– Advisory Services A. Firm Information RPg Family Wealth Advisory, LLC (“FWA” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). FWA was founded in 2011 as a wholly-owned subsidiary of Risk Paradigm Group Holdings, LLC, a privately held limited liability company (“LLC”) that is organized under the laws of the State of Delaware. David M. Gatti (Chief Executive Officer, Chief Investment Officer) is the principal officer of FWA. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by FWA. Please contact Robert McCauley, FWA’s Chief Compliance Officer (“CCO”), with any questions regarding this Disclosure Brochure. Mr. McCauley can be reached at (888) 285-8600 or via email at [email protected]. B. Advisory Services Offered FWA provides customized wealth advisory services to individuals, high net worth individuals, trusts, estates, charities, businesses, and retirement plans (each referred to as a “Client”). FWA’s primary mission is to understand Clients’ challenges and objectives, and to formulate comprehensive wealth management strategies that meet their individual needs. The Advisor adheres to the highest fiduciary standards, as demonstrated by always putting Clients’ interests first and continuously striving to act in the best interest of our Clients. FWA serves as a fiduciary to Clients, as defined under the 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. FWA’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services FWA provides Clients with wealth management services, which generally includes a broad range of comprehensive financial planning and consulting strategies as well as discretionary and non-discretionary management of investment portfolios. This is achieved through a combination of (i) regular personal Client contact and interaction, (ii) planning/consulting expertise utilized for the benefit of the Client, (iii) providing discretionary investment management services within Client accounts, and (iv) utilizing third party investment managers to achieve Client objectives. FWA works with each Client to identify their comprehensive goals as well as risk tolerance and financial situation in order initiate a strategy for supporting the Client. Financial Planning and Consulting Services – FWA provides its Clients with comprehensive financial planning and consulting services either as a component of its wealth management services or pursuant to a financial planning or consulting agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals, objectives and financial situation. FWA may also refer Clients to an accountant, attorney or other 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. Investment Management Services – FWA will construct a portfolio to meet the specific objectives of each Client. Portfolios are customized to the needs of each Client, but are typically constructed with a combination of individual equity securities, individual fixed income securities, mutual funds, exchange-traded funds (“ETFs”) and limited partnerships. Limited partnerships may include hedge funds, private investment pools and other limited partnerships that are appropriate to achieve the goals of the Client. The Advisor may also utilize other securities types, as appropriate, to meet the needs of Clients. FWA may periodically deliver investment management services through an affiliated investment manager, Risk Paradigm Group, LLC (“RPg Asset Management” or “RPg”). In this capacity, RPg will serve as a sub-advisor to FWA to conduct “Managed Accounts” activities for FWA and will administer investment management services through the individual Client accounts. For more information pertaining to this affiliation or potential conflicts, please see Item 10 of this Disclosure Brochure. FWA’s investment approach is primarily long-term outcome focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to the acceptance by the Advisor. FWA evaluates and selects securities, strategies, managers, funds, or models for inclusion in Client portfolios only after applying their internal due diligence process. FWA may recommend, on occasion, redistributing investment allocations to diversify the portfolio. FWA may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. FWA 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 the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will FWA accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated account[s]at the Custodian, pursuant to the terms of the investment advisory agreement, please see Item 12 – Brokerage Practices. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client

regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Selection of Third Party Investment Managers – As part of its comprehensive wealth management services, FWA may periodically recommend and refer Clients to a third-party investment manager or investment advisor (referred to herein as the “Third Party Manager”) at FWA's discretion or Client's request. In this scenario, the Client will then either (i) enter into a separate agreement with that Third Party Manager for services or (ii) utilize an existing contracted sub-advisory relationship between that Third Party Manager and FWA (the “Sub-advisory Agreement”) for the services that Third Party Manager will provide to the Client, most commonly the administration of a proprietary investment strategy by the respective Third Party Manager. In consideration for such services, the Third Party Manager will receive a fee, billed based on the fee schedule established in the Sub-advisory agreement. Whenever an existing contracted sub-advisory relationship with a Third Party Manager is utilized, the Client will be requested to acknowledge the services provided by the Third Party Manager and the associated fees in writing. As noted above, FWA will, when appropriate for the Client, utilize our affiliate Risk Paradigm Group, LLC (“RPg”) as the Third Party Manager. FWA has a contracted sub-advisory relationship with RPg. Use of RPg presents a conflict of interest. Please see item 10 below for more information. The Client, prior to entering into an agreement with a Third Party Manager, will be provided with the Third Party Manager's Form ADV 2A (or a brochure that makes the appropriate disclosures). Managed Account Programs – As part of its comprehensive wealth management services, FWA may recommend to Clients that all or a portion of their portfolio be implemented by utilizing one or more Third Party Managers participating in a Managed Accounts program (a “Program”) through the Client's selected Custodian or another independent platform (the “Program Sponsor”). The Client will then enter into a Program and Investment Advisory agreement with the Program Sponsor. FWA will assist and advise the Client in establishing investment objectives for the account[s], the investment offerings within the Program, and defining any restrictions on the account. FWA will continue to provide oversight of the Client’s account[s] and ongoing monitoring of the activities through the Program. In consideration for such services, the Program Sponsor will in some instances charge a Program fee that includes the investment advisory fee of any Third Party Managers, the administration of the Program and trading, clearance and settlement costs, as identified in the Program and Investment Advisory agreement between the Client and Program Sponsor. The Program Sponsor may add FWA’s investment advisory fee (described below in Item 5) and will deduct the overall fee from the Client account, generally at the start of each calendar quarter pursuant to the terms of the Program and Investment Advisory Agreement. The overall fee (including the Advisor's investment advisory fee as described in Item 5) will generally not exceed 3% annually. FWA does not receive any compensation from these Programs or the Program Sponsor, other than FWA’s investment advisory fee as described in Item 5. The Client, prior to entering into an agreement with a Program Sponsor, will be provided with the Program Sponsor's Form ADV Part 2A (or a brochure that makes the appropriate disclosures. Retirement Plan Advisory Services FWA provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Investment Oversight Services (ERISA 3(21))
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance These services are provided by FWA serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of FWA’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Prior to engaging FWA to provide wealth management services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authorities and responsibilities of the Advisor and the Client. These services may include: ● Wealth Planning – FWA provides comprehensive advice and guidance relating to the financial goals of its Clients. ● Establishing a Documented Financial Plan or Investment Policy Statement – FWA, in conjunction with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. ● Asset Allocation – FWA will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and risk tolerance for each Client. ● Portfolio Construction – FWA will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. ● Investment Advisory and Supervision – FWA will provide investment advisory and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs FWA does not manage or place Client assets into a wrap fee program. E. Assets Under Management As of December 31, 2023, FWA manages $492,260,301 in Client assets, $481,784,950 of which are managed on a discretionary basis and $10,475,351 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.