PFG Advisors, LLC (hereinafter referred to as “PFG”, “PFG Advisors”, “PFGA”, “us”, “we”, “our” or “the firm”) became registered as a SEC investment advisor in December 2014. PFG Advisors is wholly owned by Priority Financial Group, LLC. PFG Advisors provides fee-based investment advisory services for compensation primarily to individual clients (hereinafter referred to as “client”, “clients”, “you”, or “your”), including high-net worth individuals based on the individual goals, objectives, time horizon, and risk tolerance of each client. Portfolio management services include, but are not limited to, the following:
• Investment strategy • Asset selection
• Personal investment policy • Risk tolerance
• Asset allocation • Regular portfolio monitoring Investment advisory services are offered through investment advisor representatives (hereinafter referred to as “IARs”, “Advisors”, “Associates”, “Associated persons” or “Supervised persons”) registered with PFG Advisors and can provide services and charge fees in accordance with the descriptions detailed in this document and the client account agreement. However, the exact service and fees charged to a particular client are dependent upon the Advisor that is working with the client. Many IARs are dually licensed (e.g., registered with a broker-dealer firm called Securities America or “SAI” which is soon to be known as Osaic Wealth or Osaic) as a registered representative and also registered with our investment advisory firm, PFG Advisors. As an Osaic registered representative, he/she is permitted to offer commission-based products to you. Your IAR will disclose to you whether he/she is dually licensed and if there are any limitations on services offered due to their registrations and qualifications. Osaic and PFG Advisors are separate entities. PFG Advisors is not a broker-dealer firm. IARs can develop their own investment strategies and/or utilize unaffiliated third-party money managers/investment advisers. This allows our IARs to select the programs that they believe are best suited to meet each client’s needs and circumstances. There is no guarantee, stated or implied, that a strategy or client’s investment goals or objectives will be achieved. Asset Management PFG Advisors offers discretionary and non-discretionary asset management services. Advisory client assets are held at qualified custodians, primarily Charles Schwab & Co., (TD Ameritrade has now completed its merger with Charles Schwab & Co.), Fidelity and Pershing. The qualified custodians maintain physical custody of your funds and securities and you retain all rights of ownership (e.g., right to withdraw securities, cash, exercise proxy voting and receive transaction confirmations). These qualified custodians are unaffiliated with PFG Advisors. PFG Advisors is not a custodian of your funds or securities. IARs provide investment advice on the purchase and sale of various types of investments, and will generally include advice regarding security types including but not limited to:
• Mutual funds
• Exchange-traded funds (“ETFs”)
• Variable annuity subaccounts
• Real Estate Investment Trusts ("REITs")
• Equities
• Options
• Warrants
• Corporate debt securities (other than commercial paper)
• Certificates of Deposit
• Municipal Securities
• United States governmental securities
• Exchange-listed securities
• Securities traded over-the-counter
• Structured Notes Different types of investments involve certain additional degrees of risk, securities will be recommended as part of the client’s overall portfolio that is consistent with the client's stated investment objectives, risk tolerance, liquidity and suitability. Accounts are reviewed on a regular basis and rebalanced as necessary according to each client's investment profile. Clients may impose restrictions on investing in certain securities or types of securities and you are under no obligation to implement any recommendations made by your IAR. PFGA Portfolios Where suitable for a client, PFG Advisors’ IARs may utilize an independent asset management firm, typically an unaffiliated registered investment advisor firm that assists us with identifying and recommending appropriate investment options for you, particularly for a specific type of investment management or strategy. In this context, we work with two unaffiliated asset management firms, primarily Dynamic Advisors Solutions, LLC (“Dynamic”) and Cantor Fitzgerald Investment Advisors (“CFIA”), as an investment model provider. CFIA provides consulting services with regard to certain investment models. At its discretion, PFG Advisors may recommend access to Dynamic’s wealth management platform. Dynamic designs and implements investment models for suitable clients, including periodic rebalancing, re-allocating, trading and reporting. Under this arrangement, we have the flexibility to select the investment model best suited for you based on your financial goals and objectives. In addition to our disclosures, you are provided with Dynamic’s Form ADV Part 2. Dynamic and PFG Advisors receives compensation under separate written agreements. Please refer to Item 10 for more information on PFG Advisors’ relationship with Dynamic. Dynamic has several strategies and generally include: Low-cost passive equity exposure, multi-factor equity exposures combined and actively managed fixed income, and customizable portfolios designed to meet a client’s investment objectives. In addition, PFG Advisors has entered into a model provider relationship with Cantor Fitzgerald Investment Advisors, LP(“CFIA”). CFIA provides PFG Advisors with access to a CFIA financial professional and a variety of