A. Firm Description Bellwether Investment Group, LLC. (Bellwether) is a limited liability company formed in October, 2008, in the state of Tennessee. Bellwether is a Registered Investment Advisor that provides investment advice to individuals, businesses, trusts, and estates. Bellwether became registered as an investment adviser in October, 2008. Principal Owners There are four equal partners, referred to as members, that own Bellwether. They are as follows:
• Martin Summitt – 25% owner
• Lance Ray, CFP® – 25% owner
• Connie West – 25% owner
• John Lindsey, CPA – 25% owner B. Types of Advisory Services Bellwether offers the following types of advisory services: Financial Planning, discretionary and non- discretionary portfolio management and investment advice for individuals and/or businesses. and, to the extent specifically requested by a client, financial planning and related consulting services. The client can engage Bellwether to provide discretionary and/or non-discretionary investment advisory and implementation services on a fee basis, generally negotiable to 2%. Before engaging Bellwether to provide those services, clients are required to enter into an Investment Advisory Agreement with Bellwether 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. Before providing investment advisory services, an investment adviser representative will ascertain each client’s investment objectives. Thereafter, Bellwether will allocate and/or recommend that the client allocate investment assets consistent with the designated investment objectives. Bellwether will create a portfolio consisting of one or all of the following: individual equities or Exchange Traded Funds (“ETFs”), bonds, no-load or load-waived mutual funds, and other investment products. Portfolio weighting will be determined by the client’s objectives and individual needs. Clients can place investment restrictions on the types of investments if they so choose. The client maintains individual ownership of all securities in their account. Bellwether does not commingle any funds with clients. Once allocated, Bellwether provides ongoing monitoring and review of account performance, asset allocation and client investment objectives, and may rebalance and/or may recommend that clients rebalance accounts as necessary based on such reviews. When appropriate, Bellwether may recommend the use of margin transactions or option transactions. Because these investment strategies involve a certain degree of additional risk, they are only recommended when consistent with the client objectives and risk tolerance. Financial Planning and Consulting Services (Stand-Alone) To the extent specifically requested by a client, Bellwether shall generally provide financial planning and/or consulting services (including investment and non-investment related matters, estate planning, insurance planning, etc.) on a stand-alone separate and additional fee basis. Bellwether’s fees, as set forth in Item 5 below, are negotiable and may vary depending upon the level and scope of the service(s) required and the professional(s) rendering the service(s). Before engaging Bellwether to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with Bellwether 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 before Bellwether commences services. Bellwether’s planning and consulting fees are negotiable, but generally range from $1,000 to $15,000 on a fixed fee basis, and from $75 to $400 on an hourly rate basis, depending upon the level and scope of the service(s). Financial planning may address any or all of the following areas:
• Personal: Family records, budgeting, personal liability, estate information and financial goals.
• Education: College planning, Private school planning.
• Death and Disability: Cash needs at death, income needs for surviving spouse, estate planning and disability income needs.
