A. Firm Information PFG Investments, LLC d/b/a Practice Financial Group (“PFG Investments'' or the “Advisor” and also referred to as “we”) is a registered investment advisor located in the State of Oregon. The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of Oregon. PFG Investments was founded in May 2017 and is owned by Williams Hold Co, LLC, Millar Six, LLC and Rogers Four, LLC. PFG Investments is operated by Nathan Williams (Chief Executive Officer), Chad Rogers (Chief Operating Officer), and Spencer Kenley (Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by PFG Investments.
B. Advisory Services Offered PFG Investments is a wealth management firm providing financial planning, investment management, and insurance planning and placement services to individuals, high net worth individuals, families, trusts, estates, and retirement plans (each referred to as a “Client”). Accounting services are also provided through its affiliate, Practice Financial Group LLC (“Practice Financial Group”). PFG Investments offers these services on a fee basis, which may include a fixed fee, hourly fee, fees based upon the level of assets managed, or, in the case of an insurance product only, a commission. Each service is preceded by a written and signed agreement that sets forth the terms and conditions under which PFG Investments will deliver these services to our Client.
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. PFG Investment’s fiduciary commitment is further described in the Advisor’s Code of Ethics.
For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.
Investment Management Services PFG Investments helps our Clients to establish investment objectives that are designed to increase the likelihood of achieving their financial goals. We follow a four-step process to define and monitor this investment objective.
STEP 1: Understanding Our Client To begin, we always start by developing a Client-specific financial profile. This profile consists of: 1. Their goals – Generally, this is obtained through our personal financial planning service. If not, we will collect baseline information on the purpose and timing of the money being invested through PFG Investments.
2. Their financial capacity for risk – We collect adequate information on their financial condition and, coupled with their financial goals, determine what level of risk is necessary in order for our Client to meet their established goals.
3. Their emotional capacity for risk – We analyze their emotional and psychological tolerance for market and portfolio volatility.
This information is gathered through various questionnaires, including a questionnaire on their financial goals, circumstances, and feelings toward investment risk. Throughout this process we assess their level of understanding of financial and investment concepts, such as market returns, different types of investment products, market volatility, and inflation. Collectively, this information provides the context for us to define an appropriate investment objective for the assets we are engaged to manage for our Client.
STEP 2: Develop an Investment Policy Statement Page 4 of 27 Once sufficient information about the Client is gathered for purposes of developing an investment objective, PFG Investments formalizes a plan to deploy the investments in a manner consistent with that objective. This plan includes: 1. A target allocation between equity investments, fixed income investment, and cash. This is their strategic asset allocation.
2. A target allocation between various asset classes within both the equity and fixed income portions of the investment portfolio. This is their tactical allocation.
3. Identification of the investment managers used within each asset class.
4. A review of existing investment holdings, their embedded taxes, any restrictions, and any redemptions fees.
5. The development of specific steps to manage concentrated positions, illiquid investments, stock options, and restricted stock.
6. Timing guidelines for moving their investment assets into the market if they are current in cash.
7. The preparation of a cash distribution plan (if our Client is relying on investment asset for spending needs) 8. The preparation of rebalancing guidelines.
This information, collectively, is assembled into a document we title, as a matter of best practices, the Investment Policy Statement (“IPS”). The IPS, along with other potential analyses we provide, may include certain investment projections. These projections are intended strictly for the use of PFG Investments, LLC. We do not provide any level of assurance of these projections. We believe that markets and investment performance cannot be predicted in the short run and may not repeat itself in the long run. Although we believe capital markets will continue to offer returns over time to capital investors, we express no form of assurance for their investment assets. In other words, past performance is not a predictor of future performance. However, we strongly believe that our portfolios are structured to offer our Client a share in broad market returns according to their exposure to those markets. That level of exposure is Client specific and is documented in our investment policy statement.
STEP 3: Execute the Investment Policy Statement After the IPS is complete, we execute the policies instructions, on a discretionary or non-discretionary basis, by selling all securities that are not consistent with our target portfolio and use the proceeds to purchase those securities that are. Timing of this transition may be phased according to security restrictions, Client preferences, and tax constraints. Once executed, we notify our Client and provide a report illustrating that the investment portfolio is consistent with our target portfolio design.
STEP 4: Monitor the Investment Portfolio PFG Investments does not attempt to time the market cycles (see “Methods of Analysis” section). Instead, we design a portfolio that maintains its current strategic allocation and adjusts for two reasons only: 1. Shift the portfolio back to its target allocation after market changes have altered the portfolio’s allocation.
2. Reconfigure the portfolio to a new strategic allocation that is motivated by changes to their circumstances. Such changes will be documented in an updated IPS.
