A. The Archer Consulting Group, LLC The Archer Consulting Group, LLC (“ACG” or “the firm”) is a Texas limited liability company. The firm’s principal owners are Jona Husbands, Allan Jaster, and Steven C. Rhatigan. ACG has been providing investment advisory services since 2011. A.1. Advisory Services Offered We offer Investment Management Services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Investment Management Services may include, but are not limited to, the following: ▪ Discretionary Investment Management ▪ Annual Investment Policy Statement ▪ Asset allocation, reviewed quarterly ▪ Regular and/or continuous portfolio monitoring, with quarterly portfolio reports ▪ Portfolio allocation with third-party managers ▪ Coordination with other third parties (accountants, attorneys, insurance agents, etc.) on an as-needed basis We use a scientific approach and a systematic strategy to manage investments. We follow strict fiduciary standards, putting our clients’ interests before our own and seeking to avoid conflicts of interest with our clients. All prospective clients are provided a complimentary consultation (not to last more than 1 hour) to determine the service most applicable to the client. Prior to engaging us, clients are required to enter into a formal advisory agreement setting forth the scope of the relationship, the terms and conditions, and responsibilities of both ACG and client. For discretionary investment management services, ACG receives a limited power of attorney to effect securities transactions on behalf of clients that include securities and strategies described in Item 8 of this brochure. Discretionary authority allows us to act on behalf of the client in most matters necessary or incidental to the handling of the account, including monitoring certain assets, without the client’s prior approval. Risk tolerance levels will be documented in the Investment Policy Statement (or similar document used to establish client’s objectives and suitability), which will be created and provided to each client. We act in accordance with the Investment Policy Statement regardless of discretionary authority. Advice and services provided under an advisory agreement are tailored to the stated objectives of the client(s). Through personal discussions in which goals and objectives are established, we develop a client’s personal investment policy and create and manage a portfolio based on that policy. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client’s prior investment history, as well as family composition and background. Under certain agreements, we will also provide clients with estate planning advice and guidance. This type of guidance may include a review of estate planning documents, general recommendations as well as recommendations relating to irrevocable life insurance trusts, and assisting clients with the facilitation of legal document creation with attorneys or other third parties. Clients are obligated to provide the firm with any reasonable investment restrictions that should be imposed on the management of their portfolio, and to promptly notify the firm in writing of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals and tolerance for risk. ACG will remind clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the client’s account. ACG will also contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives and tolerance for risk. A.2. Fees and Compensation A.2.a. Fee Schedule Our compensation is generally based on a percentage of Assets Under Management (AUM). Fees are charged in arrears based upon the market value of the account at the end of the quarterly billing period. Market value means the value of all assets in the account (not adjusted by any margin debit). For purposes of determining value, securities and other instruments traded on a market for which actual transaction prices are publicly reported shall be valued at the last reported sale price on the principal market in which they are traded (or, if there shall be no sales on such date, then at the mean between the closing bid and asked prices on such date). Other readily marketable securities shall be priced using a pricing service or through quotations from one or more dealers. Our standard fee schedule is: Account Assets Annual Fee First $1,000,000 1.25% Next $2,000,000 0.75% Over $3,000,000 0.50% We require a minimum investment amount of $1,000,000 to establish an Investment Management relationship. This amount may be reduced or waived by us if we determine a reduction or waiver is appropriate.
If we manage the portfolio of one or more immediate family members, we will aggregate and bill the portfolio as a family account. When an individual or family account moves upward or downward during the quarter to the next tier, it will be billed that respective tier’s percentage fee for the entire quarter. We may modify the fee at any time upon 30 days’ written notice to the client. In the event client is an ERISA-governed plan, fee modifications must be approved in writing by client. The trading cost component of the above-mentioned advisory fees are estimated to range from $500 to $1,500 per year based upon a $1,000,000 account size. These fees include charges for all transaction costs such as commissions on purchase and sales of stocks, bonds, exchange-traded funds and options, and mutual fund transactions fees. Except as otherwise provided below, client will incur no charges other than the adviser’s fee pursuant to the above fee schedule in connection with the maintenance of and activity in client’s account. The wrap fee does not include annual account fees or other administrative fees, such as wire fees, charged by manager or brokerage firm; fees for securities transactions executed away from the custodian; certain odd-lot differentials, transfer taxes, transaction fees mandated by the Securities Act of 1934, postage and handling fees, and charges imposed by law with regard to transactions in the client’s account; and advisory fees, expenses or sales charges (loads) of mutual funds (including money market funds), closed-end investment companies or other managed investments, if any, held in client’s account. The wrap fee also does not cover certain costs associated with securities transactions in the over-the-counter market, such as fixed income securities where manager must approach a dealer or market maker to purchase or sell a security. Such costs include the dealer’s mark-up, mark-down or spread and odd-lot differentials or transfer taxes imposed by law. B. Disclosure of Cost Difference if Services Purchased Separately Depending on a number of factors, such as the number, size and nature of the securities transactions in an advisory account, the overall fees and charges borne

