A. Firm Information FWG Holdings, LLC d/b/a Fortress Wealth Group (“Fortress” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). Fortress is organized as a Limited Liability Company (“LLC”) under the laws of the State of Florida. Fortress was founded in March 2020 and became a registered investment advisor in May 2020. Fortress is owned by Ledford Holdings, LLC, which is wholly owned and operated by John E. Ledford (Chief Executive Officer and Chief Compliance Officer) and Capital Rock, LLC, which is wholly owned by Cole R. Linquist (President). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Fortress. B. Advisory Services Offered Fortress offers investment advisory services to: individuals, high net worth individuals, corporations, and charitable organizations (each referred to as a “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. The Advisor’s fiduciary commitment is further described in Fortress’ 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 Fortress provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management services. Fortress works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a diversified portfolio strategy. Fortress will then construct an investment allocation, consisting of exchange-traded funds (“ETFs”), mutual funds, or individual stocks to achieve the Client’s investment goals. The Advisor may also utilize bonds, options contracts, alternative investments, and/or real estate investment trusts (“REITs”) to meet the needs of its Clients. The Advisor may retain certain types of investments based on a Client’s legacy investments based on portfolio fit and/or tax considerations. Fortress’ investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Fortress will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Fortress evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Fortress may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Fortress may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Fortress may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Independent Manager - Fortress will recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Clients investment objectives and overall best interests. The Advisor 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 ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures). Page 5 When deemed to be in the Client’s best interest, the Advisor will introduce Clients to a non-purpose loan program made available through the recommended custodian. In such instances, the Client’s assets in their account[s] at the custodian will be utilized as collateral for a non-purpose loan. The recommendation of a non-purpose loan presents a conflict of interest as the Advisor will continue to receive investment advisory fees for managing the collateralized assets in the Client’s account[s]. Clients are not obligated to engage the Advisor for the non- purpose loan. For additional information related to the risks involved non-purpose loans and lines of credit, please see Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss. At no time will Fortress 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 the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Financial Planning Services Fortress typically provides financial planning services to Clients as part of its overall investment management services. Fortress may also provide financial planning services on a standalone basis pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, cash management, tax savings, insurance and asset protection, investment allocation, charitable giving and retirement planning. Clients may also engage the Advisor for estate planning services under a separate agreement. Tax Consulting – The Advisor, in coordination with an outsourced accountant and tax provider, also offers consulting services to support the Client’s tax savings and general tax management efforts. Please see Item 10 for additional details. A financial plan developed for the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Fortress may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For financial consulting engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Financial

planning 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, 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 implement the transaction through the Advisor. Financial Institution Consulting Services Fortress provides investment consulting services to brokerage customers (herein “Brokerage Customers”) of Mutual Securities, Inc. (herein “MSI”) who provide written consent requesting to receive the Advisor’s consulting services, pursuant to a written agreement with Fortress. Consulting services are strictly on products Clients have purchased through Mutual Securities, Inc. Please see Item 10 – Other Financial Industry Activities and Affiliations for additional details. Non-Purpose Loans Fortress may introduce certain Clients to various commercial banks for non-purpose loans that are sourced and collateralized through Fidelity or other custodians that offer such services (“Lending Program”). In such Page 6 instances, the Client’s assets in their account[s] at the Custodian will be utilized as collateral for a non-purpose loan. The recommendation of a Lending Program presents a conflict of interest as the Advisor will continue to receive investment advisory fees for managing the collateralized assets in the Client’s account[s], however, the Advisor will not receive an advisory fee on any loaned assets. Clients are not obligated to engage the Advisor for the Lending Program. For additional information related to the risks involved non-purpose loans and lines of credit, please see Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss. Investment Management Platform Fortress may recommend that certain Clients implement their investment portfolios through Betterment Institutional, a division of Betterment LLC (herein “Betterment Institutional” or the “Investment Platform”). Betterment Institutional is what is often termed a “robo-advisor”, an online wealth management service that provides automated, algorithm-based portfolio management advice. Robo-advisors use technology to deliver similar services as traditional advisors, but generally only offer portfolio management and do not get involved in a Client’s personal situation, such as taxes and retirement or estate planning. Fortress chose to affiliate with Betterment Institutional due to the Investment Platform’s customized portfolio allocations, automated rebalancing, and competitive fees. Fortress utilizes Betterment Institutional as a complement to its investment strategies as it provides cost effective implementation of the Advisor’s investment strategy[ies]. To establish accounts with Betterment Institutional, the Client will also enter into one or more agreements with Betterment that provides the authority for discretionary investment management by the Investment Platform. Fortress remains the Client’s primary advisor and relationship contact and will select or construct a portfolio of ETFs and/or cash equivalents from the universe of investments included on the Investment Platform. Fortress will have the discretionary authority to instruct Betterment Institutional with respect to portfolio construction, asset allocation and other investment decisions, subject to the limitations described herein. Betterment Institutional will implement the portfolio and be responsible for the discretionary trading of the ETFs in the Client’s portfolio, including the purchase and sale of investments and the automatic rebalancing back to targets. Betterment Institutional utilizes ETFs, representing various asset classes for the construction of investment portfolios. As discussed above, Fortress will work with each Client to select/construct a portfolio to meets the needs of the Client. The Client has limited ability to put restrictions on its accounts. The account[s] cannot contain investments that are not included in the Betterment Institutional universe of ETFs and cash equivalents. Betterment Institutional, under its discretionary authority, will automatically adjust and rebalance the Client’s accounts daily based on the drift tolerance established for the positions in the investment portfolio. The Advisor’s investment philosophy is long-term, but the Advisor may make such tactical overrides to take advantage of market pricing anomalies or strong market sectors. The Advisor does not actively trade in the Client’s account[s] and is also limited to a enter one allocation change per account per trading day through Betterment Institutional, the Client should be aware of these potential disadvantages. For its services, Betterment Institutional will charge an asset-based fee that is in addition to the Advisor’s fee. Betterment Institutional’s fee includes the securities transaction fees for all trades. The Advisor will only receive its investment advisory fees as detailed in Item 5.A. below and does not share in any fees earned by Betterment Institutional. The Client, prior to entering into an agreement with the Investment Platform, will be provided with the Investment Platform’s Form ADV Part 2A (or a brochure that makes the appropriate disclosures). C. Client Account Management Prior to engaging Fortress 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: Page 7
• Establishing an Investment Strategy – Fortress, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Fortress 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.
• Portfolio Construction – Fortress will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Fortress will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Fortress does not sponsor a wrap fee program in connection with investment management services, but does recommend that Clients establish accounts through Betterment Institutional, which delivers its investment management services through a wrap fee program structure. A wrap fee program is an investment program where investment management services and securities transaction costs are combined into a single combined fee. A complete description of Investment Platform and related fees, charges, when due and termination procedures are described in Betterment Institutional’s Disclosure Brochure and its Appendix 1 (“Betterment Wrap Fee Program Brochure”) which is provided to each Client prior to establishing an account with Betterment Institutional. E. Assets Under Management As of December 31, 2023, Fortress manages $294,685,885 in Client assets all of which are managed on a discretionary basis. Clients may request more current information at any time by contacting the Advisor.