Ferguson Shapiro LLC (“Ferguson Shapiro”) was established in 2018 and applied for registration as an Investment Adviser in 2018. Kevin Ferguson is the principal owner of Ferguson Shapiro. Ferguson Shapiro may manage assets on a discretionary or non-discretionary basis. In addition to the programs described in this Brochure, Ferguson Shapiro also offers a wrap fee program, which is disclosed in separate Wrap Fee Brochure. In a wrap fee program, clients are charged an all- inclusive wrap fee on Program Assets that covers advisory, execution, custodial and reporting services on Eligible Assets. A portion of these fees will be paid to Ferguson Shapiro for advisory services. In a non-wrap fee program, Ferguson Shapiro’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Our approach starts with a review of our client’s financial story, which includes a review of their financial assets, liabilities and cash flows. Based on that review, we’ll work with our clients to create a blueprint for the future, considering savings goals, any required rate of return and possible future variations in cash flow. After reviewing the foundational elements, we will move to portfolio constructions, considering all existing assets considering net capitalization, credit risk, and the optimal combination of assets. Ferguson Shapiro provides advisory services, giving continuous advice based on the client’s individual needs. Through personal discussions in which goals and objectives based upon the client’s personal objectives are established, the firm will develop a personal investment policy based upon an investment objective questionnaire and manage the portfolio according to the criteria. Each client has the ability to impose reasonable restrictions on the management of his/her account, including the designation of particular securities or types of securities that should not be purchased for the account, or that should be sold if held in the account. If a client’s instructions are unreasonable or an Investment Advisor Representative believes that the instructions are inappropriate for the client, Ferguson Shapiro will notify the client that, unless the instructions are modified, it will cancel the instructions in the client’s account. A client will not be able to provide instructions that prohibit or restrict the Investment Adviser of an open-end or closed-end mutual fund or ETF with respect to the purchase or sale of specific securities or types of securities within the fund. Enhanced Portfolio Management Our advisors may employ options strategies to hedge or gain additional exposure to a particular stock, asset class or sector. This investment strategy encompasses active trading in concentrated portfolios. Participant Account Management (Discretionary) We use a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. Third Party Money Managers Ferguson Shapiro has also entered into additional agreements with various non-affiliated investment advisors (“third-party money managers”) to offer asset allocation and asset management services to Ferguson Shapiro advisory clients. Ferguson Shapiro will assist the client in formulating a strategic investment portfolio based on the client's investment objectives. Once formulated, a suitable third-party money manager is selected to implement and continually manage the portfolio. In preparing the portfolio, Ferguson Shapiro will set restrictions or limitations on the management of the account and explain to the client the continual account activity transacted by the third-party money manager. Also, Ferguson Shapiro will periodically review the current and historical performance record of each third- party money manager. The relationship of Ferguson Shapiro with these third-party money managers will

be clearly communicated to all clients in the third-party money manager’s Client Services Agreement and/or other similar documentation. Each third-party money manager is required to provide Ferguson Shapiro with a disclosure document statement, typically a copy of their Form ADV 2A. The third-party money manager’s Form ADV 2A will be provided to the client by Ferguson Shapiro. Financial Planning Ferguson Shapiro offers advice in the form of a Financial Plan. Clients will receive a written financial plan, providing the client with a detailed financial plan designed to achieve their stated financial goals and objectives. In general, the plan will address any or all of the following:
• Personal: Family records, budgeting, personal liability, estate information and financial goals
• Tax and Cash Flow: Income tax spending analysis and planning for past and future years.
• Death and Disability: Cash needs at death, income needs of surviving dependents, estate planning
• Retirement: Strategies and investment plans to help client achieve their retirement goals
• Investments: Analysis of investment alternatives and their effect on a client’s portfolio. Information on clients will be gathered by in-depth personal interviews and review of personal financial information. Gathering data concerning current financial status, future requirements, risk appetite and goals is essential. Based upon this thorough review, a written plan is prepared for the client providing the client with a detailed financial plan designed to achieve their stated financial goals and objectives. It is recommended that the client review this plan with tax accountants, attorneys and other professional service providers. Ferguson Shapiro may work with other professionals such as attorneys, Certified Public Accountants, trust officers, Mortgage Analysts etc., to offer financial and estate planning advice. Ferguson Shapiro specializes in the areas of investment, financial, estate, risk management, retirement, and business continuation planning. The financial management process begins with an in-depth evaluation of the client’s current financial goals and objectives. Once we have established the overall objectives, Advisor will focus on the client’s specific goals. Clients are not under any obligation to engage Ferguson Shapiro when considering implementation of advisory recommendations. The implementation of any or all recommendations is solely at the discretion of the client and can be implemented through another RIA. In addition to the aforementioned services, Ferguson Shapiro offers investment data storage and periodic comprehensive reporting services which can incorporate all of the client’s investment assets, including those investment assets that are not part of the assets managed by Ferguson Shapiro (the “Excluded Assets”). Should the client utilize these reporting services, the client acknowledges and understands that with respect to the Excluded Assets, Ferguson Shapiro’s service is limited to reporting and data storage services only and does not include investment management, review, or monitoring services, nor investment recommendations or advice. As such, Ferguson Shapiro will not be responsible for the investment performance of the Excluded Assets. If the client requests Ferguson Shapiro to provide investment management services with respect to the Excluded Assets, the client may engage Ferguson Shapiro to do so for a separate and additional fee. ERISA and Individual Retirement Accounts Disclosure 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. As of December 31, 2023, Ferguson Shapiro had $326,436,615 in discretionary assets under management and $357,441 in non-discretionary assets under management.