advice is given at these workshops, nor are financial products discussed. The workshops are intended to help individuals better understand general principles and concepts important to financial planning. Wrap Fee Programs TFG does not sponsor any wrap fee programs. Client Assets under Management As of December 31, 2023, TFG has assets under management with $115,066,597 on a discretionary basis and $677,191 on a non-discretionary basis.