A. Firm Information Octagon Financial Services, Inc., (referred to as "OFS," the "Advisor," "we," or "us") is a registered investment advisor with the U.S. Securities and Exchange Commission ("SEC"). OFS is subsidiary of Octagon, Inc., the global sports and entertainment representation and marketing subsidiary of the Interpublic Group of Companies, a publicly held company listed on the New York Stock Exchange (NYS:IPG). We are headquartered in McLean, VA. Since 1983, OFS and affiliated companies have been serving the financial and investment needs of entertainers and professional athletes at every level, from retired legends to active superstars, to the emerging talent of the future (herein referred to as "Clients"). The following companies own OFS, directly or indirectly: Direct Owner: Octagon, Inc. Indirect Owner: Interpublic Group of Companies, Inc. 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. Our fiduciary commitment is further described in our Code of Ethics. For more information regarding our Code of Ethics, please see Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. To meet the often complex financial and investment needs of our Clients, we have teamed with independent institutional investment managers, brokerage firms, insurance companies, and banks to make available a diverse range of financial and investment products and services, including financial planning and portfolio management services, brokerage and insurance products, and accounting and tax services. As you review this Disclosure Brochure, please note which products and services are provided by independent companies and which are provided by OFS. Your legal and contractual rights will differ in important ways depending on (i) the specific product or service, (ii) whether we or another company provides the product or service, (iii) the capacity in which we or another company is acting when providing the product or service, and (iv) the terms of your written agreement for the product or service. B. Advisory Services Offered OFS works with Clients through its "Full Service Program," consisting of the following types of services, customized to meet each Client's specific situation and needs:
• Financial Planning Services
• Portfolio Management Services
• Cash Management Services
• Tax Services We adjust the timing and scope of the Component Services to meet your individual circumstances. As Clients progress through their careers, their needs for particular financial or investment services will change. In the early stages of their careers, some Clients may not require significant Financial Planning Services or Cash Management Services, may not have sufficient assets to participate in certain investment programs, and may have less complex tax issues to consider. We strive to tailor the services to suit each Client's situation. Financial Planning Services At the beginning of our relationship with a new Client, we will ask about their personal and family circumstances, career plans, financial situation, investment goals and objectives, and tolerance for investment risk. Based on this information, we will work with the Client to identify specific planning services where we will focus our efforts during the initial year of our relationship. Over the course of your relationship with us, we will periodically review with you relevant aspects of the financial process. Generally, we consider the following issues as part of the Financial Planning Services: Cash Flow & Budgeting: Analysis of the Client's current income, expenses, taxes, savings, and investment history, and the potential effects of various investment choices, tax strategies, or other planning techniques towards improving the Client's current and future cash flows, assets, and tax liabilities. Portfolio Review: Analysis of the Client's current investment portfolio and allocation and weighting among investments of different asset classes or market sectors, with the goal of improving diversification, reducing volatility, minimizing taxes, or enhancing performance. Insurance Planning: Review of the Client's current life and disability insurance limits and coverage to identify circumstances where the Client may benefit from purchasing additional insurance or annuity products. Retirement Planning: Preparation of projections regarding the Client's estimated financial needs at certain ages in the future and amounts which should be added to the portfolio in order to meet future obligations and attain the Client's investment objectives. Caution Regarding Projections. When we develop projections for you, whether of estimated future income, expenses, inflation, tax liabilities, or other matters, we will rely on the information you provide and on certain assumptions about key economic, financial, and tax matters. While we believe the assumptions will be reasonable at the time made, there is no assurance that these assumptions will prove correct in the future; our assumptions may turn out to be wrong. To the extent the information you provide is inaccurate or incomplete, or our assumptions prove incorrect, our projections will likely not reflect your actual experience. Investment Management Services OFS provides discretionary investment management services for its Clients either directly or through allocation to unaffiliated Third-Party Managers participating in a Managed Account Program. For Clients with accounts managed through a Managed Account Program, the Third-Party managers will also require such authority. Based on information you provide about your individual and family circumstances, financial situation, securities portfolio, investment objectives (such as income, balanced growth and income, or maximum growth, for example), expected investment time horizon, tolerance for volatility or