ETF model portfolios. PFG Advisors will assist the client in selecting one or more PFGA Portfolios that align with the client’s tolerance for risk and their stated time horizon. The investment philosophy of these portfolios emphasizes top down, macroeconomic research in creating an active asset allocation strategy. PFGA Portfolios primarily uses index-based ETFs, which are passive investment vehicles in order to gain diversified exposure to a desired asset class or category. Rebalancing PFGA Portfolios Rebalancing is the process of selling portions of an investment in a particular asset class or security that has increased as a percentage of the Portfolio to a level beyond its intended or target allocation. Proceeds from rebalancing sales are used to buy additional positions in other asset classes or securities that have fallen below their intended target allocation. Management Services for “Held Away” Assets We provide an additional service for advisory clients’ accounts not directly held with a qualified custodian of PFGA, but where we have discretion pursuant to our investment advisory relationship with our clients. We use a third-party platform to facilitate management of those “held away” assets which include for example, 401k, and 403b accounts. Through the platform, we review the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other advisory clients’ advisory accounts that are held with our custodian partners. Third-Party Money Manager Services PFG Advisors may utilize the services of a Third-Party Money Manager (“TPMM”) program to assist with the investment management needs of a client. These services generally fall within two categories: a solicitor (n/k/a “promoter”) relationship directly with the TPMM and an advisory relationship (also known as a turnkey asset management program or “TAMP”). In the solicitor arrangement, the IAR will assist you in engaging directly with a TPMM to manage your account. PFG Advisors receives a promoter’s fee for the referral from the TPMM for this engagement and pays it out to the IAR. TAMPs are where your IAR of PFG Advisors may, within the TAMP program, recommend one or more TPMMs to manage your account or a portion of your account. In these cases, this is a co-advisor arrangement and the IAR of PFG Advisors does not act as a solicitor. Rather, you pay the IAR of PFG Advisors a management fee for their services. Following recommendations by your IAR, you will have final authority to select a Manager. The IAR will assist you in completing appropriate documents. TPMMs enable the IAR to provide institutional level investment management services that include a wide range of investment strategies. Your IAR is responsible for selecting the most appropriate TPMM and/or investment strategy based on your financial situation, investment objectives and risk tolerance. In all cases, you will receive additional disclosure materials about the TPMM and their services as well as appropriate disclosure materials from PFG Advisors. You will enter into an agreement with PFG Advisors and, in most cases, an agreement directly with the TPMM or TAMP. You are advised and should understand that:
• A Manager’s past performance does not guarantee future results;

• Various market and other risks may adversely affect any Manager’s objectives and strategies and could cause a loss in a client's account(s); and,
• Client risk parameters provided to PFG Advisors are guidelines only and there is no guarantee that they will not be exceeded. You will provide discretionary trading authorization to the selected Manager for management of your account and PFG Advisors does not have any discretionary trading authority with respect to such accounts. Information provided to you by our firm regarding TPMMs is believed to be reliable and accurate but should not be considered as a replacement for account statements that you receive directly from the TPMM. Regular performance reporting will be the responsibility of the respective Manager. Such performance reports will be provided directly to you and PFG Advisors. PFG Advisors does not audit or verify that these results are calculated on a uniform or consistent basis as provided by a Manager directly to PFG Advisors or through the consulting service utilized by the Manager. AssetMark AssetMark offers a platform called Advisor as Strategist (“AAS Program”). The AAS Program provides tools to establish and maintain model portfolios for the investment of client accounts and to invest client accounts with those models. AssetMark has established relationships with independent investment management firms and include PFG Advisors (“the Strategist(s)”), to create a variety of strategic asset allocation model portfolios (“Models”) comprised with mutual funds (both independent and affiliated with AssetMark) and ETFs. The Strategist will select and monitor the performance of the mutual funds and ETFs in their Models (there are six model portfolios ranging from conservative to growth) and will periodically adjust and rebalance the portfolios in accordance with their investment strategies. We, and not AssetMark are solely responsible for the determining the appropriate Model for the client in connection with the client’s investment goals and objectives. The Strategists available on the platform are selected by AssetMark to provide a wide range of investment options. Each Strategist will provide a range of Models corresponding to a specific risk-return profiles ranging from conservative to maximum growth. The Models will be generally rebalanced quarterly. All transactions will be effected automatically through software administered by