This method of monitoring the investment portfolio produces greater levels of discipline into our investment process. It removes many of the behaviorally motivated investment decisions that so often erode long-term investment returns. However, we will not at any time restrict our Client from making the investment decision that our Client ultimately wishes to make. Any decisions made by our Client that are inconsistent with our recommendations will be documented and saved in our archives.
Page 5 of 27 PFG Investments personnel will meet with our Client periodically to review the portfolio holdings and performance. These meetings may be scheduled annually, semi-annually, or if necessary, quarterly. If our Client obtained a personal financial plan, from time to time we will review the investment portfolio in conjunction with the financial plan. Doing so allows us to compare the portfolio returns to those projected in the financial plan and assists in our ongoing financial planning reviews and updates.
Lastly, our Client will receive periodic reports, electronically or in paper form, on the portfolio holdings, gains, losses, fees, trading costs, and investment performance. We will also generally coordinate with their tax accountant to reduce taxes where possible and permitted.
Retirement Accounts – When deemed to be in the Client’s best interest, the Advisor will recommend that a Client take a distribution from an ERISA sponsored plan

or to roll over the assets to an Individual Retirement Accounts (“IRAs”), or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). In such instances, the Advisor will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Prior to rendering investment advisory services, PFG Investments will ascertain, in conjunction with the Client, the Client’s financial situation, risk tolerance, and investment objective[s]. At no time will PFG Investments accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the Client investment advisory agreement. For additional information, please see Item 12 – Brokerage Practices.
Use of Independent Managers PFG Investments will recommend that a Client utilize Buckingham Strategic (herein “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. Clients are required to enter into an investment management agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide its related services. PFG Investments will perform initial and ongoing oversight and due diligence over the Independent Manager to ensure the strategy remains aligned with its Clients investment objectives and overall best interests. PFG Investments will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client will be provided with the Independent Manager’s Form ADV2A (or a brochure that makes the appropriate disclosures) prior to entering into an agreement with the Independent Manager[s].
Personal and Business Financial Planning Services Generally, PFG Investments initiates its services for our Client by completing a high-level, but comprehensive, review of their personal and business financial conditions and goals. We identify this process, and the resulting written plan, as our Financial Planning service. Once complete, the delivered plan provides the context for our other wealth management services. This process begins by establishing and defining the terms of the relationship between PFG Investments and our Client. Once the relationship is defined and agreed upon, PFG Investments will collect and assemble relevant financial planning documents and goal information, which may include assets, liabilities, income, expenses, insurance policies, estate documentation and other appropriate information. PFG Investments will then analyze the information in order to offer a written set of recommendations that can, if implemented by our Client, increase the likelihood of achieving their financial goals. Our Client will have the option to accept, reject, or modify the information.
PFG Investments offers a specific set of planning services for dental and medical professionals. These services extend the personal financial planning process to include a review of certain elements of their business. The purpose of this extended analysis is to relate the cash flows of the business to their personal financial projections Page 6 of 27 and goals. There is an additional fee for this service that is added to the standard financial planning fee, as described in Item 5 below.
The usefulness of the personal financial plan will depend largely on the amount and accuracy of information provided to PFG Investments. Because the projections used in the plan, and the accompanying results, are calculated over many years, small changes can create large differences in future results. Consequently, the plan will not convey any form of assurance on the achievability of those projections or reasonableness of the underlying results. In addition, it does not provide any legal advice. Before making decisions with legal ramifications, our Client should consult appropriate professionals for advice that is specific to their situation.
Any investment recommendations developed as a result of the personal financial plan should be implemented by a licensed investment professional. PFG Investments does not take any responsibility for the outcome of any specific investment strategy recommended by other advisors. If our Client wishes to engage PFG Investments to implement the investment recommendations, PFG Investments may offer to provide such services under a separate agreement.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor would pose a conflict, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to effect the transaction through the Advisor.
Retirement Plan Advisory Services PFG Investments provides 3(21) retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: ●Vendor Analysis ●Plan Participant Enrollment and Education Tracking ●Investment Policy Statement (“IPS”) Design and Monitoring ●Performance Reporting ●Ongoing Investment Recommendation and Assistance These services are provided by PFG Investments serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of PFG Investments’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management Prior to engaging PFG Investments to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: ●Establishing an Investment Strategy – PFG Investments, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
●Asset Allocation – PFG Investments will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
Page 7 of 27 ●Portfolio Construction – PFG Investments will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
●Investment Management and Supervision – PFG Investments will provide investment management and ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs PFG Investments does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by PFG Investments.
E. Assets Under Management PFG Investments manages the following amount of discretionary and non-discretionary client assets calculated as of December 31, 2023: Discretionary:$4,155,391 Non-Discretionary:$291,263,857 Total:$295,419,248 Page 8 of 27