risk in your portfolio, and liquidity needs, we will work with you to develop an appropriate investment program. OFS primarily allocates Client assets among various Third-Party managers; we also may manage all or a portion a Client's account(s) internally. In addition to Third-party managers, OFS may construct Client portfolios utilizing mutual funds, exchange-traded funds ("ETFs"), individual equity securities and fixed income securities. OFS may employ other types of investments as necessary to achieve the Client's objectives. OFS may also recommend that certain accredited investors (as defined by Rule 501 of the Securities Act of 1933) invest in privately placed securities, which may include debt, equity or interests in pooled investment vehicles (e.g. hedge funds). Where applicable, OFS may also provide advice regarding legacy positions or other investments held in a Client's portfolio. Please refer to Item 8 - Methods Of Analysis, Strategies & Risk Of Loss for information about the investment strategies and types of investments we generally recommend to Clients. Managed Account Programs Most Clients allocate the largest portion of their investible assets to be managed by us through a Managed Account Program sponsored by one of the institutional management firms we recommend (each referred to as a "Sponsor"). We believe many Clients can benefit from the diverse investment products, strategies, portfolios, and institutional managers available through Managed Account Programs. We will assist the Client to select an appropriate Managed Account Program and to designate an initial investment strategy and model portfolio, and if appropriate, a third-party manager to manage their account. Currently, we have Clients participating in the Managed Account Programs sponsored by Dynasty Wealth Management, LLC ("DWM"), a subsidiary of Dynasty Financial Partners, LLC ("DFP") (collectively "Dynasty"), Envestnet and other investment platforms. The vast majority of our Clients are using Managed Account Programs through Dynasty. Please see Item 10 - Other Financial Industry Activities & Affiliations for additional disclosures. Dynasty provides an integrated platform service provider of business resources to Registered Investment Advisors ("RIA"). Dynasty provides access to trading technology, reporting, custody, and investments through an open architecture system. Dynasty selects, builds, and monitors investment portfolios in order to cater to various levels of investor sophistication. OFS uses Dynasty's Separately Managed Accounts ("SMA") and Unified Managed Accounts ("UMA") to create custom portfolios for a range of Client needs. Dynasty's SMA/UMA solutions include:
• Institutional quality research
• Integrated flexible performance reporting options
• A single technology platform to manage trading, research and reporting Accounts participating in a Managed Account Program will typically pay a quarterly Program Fee (calculated as a percentage of assets) that include (i) the Program Sponsor's services in researching and adjusting the model portfolios and strategies, screening available investment options, and performing initial due diligence and on-going monitoring of Third-Party Managers, (ii) the day-to-day investment management services of Third-Party Managers, if any, selected for the account, and (iii) the broker-dealer's brokerage and custody services. Clients should understand that Managed Account

Programs offered are typically "wrap fee" programs. Clients who are not familiar with wrap fee programs should take care to understand the special characteristics of these programs. Please refer to Item 4.D for further information about wrap fee programs. For Clients that we recommend a Managed Account Program, we will explain the objectives of the program and the wrap fee features of the program, the characteristics and risk profiles of the available investment portfolios, the management styles and strategies of the Third-Party Managers, and the potential benefits, costs, risks, and requirements of the program. The Client will also receive the Managed Account Program's Disclosure Brochure describing the Program Sponsor's methodologies for developing investment portfolios and strategies, and selecting Third-Party Managers. Clients who choose to participate in a Managed Account Program must sign separate agreements with the Program Sponsor and with a brokerage firm that will hold the account's assets and provide brokerage services. We will assist the Client to identify a suitable model portfolio or strategy, and if applicable to the Managed Account Program, an appropriate Third-Party Manager to provide day-to- day management of the Client's Program account[s]. Additionally, we can use DWM’s customized portfolio solutions, which are offered to investment advisers through its Outsourced Chief Investment Officer Program (the “OCIO Program”). Through the OCIO Program, DWM provides discretionary investment management services through its Investment Committee, in concert with research furnished by Envestnet PMC and iCapital Securities, LLC. OCIO strategies may entail active or passive management strategies with the goal of creating portfolios focused on asset protection and growth of capital. Passive portfolios typically employ inexpensive, passive ETFs, while active portfolios typically employ active third-party investment strategies, as appropriate. Portfolios are constructed, implemented and monitored through a due diligence program that functions at the submanager and product level. Cash Management Services Typically, we will recommend a Cash Management Account for a portion of Client assets outside of a Managed Account Program. We offer Cash Management Services through City National Bank, an independent bank based in Los