A. JMG Financial Group, Ltd. (the “Registrant”) is a corporation formed on March 20, 1984 in the State of Delaware. The Registrant became registered as an Investment Adviser Firm in February 1985. Anthony D. Cecchini is the Registrant’s Chief Executive Officer. B. As discussed below, the Registrant offers to its clients (individuals, trusts, pension and profit sharing plans, business entities, charitable organizations, etc.) investment advisory services, and, to the extent specifically requested by a client, financial advisory and related consulting services, investment consulting services, and retirement consulting services. INVESTMENT ADVISORY SERVICES The client can determine to engage the Registrant to provide discretionary investment advisory services on a fee-only basis. The Registrant’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under the Registrant’s management, is negotiable, and varies upon the scope of and type of services to be provided as follows: Non-Sub-Advised and Sub-Advised Portfolios (exclusive of sub-advisors fees)* Market Value of Portfolio % of Assets First $2,000,000 1.000% Next $2,000,000 0.750% Next $2,000,000 0.600% Next $14,000,000 0.500% Over $20,000,000 0.350% *PLEASE NOTE: Generally, the above fee schedule is for new clients that engage Registrant subsequent to December 31, 2017 or for existing financial advisory clients that have not previously engaged Registrant to provide investment advisory services. The fee schedule does not apply to existing investment advisory clients of Registrant (see Grandfathered Fee Schedules disclosure below), nor does the fee schedule apply to Registrant’s other advisory services including financial advisory and consulting services, or services provided under the Schwab Advisor Network® fee schedule documented below. Rather, as discussed below, such services are available on a stand-alone, separate fee basis, per the terms and conditions of a separate written agreement. In addition, many clients have and will continue to be grandfathered under fee schedules that preceded the client’s engagement of Registrant. Registrant has grown, and expects to continue to grow, by acquisition of other advisory firms. The acquired firms could have fee schedules or other fee arrangements with its clients that differ from the above fee schedule. Upon acquisition, an acquired firm will generally maintain its pre-existing fee schedule subsequent to Registrant’s acquisition. As a result, Registrant’s clients could be subject to various different fee schedules and/or arrangements, including those that may be higher or lower than Registrant’s fee schedule set forth above. Annual advisory fees applicable to a client engagement are detailed in the Advisory Agreement executed between Registrant and the client. Clients engaged under grandfathered fee schedules are advised to consult their Advisory Agreement, which may be provided on request, for more information on the fees applicable to their account. Non-Sub-Advised portfolios (direct management by Registrant), Sub-Advised Fixed Income portfolios, and Sub-Advised Equity portfolios are aggregated when applying the fee percentages described above. A separate sub-advisor fee, in addition to Registrant’s fee, will be charged for Sub-Advised Fixed Income portfolios and Sub-Advised Equity portfolios. Unless otherwise specifically indicated to the contrary, the annual fee charged by the designated sub-advisor (generally ranging between 0.090% and 0.750% depending upon the type of management services required and the market value of the assets to be managed), is exclusive of, and in addition to, Registrant’s investment advisory fee. Alternative Investments (exclusive of charges imposed by the alternative investment, for example management fees) Market Value of Portfolio % of Assets Less than $10,000,000 1.000% At least $10,000,000 0.900% Although Registrant requires a minimum account size of $1,000,000 when Registrant is providing only investment advisory services to a client, Registrant may accept an amount less than the minimum. Registrant, in its sole discretion, may reduce its account minimum. Registrant may group related client accounts for the purpose of achieving the minimum account size requirement. Registrant’s investment advisory fee is negotiable, therefore, Registrant may charge a lesser investment advisory fee based upon certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, negotiations with client, etc.). Grandfathered Fee Schedules. Registrant’s investment advisory fee schedule may be amended from time to time. Many clients have been, and will continue to be, grandfathered under fee schedules that preceded an amended fee schedule. In addition, many clients have and will continue to be grandfathered under fee schedules that preceded the client’s engagement of Registrant. Registrant has grown, and expects to continue to grow, by acquisition of other advisory firms. The acquired firms could have fee schedules or other fee arrangements with its clients that differ from the fee schedules set forth in Item 4 and Item 5. Upon acquisition, an acquired firm will generally maintain its pre-existing fee schedule subsequent to Registrant’s acquisition. As a result, Registrant’s clients could be subject to different investment advisory fee schedules than those set forth in Item 4 and Item 5, including those that may be higher or lower than Registrant’s fee schedule. Annual advisory fees applicable to a client engagement are detailed in the Advisory Agreement executed between Registrant and the client. Clients engaged under grandfathered fee schedules are advised to consult their Advisory Agreement, which may be provided on request, for more information on the fees applicable to their account. ANY QUESTIONS: Registrant’s Chief Compliance Officer, Jeffrey