A. AFG is a corporation formed in the state of Arkansas in 1982 and became an SEC registered investment adviser on April 17, 1985. Frederick E. Adkins III, Kristina K. Bolhouse and John R. Broadwater are the principal owners of AFG. This Disclosure Brochure describes the business of AFG. Certain sections will also describe the activities of its “Supervised Persons”. Supervised Persons are any of AFG’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees, or any other person who provides investment advice on AFG’s behalf and is subject to AFG’s supervision or control. B. AFG offers wealth management services to its clients on a fee only basis, which generally include a broad range of financial planning services as well as the discretionary management of investment portfolios. In the event that the client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of AFG), AFG may determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written notice to the client. To commence the investment advisory process, AFG will ascertain each client’s investment objective(s) and then allocate the client’s assets consistent with the client’s designated investment objective(s). Once allocated, AFG provides ongoing supervision of the account(s). Before engaging AFG to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with AFG setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client (collectively the “Agreement”). WEALTH MANAGEMENT SERVICES Core Financial Planning Services Depending upon the needs and direction of the client, the financial planning component of the wealth management offering can generally include the following services:
• Preparation of a wealth management foundational report;
• Development of an individualized investment policy statement (“IPS”);
• Review and monitoring of wealth management plans;
• Consultation, analysis, advice and assistance related to financial issues or decisions that may arise in the future; and
• Administration of investment accounts. Investment Management Services Clients engage AFG to manage their investment assets on a discretionary basis. AFG primarily invests clients’ assets among mutual funds, exchange-traded funds (“ETFs”), and individual debt securities. Individual equity securities, options, and the securities components of variable annuities and variable life insurance contracts are held only at the client’s request or pending liquidation. All investments are made in accordance with the investment objectives of the client. AFG also may render discretionary investment management services to clients relative to variable life/annuity products that they may own, their individual employer-sponsored retirement plans, or other products that may not be held by the client’s primary custodian. In so doing, AFG either directs or recommends the allocation of client assets among the various investment options that are available with the product. Client assets are maintained at the specific insurance company or custodian designated by the product. MISCELLANEOUS Limitations of Planning and Non-Investment Consulting/Implementation Services: To the extent requested by a client, AFG will provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning and insurance review and / or planning, for a separate fee (see Item 5 below) per the terms and conditions of a written financial planning agreement between AFG and the client. Clients are generally required to enter into a Financial Planning and Consulting Agreement with AFG setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to AFG commencing services. AFG does not serve as a law firm, accounting firm, or insurance agency, and no portion of AFG’s services should be construed as legal, accounting, or insurance implementation services. Accordingly, AFG does not prepare estate planning or any other type of legal documents, tax returns or sell insurance products. Neither AFG, nor any of its representatives will assist clients with implementing aspects of a financial plan, unless they have agreed to do so in writing. To the extent requested by a client, AFG may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance agents, etc.). Clients are ultimately responsible for determining whether to hire an unaffiliated recommended professional (e.g., attorneys, accountants, insurance agents), even if they hire an unaffiliated recommended professional at AFG’s recommendation and clients are reminded that they are under no obligation to engage the services of any recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation made by AFG or its representatives. If the client engages any unaffiliated recommended professional, and a dispute arises thereafter, the client agrees to seek recourse exclusively from the engaged professional. At all times, the engaged licensed professional(s) (i.e. attorney, accountant, insurance agent, etc.), and not AFG, shall be responsible for the quality and competency of the services provided. The fee for financial planning services is separate from, and in addition to, AFG’s investment management fee. Both AFG’s financial planning and investment management fees are discussed at Item 5 below. Please Note: AFG believes that it is important for the client to address financial planning issues on an ongoing basis. AFG’s advisory/financial planning fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to address financial planning issues with AFG. Use of Mutual Funds and ETFs: AFG utilizes mutual funds and exchange traded funds for its client portfolios. While AFG may recommend or invest in mutual funds or exchange traded funds (“ETFs”) that are not available directly to the public, AFG may also recommend or invest in publicly-available mutual funds and ETFs that the client could obtain without engaging AFG as an investment adviser. However, if a client or prospective client determines to invest in these securities without engaging AFG as an investment adviser, the client or prospective client would not receive the benefit of AFG’s initial and ongoing investment advisory services. In addition to AFG’s investment management fee described at Item 5 below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and ETF purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). ERISA PLAN and 401(k) INDIVIDUAL ENGAGEMENTS:
• Trustee Directed Plans. AFG may be engaged to provide discretionary investment advisory services to ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the investment objective designated by the Plan trustees. In such engagements, AFG will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). AFG will generally provide services on an “assets under management” fee basis per the terms and conditions of an Investment Advisory Agreement between the Plan and the Firm.