• Retirement: Retirement goals and strategies
• Estates: Trusts, wills, estate tax, powers of attorney
• Insurance: review existing policies, structure new policies. Financial planning clients may receive a written report, providing a detailed financial plan designed to achieve their stated goals and objectives. Bellwether gathers required information through in-depth personal interviews. Information gathered includes client’s current financial states, future goals and risk tolerances. Related documents include a questionnaire completed by the client, tax returns, investment statements, wills and trusts. After careful analysis and review a written report is typically provided with recommendations provided in the plan. Bellwether suggests that the client work closely with their attorney and accountant. Bellwether does not give legal or tax advice. Implementation of the plan recommendations is solely the client’s responsibility. Financial planning recommendations are not limited to any specific product or service offered by a broker dealer or insurance company. If requested by the client, Bellwether may recommend the services of other professionals for implementation purposes, including Bellwether’s representatives in their individual capacities as licensed insurance agents (see disclosure at 10.C.). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Bellwether. At all times, the engaged licensed professional[s] (i.e. attorney, accountant, etc.), and not Bellwether, shall be responsible for the quality and competency of the services provided. Retirement Plan Consulting Services Bellwether provides pension consulting services, pursuant to which it assists sponsors of self-directed retirement plans with monitoring of investment alternatives (generally open-end mutual funds) from which plan participants shall choose in self-directing the investments for their individual plan retirement accounts. In addition, to the extent requested by the plan sponsor, Bellwether may also provide participant education designed to assist participants in identifying the appropriate investment strategy for their retirement plan accounts. The terms and conditions of the engagement shall generally be set forth in an agreement between Bellwether and the plan sponsor. Miscellaneous Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. As indicated above, to the extent requested by a client, Bellwether may provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. on a stand-alone separate and additional fee basis. Bellwether will generally provide such consulting services inclusive of its advisory fee set forth at Item 5 below (exceptions could occur based upon assets under management, special projects, stand-alone planning engagements, etc. for which Firm may charge a separate or additional fee). Please Note. Bellwether believes that it is important for the client to address financial planning issues on an ongoing basis. Bellwether’s advisory 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 Bellwether. Neither Bellwether nor its investment adviser representatives assist clients with the implementation of any financial plan, unless they have agreed to do so in writing. In addition, Bellwether does not monitor a client’s financial plan, and it is the client’s responsibility to revisit the financial plan with Bellwether, if desired. Please Note: We do not serve as an attorney or accountant, and no portion of our services should be construed as same. Accordingly, we do not prepare estate planning documents or tax returns. To the extent requested by a client, we may recommend the services of other professionals for certain non-investment implementation purposes, including Bellwether’s representatives in their separate individual capacities as licensed insurance agents. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Bellwether and/or its representatives. Please Note: If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Please Also Note - Conflict of Interest: The recommendation by Bellwether that a client purchase an insurance commission product from a Bellwether representative, in his individual capacity as an insurance agent, presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend insurance products based on commissions to be received, rather than on a particular client’s need. No client is under any obligation to purchase any insurance commission products from a Bellwether representative. Clients are reminded that they may purchase insurance products recommended by Bellwether through other, non-affiliated insurance agents. Bellwether’s Chief Compliance Officer, John Lindsey, remains available to address any questions that a client or prospective client may have regarding the above conflict of interest. Please Note: If the client engages any such recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional[s] (i.e. attorney, accountant, etc.), and not Bellwether, shall be responsible for the quality and competency of the services provided. Please Also Note: It remains the client’s responsibility to promptly notify Bellwether if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Bellwether’s previous recommendations and/or services. Variable Annuity Management. As part of its Investment Advisory services, Bellwether may be engaged to provide discretionary management to a client’s variable annuity product(s). In such engagements, Bellwether will allocate investment assets on a fee basis among the investment subaccounts of variable annuity products owned by the client. Bellwether will typically propose allocations to individual equity and fixed income investments, exchange-traded funds, and mutual funds, consistent with the client’s designated investment objectives. Once allocated, Bellwether provides ongoing monitoring and review of subaccount performance, asset allocation, and client investment objectives. Use of Mutual Funds or Exchange Traded Funds. While Bellwether may recommend allocating investment