G. Dohner, remains available to address any questions regarding Registrant’s service offerings and fees. FINANCIAL ADVISORY AND CONSULTING SERVICES (STAND-ALONE) To the extent specifically requested by a client, the Registrant may determine to provide financial advisory and related consulting services (including investment consulting services, retirement planning, cash flow planning, estate consulting services (not involving legal or accounting advice/services), and budget analysis and review, etc.) on a stand-alone separate fee basis. Registrant’s financial advisory and consulting fees are negotiable, but generally range from $10,000 to $50,000 on a fixed fee basis, depending upon the level and scope of the service(s) required and the professional(s) rendering the service(s). In very limited instances and/or unique circumstances (to be determined in the sole discretion of the Registrant), Registrant’s financial advisory and consulting fees may be based on an hourly rate, ranging from $100 to $600, depending on the level and scope of the service(s) required and the professional(s) rendering the service(s). Long term clients of Registrant may continue to be grandfathered under financial advisory fee schedules which fall outside the general fee range described above. Prior to engaging the Registrant to provide financial advisory or consulting services, clients are generally required to enter into an Advisory Agreement with Registrant setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to Registrant commencing services. If requested by the client, Registrant may recommend the services of other professionals for implementation purposes. Certain professionals recommended by Registrant are clients of the Registrant. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Registrant. Please Note: If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Please Also Note: It remains the client’s responsibility to promptly notify the Registrant, in writing, if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Registrant’s previous recommendations and/or services. Combined Investment Advisory and Financial Advisory Services Generally, this fee arrangement is unique to long term clients of Registrant that continue to be grandfathered. Under this fee arrangement, the client can determine to engage the Registrant to provide discretionary investment advisory services and financial advisory and consulting services (including investment consulting services, retirement planning, cash flow planning, estate consulting services (not involving legal or accounting advice/services), and budget analysis and review, etc.) and pay a combined fee for both services. The Registrant’s annual combined investment advisory and financial advisory fee is based upon a percentage (%) of the market value of the assets set forth on the exhibit to the Advisory Agreement and generally ranges between 0.30% and 1.00%. Alternatively, Registrant’s annual combined investment advisory and financial advisory fee may be a fixed fee. The Registrant’s annual combined investment advisory and financial advisory fee is negotiable and generally subject to a minimum annual fee of $20,000. To the extent assets are directed to a sub-advisor, a separate fee (as described below), in addition to the combined fee, will be charged to the client for the services of the sub-advisor. In addition, many clients have and will continue to be grandfathered under fee schedules that preceded the client’s engagement of Registrant. Registrant has grown, and expects to continue to grow, by acquisition of other advisory firms. The acquired firms could have fee schedules or other fee arrangements with its clients that differ from the fee schedules set forth in Item 4 and Item 5. Upon acquisition, an acquired firm will generally maintain its pre-existing fee schedule subsequent to Registrant’s acquisition. As a result, Registrant’s clients could be subject to various different fee schedules and/or arrangements, including, but not limited to, a combined investment advisory and financial advisory fee based upon a percentage (%) of the market value of the assets placed under Registrant’s management, which may be higher or lower than Registrant’s fee schedules set forth in the Advisory Agreement executed between Registrant and the client. Clients engaged under grandfathered fee schedules are advised to consult their Advisory Agreement, which may be provided on request, for more information on the fees applicable to their account. RETIREMENT CONSULTING SERVICES The Registrant also provides non-discretionary pension consulting services, pursuant to which it assists plan sponsors of trustee and participant directed retirement plans with the selection and/or monitoring of investment alternatives (generally open-end mutual funds). Plan participants shall choose the investments for their individual retirement accounts. In addition, to the extent requested by the plan sponsor, the Registrant may also provide participant education designed to assist participants in identifying the appropriate investment strategy for their retirement plan accounts. The terms and conditions of the engagement shall generally be set forth in the Investment Consulting Services Agreement between the Registrant and the plan sponsor. The Registrant’s annual consulting fixed fee arrangements are negotiable depending on the time and complexity of the engagement. The Registrant’s annual consulting fees based upon a percentage of the market value of the plan’s assets are negotiable and generally range between 0.35% and 1.00% of the market value of the plan’s assets. Generally, Registrant’s annual consulting fee shall be calculated and paid quarterly, in advance. Consulting fees based on a percentage of the market value of the plan’s assets are based upon the market