Angeles, California. Clients participating in this service will arrange for checks, transfers, or other sources of income to be deposited to an account held in their name at City National Bank. Client vendor invoices or bills will be forwarded to us, and we will direct timely payments on the Client's behalf. Clients will authorize certain OFS Supervised Persons to disburse funds from their account(s). Cash Management Clients will receive monthly statements from us and also directly from City National Bank. Clients are encouraged to compare our statements with the statements from City National Bank, and to alert us immediately of any discrepancies. Tax Services Many of our Clients have complex tax situations and will benefit from having their U.S. federal and state income tax returns prepared by one of our Supervised Persons, or where appropriate, an independent tax firm we retain. Clients will also receive, upon request, tax projections prepared by us or another firm. Returns and projections will be prepared based on information provided by the Client or sources the Client identifies. Neither we nor any independent firm we engage will be responsible for verifying, authenticating, or auditing any information from the Client or other sources, nor will we (or any independent firm) be responsible for identifying or disclosing errors, fraud, or other illegal acts. Clients should be aware that we will usually rely on the advice and services of independent firms in providing the Tax Services. While we believe these firms are qualified and capable of providing these services, OFS will not be responsible for errors, penalties, interests, or other costs as a result of errors by a firm we retain for the Tax Services. Other Advisory Services A Client may ask us to provide advice or consulting services outside the scope of our Full Service Program. For example, a Client may ask for advice regarding a specific issue related to estate planning or tax planning strategies. We will negotiate the terms of these limited scope services, on a case-by- case basis. IRA Rollover Recommendations For purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. 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. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. C. Tailored Services & Client-Imposed Restrictions We tailor our investment advice and services to the financial situation, investment objectives, investment time horizon, risk tolerance, and liquidity needs of each account, according to information provided by the Client through written questionnaires, telephone or in-person discussions, and periodic account reviews and meetings. We permit Clients to impose reasonable restrictions on the types of securities we recommend or purchase for their account, and permit Clients to change these restrictions by written notice to us. However, Clients should be aware that the terms of Managed Account Programs may restrict the Client's ability to impose restrictions on account investments. These restrictions will be described in the disclosure document or Client's Managed Account Agreement. Our investment strategies and advice may vary depending upon each client's specific financial situation, and as such we may provide investment advice to different clients regarding the same security or investment. D. Information About Wrap Fee Programs We are required to provide information about wrap fee programs for which we provide portfolio management services. A wrap fee program combines portfolio management services and transaction fees into a single advisory fee. Although we recommend various wrap fee programs to our Clients, we do not provide "portfolio management services" for those programs. We assist our Clients in choosing a wrap fee program, model investment portfolio or strategy, and for some Programs, an appropriate Third-Party Manager to meet their needs, and then monitor account performance and exercise discretion to change or replace the account's model, strategy, or Third-Party Manager, as necessary. Special Considerations Regarding Wrap Fee Programs. Clients participating in wrap fee programs should consider that wrap fee arrangements are not suitable for every account. The benefits of the arrangement depend on a number of factors, particularly the amount of the wrap fee, the number and frequency of account trades, and the types of securities the account will trade. A wrap fee arrangement is likely to be more beneficial for accounts that expect relatively frequent trading, such as where a Third-Party Manager intends to pursue an active trading strategy. In that case, a wrap fee arrangement that combines the costs of investment advice and brokerage services into a single fee may cost less than a traditional managed account arrangement where the account pays brokerage commissions separate from (and in addition to) fees for investment advice. Conversely, an account that expects a relatively small number of trades each year would likely find a wrap fee arrangement to be more costly than paying the separate costs of brokerage commissions and fees for investment advice. Clients are cautioned to review the information in the disclosure brochure for wrap programs they are considering to understand the costs and factors they should consider when deciding whether to participate in (or to continue to participate in) the programs. Clients should also consider that lower cost programs for similar advisory, brokerage, and custody services may be available through programs available through other advisers or broker-dealers, either through a wrap fee or on a separate cost basis. E. Assets Under Management As of December 31, 2023, OFS managed Client assets of $1,196,492,649 on a discretionary basis, and did not manage any assets on a non-discretionary basis.