• Client Retirement Plan Assets. If requested to do so, AFG shall provide investment advisory services relative to 401(k) plan assets maintained by the client in conjunction with the retirement plan established by the client’s employer. In such event, AFG shall allocate (or recommend that the client allocate) the retirement account assets among the investment options available on the 401(k) platform. AFG’s ability shall be limited to the allocation of the assets among the investment alternatives available through the plan. AFG will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify AFG of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Unless expressly indicated by AFG to the contrary, in writing, the client’s 401(k) plan assets shall be included as assets under management for purposes of AFG calculating its advisory fee. Retirement Rollovers-Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If AFG recommends that a client roll over their retirement plan assets into an account to be managed by AFG, such a recommendation creates a conflict of interest if AFG will earn new (or increase its current) compensation as a result of the rollover. Whether AFG provides a recommendation as to whether a client should engage in a rollover or not, AFG is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to roll over retirement plan assets to an account managed by AFG. AFG’s Chief Compliance Officer, Mary E. McCraw, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Custodian Charges-Additional Fees: As discussed below at Item 12 below, when

requested to recommend a broker-dealer/custodian for client accounts, AFG generally recommends that Fidelity Brokerage Service, LLC and National Financial Services, LLC (collectively “Fidelity”) serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Fidelity charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark- ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian (while certain custodians, including Fidelity generally do not currently charge fees on individual equity transactions (including ETFs), others do. Please Note: there can be no assurance that Fidelity will not change their transaction fee pricing in the future. Please Also Note: When beneficial to the client, individual fixed‐income and/or equity transactions may be effected through broker‐dealers with whom AFG and/or the client have entered into arrangements for prime brokerage clearing services, including effecting certain client transactions through other SEC registered and FINRA member broker‐dealers (in which event, the client generally will incur both the transaction fee charged by the executing broker‐dealer and a “trade-away” fee charged by Fidelity). These fees/charges are in addition to AFG’s investment advisory fee at Item 5 below. AFG does not receive any portion of these fees/charges. ANY QUESTIONS: AFG’s Chief Compliance Officer, Mary E. McCraw, remains available to address any questions that a client or prospective client may have regarding the above. Portfolio Activity: AFG has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, AFG will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when AFG determines that changes to a client’s portfolio are neither necessary nor prudent. AFG’s investment advisory fee, as described at Item 5 below, remains payable during periods of account inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by AFG will be profitable or equal any specific performance level(s). ByAllAccounts and eMoney Advisor Platform. Via its PlanFirst tool, and/or the online platform hosted by “eMoney Advisor” (“eMoney”), AFG may also provide access to account aggregation services, which can incorporate all of the client’s investment assets, including those investment assets that are not part of the assets that we manage (the “Excluded Assets”). AFG does not provide investment management, monitoring, or implementation services for the Excluded Assets. Unless otherwise specifically agreed to, in writing, AFG’s service relative to the Excluded Assets is limited to reporting only. Therefore, AFG shall not be responsible for the investment performance of the Excluded Assets. Rather, the client and/or their advisor(s) that maintain management authority for the Excluded Assets, and not AFG, shall be exclusively responsible for such investment performance. Without limiting the above, AFG shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. The client may choose to engage AFG to manage some or all of the Excluded Assets pursuant to the terms and conditions of an Investment Advisory Agreement between AFG and the client. Cash Sweep Accounts. Account custodians generally require that cash proceeds from account transactions or cash deposits be swept into and/or initially maintained in the custodian’s sweep account. The yield on the sweep account is generally lower than those available in money market accounts. To help mitigate this issue, AFG shall generally purchase a higher yielding money market fund available on the custodian’s platform with cash proceeds or deposits, unless AFG reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to, the amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. Please Note: The above does not apply to the cash component maintained within AFG’s actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager, and cash balances maintained for fee billing purposes. Please Also Note: The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any of AFG’s unmanaged accounts. Cybersecurity Risk. The information technology systems and networks that AFG and its third- party service providers use to provide services to AFG’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in AFG’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and AFG are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although AFG has established its processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that AFG does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Cross Transactions. In limited circumstances, when determined to be in the best interest of its clients, AFG may engage in a cross-transaction pursuant to which AFG may effect transactions between two of its managed client accounts (i.e., arranging for the clients’ securities trades by “crossing” these trades when AFG believes that such transactions [generally, thinly traded bonds] are beneficial to its clients). This may present a conflict of interest. For all such transactions, neither AFG nor any affiliate will be acting as a broker. Additionally. AFG will not receive any commission or transaction-based compensation although AFG has an interest in the price at which the cross trades are conducted since AFG’s asset-based fees will be negatively impacted by lower bond values. These transactions will be effected through Fidelity, Fidelity will determine the price of the cross transactions and Fidelity will charge the client a transaction fee for the cross transactions. The client may revoke AFG’s cross-transaction authority at any time upon written notice to AFG. AFG’s Chief Compliance Officer, Mary E. McCraw, remains available to address any questions that a client or prospective client may have regarding the above. Cash Positions. AFG continues to treat cash as an asset class. As such, unless determined to the contrary by AFG, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating AFG’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), AFG may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, AFG’s advisory fee could exceed the interest paid by the client’s money market fund. AFG’s Chief Compliance Officer, Mary E. McCraw, remains available to address any questions that a client or prospective may have regarding the above fee billing practice. Client Obligations. In performing its services, AFG shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Clients are advised that it remains their responsibility to promptly notify AFG if there is ever any change in their financial situation or investment objectives for the purpose of reviewing and evaluating, and if necessary, revising its previous recommendations or services. Disclosure Brochure. A copy of AFG’s written Privacy Notice, written Disclosure Brochure as set forth in this Part 2A and 2B of Form ADV and Form CRS (Client Relationship Summary) shall be provided to each client prior to, or contemporaneously with, the execution of a wealth management agreement. C. AFG tailors its advisory services to the individual needs of clients. AFG consults with clients initially and on an ongoing basis to develop and maintain an Investment Policy Statement based upon the client’s investment objective, goals, risk tolerance, and time horizon. D. AFG does not participate in a wrap program. E. AFG managed $755,112,171 in assets on a discretionary basis as of December 31, 2023.