value of the plan’s assets on the last day of the previous quarter. SCHWAB ADVISOR NETWORK® (Combined Services) Registrant receives client referrals from Charles Schwab & Co., Inc. (“Schwab”) through Registrant’s participation in the Schwab Advisor Network® (“the Service”). See a description of the Service in Item 12 and Item 14 below. Registrant provides clients referred through the Service discretionary investment advisory services and financial advisory and consulting services (including investment consulting services, retirement planning, cash flow planning, estate consulting services (not involving legal or accounting advice/services), and budget analysis and review, etc.) for a combined fee for both services. The Registrant’s annual combined investment advisory and financial advisory fee is based upon a percentage (%) of the market value of the assets placed under Registrant’s management, is negotiable, and varies upon the scope of and type of services to be provided as follows: Non-Sub-Advised and Sub-Advised Portfolios (exclusive of sub-advisors fees) Market Value of Portfolio % of Assets First $4,000,000 1.000% Next $2,000,000 0.750% Next $14,000,000 0.500% Over $20,000,000 0.350% Non-Sub-Advised portfolios (direct management by Registrant), Sub-Advised Fixed Income portfolios, and Sub-Advised Equity portfolios are aggregated when applying the fee percentages described above. To the extent assets are directed to a sub-advisor, a separate fee (as described below), in addition to the combined fee, will be charged to the client for the services of the sub- advisor. Alternative Investments (exclusive of charges imposed by the alternative investment, for example management fees) Market Value of Portfolio % of Assets Less than $10,000,000 1.000% At least $10,000,000 0.900% Registrant requires a minimum account size of $500,000 for clients referred through Registrant’s participation in the Service. For clients referred through the Service with an account size greater than $4 million, generally, Registrant will provide income tax preparation services for no additional fee. Registrant may charge an additional fee for providing income tax preparation services to clients with an account size less than $4 million. Commencement of Registrant Compensation. Registrant’s financial advisory and consulting services shall commence on the date that the client and the Registrant have executed an Advisory Agreement. The Registrant’s annual advisory fee shall commence on the date that Schwab has transitioned the client’s investment assets to an account(s) to be managed by the Registrant, regardless of the date on which

the Registrant and the client confirm the investment objective(s) for the account(s), which will generally be a date subsequent to the execution of the Advisory Agreement. TAX CONSULTING AND PREPARATION SERVICES To the extent specifically requested by a client, the Registrant may determine to provide its clients with tax consulting and preparation services, on either a mutually agreed upon fixed fee or hourly rate basis. MISCELLANEOUS Financial Advisory and Related Consulting - Implementation. To the extent requested by the client, the Registrant may determine to provide financial advisory and related consulting services (including investment consulting services, retirement planning, cash flow planning, estate consulting services (not involving legal or accounting advice/services), and budget analysis and review, etc.). Neither the Registrant, nor any of its representatives, serves as an attorney, accountant, or licensed insurance agent, and no portion of the Registrant’s services should be construed as same. To the extent requested by a client, the Registrant may recommend the services of other professionals for certain implementation purposes (i.e., attorneys, accountants, licensed insurance agents, mortgage brokers, etc.), including professionals that are clients of the Registrant as discussed below. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Registrant. Please Note: If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Please Also Note: It remains the client’s responsibility to promptly notify the Registrant, in writing, if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Registrant’s previous recommendations and/or services. Please Note: Non-Discretionary Service. Registrant primarily provides investment management services on a discretionary basis. In very limited instances, Registrant may provide these same investment services on a non-discretionary basis. Any such client for whom the Registrant agrees to provide non-discretionary investment management services must be willing to accept that the Registrant cannot effect any account transactions without obtaining prior oral consent to any such transaction(s) from the client. Thus, in the event of a market correction during which the client is unavailable, the Registrant will be unable to effect any account transactions (as it would for its discretionary clients) without first obtaining the client’s oral consent. Sub-Advisory Arrangements. The Registrant may engage sub-advisors for the purpose of assisting the Registrant with the management of its client accounts. The sub-advisor(s) shall have discretionary authority for the day-to-day management of the assets that are allocated to it by the Registrant. The sub-advisor shall continue in such capacity until such arrangement is terminated or modified by the Registrant. Unless otherwise specifically indicated to the contrary, the annual fee charged by the designated sub-advisor (generally ranging between 0.090% and 0.750% depending upon the type of management services required and the market value of the assets to be managed), is exclusive of, and in addition to, Registrant’s investment advisory fee. Factors which Registrant