assets to mutual funds and exchange traded funds that are not available directly to the public, Bellwether may also recommend that clients allocate investment assets to publicly-available mutual funds and exchange traded funds that the client could obtain without engaging Bellwether as an investment adviser. However, if a client or prospective client determines to allocate investment assets to publicly- available mutual funds or exchange traded funds without engaging Bellwether as an investment advisor, the client or prospective client would not receive the benefit of Bellwether’s initial and ongoing investment advisory services. Please Note: In addition to Bellwether’s investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, internal charges imposed at the fund level (e.g. management fees and other fund expenses). Other mutual funds, such as those issued by Dimensional Fund Advisors (“DFA”), are generally only available through selected registered investment advisers. Bellwether may allocate client investment assets to DFA mutual funds. Therefore, upon the termination of Bellwether’s services to a client, restrictions regarding transferability and/or additional purchases of, or reallocation among DFA funds will apply. ANY QUESTIONS: Bellwether’s Chief Compliance Officer, John Lindsey, remains available to address any questions that a client or prospective client may have regarding the above. Cybersecurity Risk. The information technology systems and networks that Bellwether and its third-party service providers use to provide services to Bellwether’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Bellwether’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Bellwether 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 Bellwether has established its systems to reduce the risk of cybersecurity incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that Bellwether 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. 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, Bellwether may purchase a higher yielding money market fund available on the custodian’s platform with cash proceeds or deposits that exceed a particular clients typical cash level, if Bellwether reasonably anticipates that it will not utilize the cash proceeds during the subsequent 180-day period to purchase additional investments for the client’s account and upon the client’s formal or informal agreement for such. 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, 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. Retirement Rollovers - No Obligation/Conflict of Interest: A client leaving an employer typically has four options (and may engage in a combination of these options): i) leave the money in his former employer’s plan, if permitted, ii) roll over the assets to his/her new employer’s plan, if one is available and rollovers are permitted, iii) rollover to an IRA, or iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). Bellwether may recommend an investor roll over plan assets to an Individual Retirement Account (IRA) advised by Bellwether. As a result, Bellwether and its representatives may earn an asset-based fee. In contrast, a recommendation that a client or prospective client leave his or her plan assets with his or her old employer or roll over the assets to a plan sponsored by a new employer will generally result in no compensation to Bellwether (unless you engage Bellwether to monitor and/or advise on the account while maintained with the client’s employer). Bellwether has an economic incentive to encourage an investor to roll plan assets into an IRA that Bellwether will advise on or to engage Bellwether to monitor and/or advise on the account while maintained with the client's employer. There are various factors that Bellwether may consider before recommending a rollover, including but not limited to: i) the investment options available in the plan versus the investment options available in an IRA, ii) fees and expenses in the plan versus the fees and expenses in an IRA, iii) the services and responsiveness of the plan’s investment

professionals versus those of Bellwether, iv) protection of assets from creditors and legal judgments, v) required minimum distributions and age considerations, and vi) employer stock tax consequences, if any. If Bellwether recommends that a client roll over their retirement plan assets into an account to be managed by Bellwether, such a recommendation creates a conflict of interest if Bellwether will earn a new (or increase its current) advisory fee on the rolled over assets. If Bellwether provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Bellwether 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 plan or IRA assets to an IRA advised by Bellwether or to engage Bellwether to monitor and/or advise on the account while maintained with the client's employer. Bellwether’s Chief Compliance Officer, John Lindsey, remains available to address any questions that a client or prospective client may have regarding the above and the corresponding conflict of interest presented by such engagement. Independent Managers. Bellwether may allocate (and/or recommend that the client allocate) a portion of a client’s investment assets among unaffiliated independent investment managers (“Independent Manager(s)”) in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager(s) shall have day-to-day responsibility for the active discretionary management of the allocated assets. Bellwether shall continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors which Bellwether shall consider in recommending Independent Manager(s) include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. Please Note: The investment management fee charged by the Independent Manager(s) is separate from, and in addition to Bellwether’s advisory fee as set forth in the fee schedule at Item 5 below and which will be disclosed to the client before entering into the Independent Manager engagement