A. Conway Financial Group, LLC (the “Adviser,” “we,” “us,” or “our”) is an investment adviser founded in 2001, registered with the U.S. Securities and Exchange Commission (“SEC”), and principally owned by Patricia Conway and Dylan Camp.
B. Adviser offers the following types of advisory services: i.Annual Financial Planning & Investment Implementation Services. Annual Financial Planning & Investment Implementation Services shall be inclusive of one meeting between the client and Adviser per year during which Adviser shall assess the client’s financial condition, cash flow, goals, risk tolerance, future income needs, liquidity requirements, investment time horizon, and other information that is relevant to the client’s financial life. This information will be used to deliver analyses and recommendations with respect to various topics as mutually agreed between Adviser and the client. Such topics could include, for example, retirement planning, education savings, cash flow management, debt reduction, employee benefits analysis, estate planning, insurance needs, investment allocations, risk mitigation, tax planning, financial goal tracking, etc.
After the conclusion of the annual meeting between the client and Adviser described above, the client may instruct Adviser to implement the investment transactions discussed and agreed-to during such annual meeting in the client’s account(s). Pursuant to a limited power of attorney signed by the client, Adviser shall execute such investment transactions in the client’s account(s) at the client’s independent and unaffiliated third-party custodial broker-dealer. Adviser shall not be granted any discretionary trading authority in carrying out such transactions.
Except with respect to the client-directed investment transactions described above, Adviser shall not be responsible for the actual implementation of its recommendations.
The responsibility to implement Adviser’s recommendations shall rest solely with the client, and the client may accept or reject Adviser’s recommendations in its sole and absolute discretion. If the client elects to act on any such recommendations, the client is under no obligation to effect any transactions through Adviser or any of its investment adviser representatives (“IARs”).
Financial planning topics and deliverables may include the following: A Written Statement of Goals and Objectives In the planning process, the client is encouraged to define his/her specific goals and to answer such questions as “What do I hope to achieve with this process?” and “What are my priorities, financially, for myself (spouse, children) and how can I achieve these goals?” A Risk Profile for Both the Client and the Spouse You will be given a questionnaire to fill out independent of one another. This will help you and us to better understand how you approach investment decisions and investment risk.
We will prepare your Investment Objectives and your Investment Risk Profile, which will help determine how your investment portfolio should be distributed among various investment asset classes.
Cash Flow and Tax Planning You will be asked to provide, in great detail, information about your income and spending habits, your investments, retirement funds, etc. This information will be held in the strictest confidence. We will utilize this data in developing an investment distribution schedule, estimated taxable income report, and a cash flow projection. An income and cash flow summary statement will help you understand how your funds are being consumed and where you may have a shortfall, if any.
Investment Portfolio Allocation Implementation A review of your investment portfolio, in conjunction with your goals and objectives, your cash flow and your federal tax situation, will allow for the development of an investment policy statement. This will summarize our portfolio target asset allocation, which incorporates the client’s risk tolerance. A current investment distribution will be prepared to show the client’s investment allocation mix utilizing fixed income, equities, and real assets. Your investment plan will recommend changes, if any, which need to be made in order to help achieve your stated objectives. Assistance in the implementation of the recommendations will be provided.
Adviser generally implements its investments strategy by allocating clients’ investable assets across a diversified risk-based portfolio of no-load mutual funds and/or exchange traded funds (“ETFs”), as well as individual stocks and bonds. The asset allocation may be changed from time to time based on changes to a client’s specific situation. Accounts are held at the client’s Custodian and the Custodian may charge commissions for the purchase or sale of a mutual fund, ETF, stock, or bond. The brokerage firm charges a fee for stock and bond trades. Adviser does not receive any compensation, in any form, from fund companies.
Investments may also include: corporate debt securities, certificates of deposit, municipal securities,

and investment company securities. Initial public offerings (IPOs) are not available through Adviser.
Retirement Planning A retirement needs analysis, based on your financial situation, may be prepared. This will help to answer questions such as “Can I afford to retire?” and “Will I outlive my money?”.
Assumptions about income, social security, inflation, expectations, spending, and longevity will all be written down and reviewed over time as needs and expectations change.
Risk Management A review of your current insurance coverage will provide assurance that you and your family are adequately covered by financially stable insurance companies. This will provide an opportunity to review your insurance with your agent and to make any changes recommended.
Estate Planning A review of your current estate plan, if appropriate, may be provided. An estate tax analysis will show the possible tax implications on your estate with the first to die and the subsequent death of the remaining spouse. This provides the opportunity to review, with your estate planning attorney, your current documents and to make any additions or changes to assure that your estate will pay the minimum in taxes and be distributed according to your wishes.
Other Specific Client Needs Other areas of concern such as education funding or disability needs, will be addressed and will be included in your financial plan.
Special Project Plans Projects may be undertaken that are not described in other types of agreements, including the development and implementation of Investment Planning recommendations, periodic investment portfolio review, assistance with tax planning, or other services specifically described in an engagement letter.
ii.Ongoing Investment Management. Adviser provides ongoing discretionary or non-discretionary investment management services to its clients based upon each client’s current financial condition, goals, risk tolerance, income, liquidity requirements, investment time horizon, and other information that is relevant to the management of clients’ account(s), and inclusive of ongoing financial planning advice and recommendations over the course of the year. This information will then be used to make investment decisions or recommendations that reflect clients’ individual needs and objectives on an initial and ongoing basis. Adviser’s investment decisions and recommendations will allocate portions of clients’ account(s) to various asset classes classified according to historical and projected risks and rates of return. If a client grant’s Adviser discretionary trading authority, Adviser will retain the discretion to buy, sell, or otherwise transact in securities and other investments in a client’s accounts without first receiving the client’s specific approval for each transaction. Such discretionary authority is granted by a client in his or her investment management agreement with Adviser. If a client does not grant Adviser non-discretionary trading authority, clients must first authorize any such trading in their account(s). Clients may impose restrictions on investing in certain securities or types of securities so long as such restrictions may reasonably be implemented by Adviser.
C. Adviser generally implements its investments strategy by allocating clients’ investable assets across a diversified risk-based portfolio of no-load mutual funds and/or exchange traded funds (“ETFs”), stocks, and bonds. This portfolio is rebalanced periodically to remain in-line with the client’s agreed-upon asset allocation, though the asset allocation may be changed from time to time based on changes to a client’s specific situation.
D. Adviser does not participate in any wrap fee programs.
E. 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 (“ERISA”) and/or the Internal Revenue Code (the “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 interest ahead of yours. Under this special rule’s provisions, we must: i.Meet a professional standard of care when making investment recommendations (give prudent advice); ii.Never put our financial interests ahead of yours when making recommendations (give loyal advice); iii.Avoid misleading statements about conflicts of interest, fees, and investments; iv.Follow policies and procedures designed to ensure that we give advice that is in your best interest; v.Charge no more than is reasonable for our services; and vi.Give you basic information about conflicts of interest.
F. Adviser manages the following amount of discretionary and non-discretionary client assets calculated as of December 31, 2023: Discretionary:$105,090,830 Non-Discretionary:$0 Total:$105,090,830