A. Firm Information Monument Group Wealth Advisors, LLC (“Monument” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). Monument is located in the Commonwealth of Massachusetts. Monument is organized as a Limited Liability Company (“LLC”) under the laws of the State of Delaware. Monument was founded in February 2001, and the principal owners are the Founder & CEO Byron E. Woodman, Jr. and the President, Chief Compliance Officer and Senior Wealth Advisor Lee C. McGowan. This Disclosure Brochure provides information regarding the qualifications, business practices, and advisory services provided by Monument. The Advisor serves as a fiduciary to Clients, as defined under applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Our fiduciary commitment is further described in our Code of Ethics. For more information regarding our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. B. Advisory Services Offered Monument offers investment management services to individuals, high net worth individuals, trusts, estates, and businesses in the Commonwealth of Massachusetts and other states (each referred to as a “Client”). Investment Management Services – Master Planning Monument will typically provide a variety of wealth management services to high net worth individuals and families, pursuant to a written investment management agreement. Services are offered in several areas depending on Client goals, objectives and resources. Generally, the Advisor designs a plan for the overall wealth management of the Client. Generally, such wealth management services will involve preparing key documents such as a Statement of Net Worth, Cash Flow Statement, or rendering a financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need including, but not limited to investment planning, retirement planning, tax planning, estate planning, personal savings, education savings and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to, the Client will usually include specific actions to be taken by the Client. For example, recommendations may be made for the Client to start or revise their investment program, commence or alter retirement savings, establish education savings and/or a charitable giving program. Monument may also refer Clients to an accountant, attorney or other specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor may provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. Under the terms of the investment management agreement, Monument will also provide customized investment management solutions for their Clients. This is achieved through personal Client contact and interaction while providing discretionary investment management and consulting services. Monument works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a target allocation. Monument will then construct and provide ongoing management for a portfolio consisting of mutual funds, exchange traded funds (“ETFs”), individual stocks and bonds, or other securities. In addition the Advisor may implement certain investment recommendations through the use of a Sub-Advisor. Monument evaluates and selects mutual funds and ETFs for inclusion in Client portfolios only after applying their internal due diligence process. On occasion, Monument may recommend redistributing investment allocations to diversify the portfolio. Monument may recommend selling positions for reasons that include, but are not limited to harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Page 5 Generally, Monument will assist the Client with establishing custodian accounts and relationships with Sub- Advisors, as necessary. At no time will Monument accept or maintain custody of a Client’s funds or securities, but for as described in Item 10 below. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the Client investment management agreement.
For additional information, please see Item 12 – Brokerage Practices and Item 15 - Custody. Financial Planning Monument will typically provide a variety of financial planning services to individuals and families, pursuant to a written Financial Planning Agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals, objectives and financial circumstances. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for Clients based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need including, but not limited to investment planning, retirement planning, personal savings, education savings and other areas of a Client’s financial situation. A financial plan developed for (or financial consultation rendered to) the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs,

commence or alter retirement savings, establish education savings and/or charitable giving programs. Monument may also refer Clients to an accountant, attorney or another specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of the contract date, assuming all information and documents requested are promptly provided. Financial planning and consulting recommendations may pose a potential conflict between the interests of the Advisor and the interests of the Client. For example, a recommendation to engage the Advisor for investment management services or to increase the level of investment assets with the Advisor would pose a conflict, as it would increase the advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Family Office Services The Advisor also provides Family Office Services. Family Office Services Clients are generally families with a minimum net worth of $50,000,000. This high-touch service offering begins with Monument assisting Clients in establishing a team of advisors to oversee many facets of the Clients financial situation. Monument’s specific services generally include, but are not limited to the following:
• Assisting the Client in the establishment of custodial accounts and investment management relationships;
• Monitoring accounts and relationships to assure compliance with the specific Investment Policy Statement adopted by the Client;
• Establishing appropriate benchmarks for investment performance measurements and updating to reflect changesin financial needs and investment objectives;
• Maintaining documents, records, comprehensive financial information, and current information about investment strategies and tax matters; and
• Investment Management, as described below. Use of Sub-Advisors At their discretion, Monument may periodically engage or hire an unaffiliated money manager or investment advisor (each a “Sub-Advisor”). Monument will assist and advise the Client in establishing investment objectives Page 6 for the account, will have the discretion to select the Sub-Advisor, and will define any restrictions on the account. Monument will continue to provide oversight of the Client account and ongoing monitoring of the activities of the Sub-Advisor. Through this arrangement, Monument and the Client will then enter into an advisory agreement with the Sub- Advisor. Monument will establish investment objectives and the Sub-Advisor will assist in developing and implementing an investment strategy to meet the objectives. In consideration for such Sub-Advisor services, the Sub-Advisor will receive an investment management fee that will be billed based on the fee schedule that Monument establishes with the Sub-Advisor. The Client, prior to entering into an agreement with a Sub-Advisor, will be provided with the Sub-Advisor ‘s Form ADV 2 (or a brochure that makes the appropriate disclosures). Held Away Account Services (Pontera) We use a third-party platform, Pontera, to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid gathering Client log-in credentials to affect trades. We are not affiliated with the platform and receive no compensation from Pontera for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations and investment options. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and the Client’s overall portfolio including accounts held at the Custodian. Client account(s) will be reviewed at least quarterly, and allocation changes will be made as deemed necessary. We compensate Pontera for client assets on the platform at an annual rate of 30%. C. Client Account Management Prior to engaging Monument to provide investment management services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Policy Statement – Monument, in connection with the Client, may develop a statement that summarizes the Client’s investment strategy that seeks to achieve the Client’s investment goals and objectives based on the Client’s financial situation, time horizon and tolerance for risk.
• Asset Allocation – Monument will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – Monument will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Monument will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Monument does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Monument. E. Assets Under Management As of December 2023, Monument manages the following assets: Discretionary Assets $ 535,577,652 Non-Discretionary Assets $ 0 Total Assets Under Management $ 535,577,652 Clients may request more current information at any time by contacting the Advisor. Page 7