Introduction FWG Investments is a registered investment adviser with its principal place of business in Lexington, Kentucky. Donald Bentley and Jeffrey Sheppard each now own exactly 50% of FWG Investments, LLC. Donald Bentley owns his stake in the firm through a limited liability company as does Jeffrey Sheppard. The transaction closing date was March 4, 2022. The investment advisory services of FWG Investments are provided to you through an appropriately licensed and qualified individual who is an investment adviser representative of FWG Investments (referred to as your investment adviser representative throughout this brochure). Description of Advisory Services The following are descriptions of the primary advisory services of FWG Investments. Please understand that a written agreement, which details the exact terms of the service, must be signed by you and FWG Investments before we can provide you with the services described below. Financial Planning Services FWG Investments offers financial planning services as part of their traditional investment advisory services, which typically address the following topics:
• Investment Planning,
• Retirement Planning,
• Insurance Planning,
• Tax Planning,
• Education Planning,
• Portfolio Reviews,
• Asset Allocation, and
• Real Estate Planning. When providing financial planning services, the role of your investment adviser representative is to find ways to help you understand your overall financial situation and help you set financial objectives. Asset Management Services sub-advised by AE Wealth Management FWG Investments has entered into a sub-advisory agreement with AE Wealth Management, LLC (“AE Wealth Management”), an SEC registered investment advisor, to provide investment advisory services to clients. The Program provides clients with the opportunity to establish mutual fund portfolios, separate account portfolios and managed account portfolios developed by both FWG Investments and by third party investment managers. FWG Investments, LLC Page 5 Form ADV Part 2A: Firm Brochure The primary investment management service we provide is a discretionary asset management program. Clients participating in this program are generally placed in a model overseen by a financial professional at our firm and sub-advised by a third-party investment adviser. Under this program, FWG Investments and any sub-advisers we hire to manage the assets in your account are authorized to buy and sell investments in the account without asking you in advance. We will monitor the portfolio's performance on an ongoing and continuous basis, unless otherwise agreed, and will make adjustments and reallocations as necessary due to changes in market conditions and your unique circumstances. Clients have the ability to impose reasonable restrictions and guidelines on investing in certain securities, types of securities or industry sectors. We expect all such restrictions to be timely communicated to us. Client restrictions and guidelines could negatively affect investment performance. Clients must inform us of any changes to their financial circumstances, investment objectives or risk tolerance, or of any modifications or restrictions that are imposed on the management of the client's account. In this manner, our firm can better serve clients' needs. Services provided as sponsor of the Program include technology platforms to support data reconciliation, performance reporting, fee calculation and billing, research, client database maintenance, quarterly performance evaluations, models, trading platforms, and other functions related to the administrative tasks of managing client accounts. FWG Investments assists clients with the establishment of one or more individual accounts at National Financial Services through the Fidelity Institutional Wealth Program (collectively referred to as Fidelity). Clients must appoint FWG Investments and AE Wealth Management, as a sub-adviser, as their investment advisors of record on the account. The qualified custodian maintains physical custody of all funds and securities of the account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the account. Clients will receive continuous investment advice based on your needs and circumstances. Utilizing tools provided by AE Wealth Management, FWG Investments will determine the suitability of the asset allocation and investment options for each client. FWG Investments will then assist clients in allocating their assets among different investment options in the Program and recommend strategies developed by FWG Investments or by the sub-adviser. Your accounts may be comprised of equity-based investments determined and selected by FWG Investments using our standard growth and dividend income strategies. Accounts not being managed using our own equity-based investment strategies will be managed using one or more strategies developed by AE Wealth. Clients will grant FWG Investments discretionary authority with respect to investment and advisory services provided to Program clients. Additionally, each client will grant AE Wealth Management full discretionary authority to (i) invest and reinvest the assets in the Program and (ii) retain Model Managers with respect to all or a part of account assets. This means AE Wealth Management will have trading authority on your account, which is necessary to trade the recommended investments. FWG Investments will also direct AE Wealth Management to trade accounts managed using FWG Investments’ own strategies. FWG Investments, LLC Page 6 Form ADV Part 2A: Firm Brochure Although we review the performance of Model Managers, we are only able to select the investment managers approved by AE Wealth Management. Therefore, we have a conflict of interest because we do not recommend Model Managers to you if the investment manager is not available through AE Wealth Management. We will provide you with a copy of AE Wealth Management’s disclosure brochure which contains a detailed description of AE Wealth Management