AssetMark. For additional information, please refer to the Disclosure Brochure and other materials for AssetMark and the Strategists available on the platform. Schwab Institutional Intelligent Portfolios™ For the appropriate clients, we may recommend portfolio management services through Institutional Intelligent Portfolios™, an automated, online investment management platform for use by independent investment advisors and sponsored by Schwab Wealth Investment Advisory, Inc. (the “Program” and “SWIA,” respectively). Through the Program, we offer clients a range of investment strategies we have constructed and manage, each consisting of a portfolio of exchange traded funds (“ETFs”) and a cash allocation. The client may instruct us to exclude up to three ETFs from their portfolio. The client’s portfolio is held in a brokerage account opened by the client at SWIA’s affiliate, Charles Schwab & Co., Inc. (“Schwab”). We are independent of and not owned by, affiliated with, or sponsored or supervised by SWIA, Schwab or their affiliates (together, “Schwab”). The Program is described in the Schwab Wealth Investment Advisory, Inc. Institutional Intelligent Portfolios™ Disclosure Brochure (the “Program Disclosure Brochure”), which is delivered to clients by SWIA during the online enrollment process. We, and not Schwab, are the client’s investment advisor and primary point of contact with respect to the Program. We are solely responsible, and Schwab is not responsible, for determining the appropriateness of the Program for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis. SWIA’s role is limited to delivering the Program Disclosure Brochure to clients and administering the Program so that it operates as described in the Program Disclosure Brochure. Financial Planning/Consulting Services As part of our financial planning services, PFG Advisors, through its IARs, can provide personal financial planning tailored to the individual needs of the client. These services may include, as selected by the client on the Financial Planning/Consulting Agreement, information and recommendations regarding tax planning, retirement planning, estate needs, education planning, life and disability insurance needs, long-term care needs, and customized services. The services consider information collected from the client such as financial status, investment objectives and tax status, among other data. For planning services, the Financial Planning/Consulting Agreement will address whether a written plan is included or not. Frequency of the fees for such services are negotiable and detailed in the Financial Planning/Consulting Agreement. The financial plan may include generic recommendations as to the general types of investment products or specific securities which is deemed to be appropriate for the Client to purchase given his/her financial situation and objectives. The Client is under no obligation to act upon the IAR’s recommendation or purchase such securities through and the IAR. However, if the Client desires to purchase securities or advisory services in order to implement his/her financial plan, PFG Advisors may make a variety of products and services available through its IARs resulting in the payment of standard and customary commissions, advisory fees or other types of compensation to PFG Advisors and the IAR. A conflict exists between the interests of the IAR and the interests of the client. Depending on the type of account that could be used to implement a financial plan, such compensation may include (but is not limited to) advisory fees, advisory program wrap fees, or commissions.;\ To the extent that an IAR recommends that a Client invest in products and services that will result in compensation being paid to PFG Advisors and the IAR, this presents a conflict of interest. This compensation to the IAR and PFG Advisors may depend on the product or service that the IAR recommends. Therefore, the IAR has a financial incentive to recommend that a financial plan implemented using a certain product or service over another product or service. However, at all times PFG Advisors and their IARs must act in the client’s best interest and act as a fiduciary in carrying out the services provided. A few IARs may provide accounting or tax services as an outside business activity, however PFG Advisors does not share in any compensation received by such IARs for performing such services. You are not obligated to utilize such IARs for accounting or tax services. PFG Advisors does not provide accounting or legal advice and encourages clients to work closely with his/her attorney or accountant regarding such matters. Retirement Planning When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries 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. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. PFG Wrap Fee Program In addition to the advisory business described above, we also sponsor PFGA wrap fee programs. Under the wrap fee programs, investment advice and costs of trade executions provided to clients are bundled into one fee for an all-inclusive wrap fee. This means that under wrap fee programs, we pay the trading costs out of the advisory fee that we receive from you. There is no difference between how we manage wrap fee accounts and how we manage other accounts. For more information about PFG Advisors’ wrap fee program(s), please see the PFG Advisors Form ADV Part 2A, Appendix 1 wrap fee disclosure brochure. Assets Under Management As of December 31, 2023, total assets under management were $1,953,295,383.00 (discretionary) and $379,983,192.00 (non-discretionary) for an aggregate total of $2,333,278,575.00.