by the client over time could be more or less than what these fees and charges would be if the same services were provided on a separate basis. Bundled fees generally provide an economic incentive for the advisory firm to select investments and strategies that minimize trading costs. Frequent trading in an account where transaction fees are included as part of the overall advisory fee to the client drive trading costs higher and reduce the overall fee revenue to the advisor. As a result, higher trading costs in a bundled fee account have a negative impact on the advisory firm’s profitability. C. Additional Client Fees and Terms of Payment C.1. Client Payment of Fees Advisory management fees are paid in arrears. ACG will deduct advisory fees directly from the client’s account provided that (i) the client provides written authorization to the qualified custodian, and (ii) the qualified custodian sends the client a statement, at least quarterly, indicating all amounts disbursed from the account. The client is responsible for verifying the accuracy of the fee calculation, as the client’s custodian will not verify the calculation. A client investment advisory agreement may be canceled at any time by the client, or by CWSFA with 30 days’ prior written notice to the client. Upon termination, any earned, unpaid fees will be due and payable. C.2. Additional Fees In addition to ACG’s fee, clients may incur certain charges imposed by custodians, brokers, third- party investment and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, mutual fund sales loads, 12(b)-1 fees, surrender charges, variable annuity fees and surrender charges, IRA and qualified retirement plan fees, and other fees and taxes. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Advisory fees charged by ACG are separate and distinct from the fees and expenses charged by investment company securities that may be recommended to clients. ACG does not share in or receive any portion of such fees. A description of these fees and expenses are available in each investment company security’s prospectus. Please refer to the Brokerage Practices section (Items 9.B.2 and 9.B.3) for additional information regarding the firm’s brokerage practices. D. Compensation for Recommending the Wrap Program The Wrap Program is a proprietary product offered exclusively through ACG. As such, there are no conflicts of interest in that there are no commissions paid for selling the Wrap Program. E. External Compensation for the Sale of Securities to Clients ACG’s advisory professionals are compensated primarily through a salary and bonus structure. ACG is not paid any sales, service, or administrative fees for the sale of mutual funds or any other investment products with respect to managed advisory assets. F. Important Disclosure – Custodian Investment Programs Please be advised that the firm utilizes certain custodians/broker-dealers. Under these arrangements we can access certain investment programs offered through such custodian(s) that offer certain compensation and fee structures that create conflicts of interest of which clients need to be aware. Please note the following: Limitation on Mutual Fund Universe for Custodian Investment Programs: There are certain programs in which we participate where a client’s investment options may be limited in certain of these programs to those mutual funds and/or mutual fund share classes that pay 12b-1 fees and other revenue sharing fee payments, and the client should be aware that the firm is not selecting from among all mutual funds available in the marketplace when recommending mutual funds to the client. Conflict Between Revenue Share Class (12b-1) and Non-Revenue Share Class Mutual Funds: Revenue share class/12b-1 fees are deducted from the net asset value of the mutual fund and generally, all things being equal, cause the fund to earn lower rates of return than those mutual funds that do not pay revenue sharing fees. The client is under no obligation to utilize such programs or mutual funds. Although many factors will influence the type of fund to be used, the client should discuss with their investment adviser representative whether a share class from a comparable mutual fund with a more favorable return to investors is available that does not include the payment of any 12b-1 or revenue sharing fees given the client’s individual needs and priorities and anticipated transaction costs. In addition, the receipt of such fees can create conflicts of interest in instances where the custodian receives the entirety of the 12b-1 and/or revenue sharing fees and takes the receipt of such fees into consideration in terms of benefits it may elect to provide to the firm, even though such benefits may or may not benefit some or all of the firm clients. Additional Disclosure Concerning Wrap Programs: To the extent that we either sponsor or recommend wrap fee programs, please be advised that certain wrap fee programs may (i) allow our investment adviser representatives to select mutual fund classes that either have no transaction fee costs associated with them but include embedded 12b-1 fees that lower the investor’s return (“sometimes referred to as “A-Shares,” depending on the mutual fund issuer), or (ii) allow the use of mutual fund classes that have transaction fees associated with them but do not carry embedded 12b-1 fees (sometimes referred to as “I-Shares,” depending on the mutual fund sponsor). Wrap fee programs offer investment services and related transaction services for one all-inclusive fee (except as may be described in the applicable wrap fee program brochure). The trading costs are typically absorbed by the firm and/or the investment representative. If a client’s account holds A-Shares within a wrap fee program, the firm and/or its investment adviser representative avoids paying the transaction fees charged by other mutual fund classes, which in effect decreases the firm’s costs and increases its revenues from the account. Effectively, the cost is transferred to the client from the firm in the form of a lower rate of return on the specific mutual fund. This creates an incentive for the firm or investment adviser representative to utilize such funds as opposed to those funds that may be equally appropriate for a client but do not carry the additional cost of 12b-1 fees. As a policy matter, the firm does not allow funds that impose 12b-1 or revenue sharing fees on the client’s investment within its wrap fee programs. Clients should understand and discuss with their investment adviser representative the types of mutual fund share classes available in the wrap fee program and the basis for using one share class over another in accordance with their individual circumstances and priorities. G. Client Assets Under Management As of December 31, 2022, ACG managed $152,531,820 of discretionary assets and $0 of non- discretionary assets. Item 5: Account Requirements and Types of Clients