and the services they provide. Administrative Services Provided by Orion Advisor Services, LLC To help manage accounts through the AE Wealth Management, we utilize Orion Advisor Services, LLC (referred to as “Orion”) technology platforms to support data reconciliation, performance reporting, fee calculation and billing, client database maintenance, quarterly performance evaluations, and other functions related to the administrative tasks of managing client accounts. Due to this arrangement, Orion will have access to client accounts, but Orion will not serve as an investment advisor to our clients. Orion receives a portion of the overall fee charged to our client accounts. Non-Managed (Courtesy) Account Services Upon discretion and final approval by FWG Investments, some clients may be allowed to establish one or more non-managed (also known as “courtesy”) accounts through Fidelity Investments and appoint FWG Investments as the investment advisor to the account. While our Firm will be listed as an investment advisor on a courtesy account; courtesy accounts do not receive ongoing supervision and monitoring services like those provided to accounts through our Asset Management Services described above. We do not make any investment recommendations and will not monitor specific securities or general portfolios for these accounts. The primary purpose of this service is to include non-managed accounts owned by the client in the performance reports provided by our firm to those clients. Although we do not provide on-going management services or provide specific investment recommendations for these accounts, non-managed accounts will be included in the performance reports that are prepared and provided by FWG Investments. Clients are solely responsible for initiating all purchase and sale decisions of general securities held in non-managed accounts. Therefore, clients with courtesy accounts, and not FWG Investments or any of our employees, will have the exclusive responsibility for the performance and monitoring of all securities that are purchased for, or held, in the non-managed account. FWG Investments does not currently charge a fee for this service. However, clients will be required to enter into a written agreement with FWG Investments, and they will be provided with a copy of this disclosure brochure prior to establishing a courtesy account. Newsletters - FWG Investments occasionally prepares general, educational and informational newsletters. Newsletters are always offered on an impersonal basis and do not focus on the needs of FWG Investments, LLC Page 7 Form ADV Part 2A: Firm Brochure a specific individual. We do not charge a subscription or other fee for sending newsletters. Types of Securities FWG Investments provides investment advice on the following types of investments:
• Equity Securities (e.g., stocks)
• Exchange Traded Funds (ETFs)
• Fixed Income Securities (e.g., bonds)
• Options Contracts on Securities
• Mutual Funds
• Exchange-listed Securities
• Corporate Debt Securities
• Variable Life Insurance Although we generally provide advice only on the products previously listed, we reserve the right to offer advice on any investment product that may be suitable for each client’s specific circumstances, needs, goals and objectives. It is not our typical investment strategy to attempt to time the market, but we may increase cash holdings modestly as deemed appropriate based on your risk tolerance and our expectations of market behavior. We may modify our investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.) Tailor Advisory Services to Individual Needs of Clients FWG Investments advisory services are always provided based on your individual needs. This means, for example, that when we provide asset management services, you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. Our financial planning services are always provided based on your individual needs. When providing financial planning services, we work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. We will not enter an investment adviser relationship with a prospective client whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. FWG Investments, LLC Page 8 Form ADV Part 2A: Firm Brochure Rollover Recommendations 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 interest 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. Client Assets Managed by FWG Investments FWG Investments has a total of $205,904,853 in regulatory assets under management to report as of December 31, 2023. All assets are managed on a discretionary basis.