and/or subject to the terms and conditions of a separate agreement between the client and the Independent Manager(s). The AMS Managed Programs Bellwether may use several managed programs available through RJA”). Specifically, Bellwether engages the Asset Management Division (“AMS”) division of RJA to provide discretionary investment management services as a sub-advisor. For certain AMS Managed Programs, RJA also retains an unaffiliated investment manager as a sub-advisor to RJA. This Manager provides discretionary investment management of the client’s portfolio through RJA, making the investment decisions and placing the trades in the client’s account. Bellwether then monitors the client’s account to ensure that the Program selected and the Manager RJA has selected continue to be consistent with the client’s investment objective. The AMS Managed Programs available to our clients through RJA are described below. Assets in these accounts will be invested and reinvested as RJA or the Manager deem in the client’s best interest to achieve investment objectives identified by Bellwether, without regard to holding period, portfolio turnover or resulting gain or loss. If a participating client informs the Bellwether of a change in the client’s financial situation or investment objectives, Bellwether assesses the continued appropriateness of the previously selected investment discipline(s) and makes changes as the Bellwether deems appropriate. Similarly, if RJA changes its opinion of a Manager or investment discipline, RJA will ask Bellwether to select a new Manager or investment discipline for a participating client. Margin Accounts: Risks/Conflict of Interest. Bellwether may recommend the use of margin for investment purposes. A margin account is a brokerage account that allows investors to borrow money to buy securities. By using borrowed funds, the customer is employing leverage that will magnify both account gains and losses. The broker-dealer charges the investor interest for the right to borrow money and uses the securities as collateral. Should a client determine to use margin, Bellwether will include the entire market value of the margined assets when computing its advisory fee. Accordingly, Bellwether’s fee shall be based upon a higher margined account value, resulting in Bellwether earning a correspondingly higher advisory fee. As a result, the potential of conflict of interest arises since Bellwether may have an economic disincentive to recommend that the client terminate the use of margin. ANY QUESTIONS: Our Chief Compliance Officer, John Lindsey, remains available to address any questions that a client or prospective client may have regarding the use of margin. Participant Directed Retirement Plans. As noted above, Bellwether may also provide investment advisory and consulting services to participant directed retirement plans per the terms and conditions of a Retirement Plan Consulting Agreement between Bellwether and the plan. For such engagements, Bellwether shall assist the Plan sponsor with the ongoing review the plan sponsor’s investment platform from which Plan participants shall make their respective investment choices, and, to the extent engaged to do so, may also provide corresponding education to assist the participants with their decision-making process. Inverse/Enhanced Market Strategies: Bellwether may utilize long and short mutual funds and/or exchange traded funds that are designed to perform in either an: (1) inverse relationship to certain market indices (at a rate of 1 or more times the inverse [opposite] result of the corresponding index) as an investment strategy and/or for the purpose of hedging against downside market risk; and (2) enhanced relationship to certain market indices (at a rate of 1 or more times the actual result of the corresponding index) as an investment strategy and/or for the purpose of increasing gains in an advancing market. There can be no assurance that any such strategy will prove profitable or successful. In light of these enhanced risks/rewards, a client may direct Bellwether, in writing, not to employ any or all such strategies for the client’s account. Custodian Charges-Additional Fees: As discussed below at Item 12, when requested to recommend a broker-dealer/custodian for client accounts, Bellwether generally recommends that Raymond James and Associates (“RJA”) serve as the broker-dealer/custodian for client investment management assets. Broker- dealers such as RJA 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 RJA, do not currently charge fees on individual equity transactions, others do). Please Note: there can be no assurance that RJA will not change its transaction fee pricing in the future. Please Also Note: RJA may also assess fees to clients who elect to receive trade confirmations and account statements by regular mail rather than electronically. When beneficial to the client, individual fixed-income and/or equity transactions may be effected through broker-dealers with whom Bellwether 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 RJA). Nonetheless, transaction-related or administrative fees may be charged in connection with certain securities transactions ( and in connection with platform participation) and (b) internal charges may be assessed at the fund level by the mutual fund or ETF product sponsor. These fees/charges are in addition to Bellwether’s investment advisory fee at Item 5 below. Bellwether does not receive any portion of these fees/charges. ANY QUESTIONS: Bellwether’s Chief Compliance Officer, John Lindsey, remains available to address any questions that a client or prospective client may have regarding the above. Non-Discretionary Service Limitations. Clients that determine to engage Bellwether on a non- discretionary investment advisory basis must be willing to accept that Bellwether cannot effect any account transactions without obtaining prior consent to such transaction(s) from the client. Thus, should Bellwether desire to make a transaction for a client’s account (as a result of, and including an event that effects individual holdings or because of a general market correction), and the client is unavailable, Bellwether will be unable to effect the account transaction(s) (as it would for its discretionary clients) without first obtaining the client’s consent. Portfolio Activity. Bellwether has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Bellwether 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 Bellwether determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by Bellwether will be profitable or equal any specific performance level(s). Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Please Note: Cash Positions. Bellwether continues to treat cash as an asset class. As such, unless determined to the contrary by Bellwether, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Bellwether’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), Bellwether 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, Bellwether’s advisory fee could exceed the interest paid by the client’s money market fund. ANY QUESTIONS: Bellwether’s Chief Compliance Officer remains available to address any questions that a client or prospective may have regarding the above fee billing practice. Advyzon. In conjunction with the services provided by Advyzon, Bellwether may also provide periodic comprehensive reporting services, which can incorporate all of the client’s investment assets including those investment assets that are not part of the assets managed by Bellwether (the “Excluded Assets”). Bellwether’s service relative to the Excluded Assets is limited to reporting services only, which does not include investment implementation. Because Bellwether does not have trading authority for the Excluded Assets, to the extent applicable to the nature of the Excluded Assets (assets over which the client maintains trading authority vs. trading authority designated to another investment professional), the client (and/or the other investment professional), and not Bellwether, shall be exclusively responsible for directly implementing any recommendations relative to the Excluded Assets. The client and/or their other advisors that maintain trading authority, and not Bellwether shall be exclusively responsible for the investment performance of the Excluded Assets. Without limiting the above, Bellwether shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. In the event the client desires that Bellwether provide investment management services with respect to the Excluded Assets, the client may engage Bellwether to do so pursuant to the terms and conditions of the Investment Advisory Agreement between Bellwether and the client. Client Obligations: In performing our services, Bellwether 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. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify Bellwether if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. The client is also responsible for providing current contact information. Structured Notes. Bellwether may purchase structured notes for client accounts. A structured note is a financial instrument that combines two elements, a debt security and exposure to an underlying asset or assets. It is essentially a note, carrying counter party risk of the issuer. However, the return on the note is linked to the return of an underlying asset or assets (such as the S&P 500 Index or commodities). It is this latter feature that makes structured products unique, as the payout can be used to provide some degree of principal protection, leveraged returns (but usually with some cap on the maximum return), and be tailored to a specific market or economic view. In addition, investors may receive long-term capital gains tax treatment if certain underlying conditions are met and the note is held for more than one year. Finally, structured notes may also have liquidity constraints, such that the sale thereof before maturity may be limited. See additional disclosure at Item 8 below. In the event that he client seeks to prohibit or limit the purchase of structured notes for the client’s account, the client can do so, in writing, addressed to Bellwether’s Chief Compliance Officer. Please Note: Fee Differentials. Bellwether shall generally price its advisory services based upon various objective and subjective factors. As a result, our clients could pay diverse fees based upon the type, amount and market value of their assets, the anticipated complexity of the engagement, the anticipated level and scope of the overall investment advisory services to be rendered, negotiations. Additional factors effecting pricing can include related accounts, employee accounts, competition, and negotiations. As a result of these factors, similarly situated clients could pay diverse fees, and the services to be provided by Bellwether to any particular client could be available from other advisers at lower fees. All clients and prospective clients should be guided accordingly. ANY QUESTIONS: Bellwether’s Chief Compliance Officer, John Lindsey, remains available to address any questions regarding advisory fees. Disclosure Statement. A copy of Bellwether’s written Brochure as set forth on Part 2A of Form ADV, in addition to Form CRS, shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement, Retirement Plan Consulting Agreement or Financial Planning and Consulting Agreement. Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Bellwether) will be profitable or equal any specific performance level(s). C. Bellwether shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, Bellwether shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on Bellwether’s services. D. Bellwether does not participate in a wrap fee program. E. As of December 31, 2022, Bellwether had $109,454,676 in assets under management on a discretionary basis and $9,300,535 in assets under management on a non-discretionary basis.