shall consider in engaging sub-advisors include the client’s stated investment objective(s), and the sub- advisor’s management style, performance, reputation, financial strength, reporting, pricing, and research. The Registrant’s Chief Compliance Officer, Jeffrey G. Dohner, remains available to address any questions concerning the Registrant’s sub-advisory arrangements. Pontera Solutions Inc. (“Pontera”). Registrant engaged Pontera, a third party platform provider, to facilitate the management of held away assets such as defined contribution plan participant accounts, with discretion. Those clients who choose to engage Registrant to service their held away accounts will be provided a link to connect their outside accounts to the platform. Once the client’s account is connected to the platform, Registrant will review the client's current account allocation. Registrant will rebalance the connected outside accounts consistent with the client’s investment goals and risk tolerance. To facilitate use of the Pontera platform, the client securely logs into the Pontera site and entitles Registrant to manage the assets. Pontera charges Registrant 0.30% for each managed account. Clients do not pay any additional fee to Pontera or to Registrant in connection with their platform participation; however, Registrant will charge an investment advisory fee for the management of held away assets. Registrant is not affiliated with Pontera in any way and receives no compensation from them for using their platform. Private Investment Funds. Registrant may provide investment advice regarding private investment funds. The Registrant’s role relative to the private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become a private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of Registrant calculating its investment advisory fee. Registrant’s clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). Please Note: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may maintain, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. Please Also Note: Valuation. In the event that the Registrant references private investment funds owned by the client on any supplemental account reports prepared by the Registrant, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. If no subsequent valuation post-purchase is provided by the fund sponsor, then the valuation shall reflect the initial purchase price (or a value as of a previous date). If the valuation reflects the initial purchase price (or a value as of a previous date), the current value(s) (to the extent ascertainable) could be significantly more or less than the original purchase price. The client’s advisory fee shall be based upon reflected fund value(s). Recommended Professionals. Registrant may recommend the services of other professionals for certain implementation purposes (i.e., attorneys, accountants, licensed insurance agents, mortgage brokers, etc.), including professionals that are clients of the Registrant. This arrangement presents a conflict of interest, such that Registrant could be deemed to have an incentive to recommend these client professionals to Registrant’s other clients. The Registrant’s Chief Compliance Officer, Jeffrey G. Dohner, remains available to address any questions that a client or prospective client may have regarding the above conflicts of interest. Retirement Plans and Retirement Plan Participants. When Registrant provides investment advice to clients regarding their retirement plan account or individual retirement account, it is a fiduciary 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 Registrant makes money creates some conflicts with client interests, so Registrant operates under a special rule that requires it to act in a client’s best interest and not put its interest ahead of the client’s. Under this special rule's provisions, the Registrant must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put its financial interests ahead of the client’s when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that it gives advice that is in the client’s best interest;
• Charge no more than is reasonable for its services; and
• Give the client basic information about conflicts of interest. Rollover Recommendations. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): i) leave the money in the former employer’s plan, if permitted, ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, iii) roll over the assets to an Individual Retirement Account (“IRA”), or iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If the Registrant recommends that a client roll over their retirement plan assets into an account managed by the Registrant, such a recommendation creates a conflict of interest if the Registrant will earn a new or increase its advisory fee as a result of the rollover. No client is under any obligation to roll over retirement plan assets to an account managed by Registrant. The Registrant’s Chief Compliance Officer, Jeffrey G. Dohner, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such roll over recommendation. Please Note: Asset Based Pricing Limitations: Registrant, in limited circumstances, may recommend clients enter into an asset based pricing agreement with the account custodian, generally Charles Schwab & Co., Inc. Under an asset based pricing arrangement, the amount the client will pay the custodian for account commission/transaction fees is based upon a percentage (%) of the market value of the client’s account (generally, the greater the market value, the lower the %). This differs from transaction-based pricing, which assesses a separate commission/transaction fee against the client’s account for each account transaction. Account investment decisions are driven by security selection and anticipated market conditions and not the amount of transaction fees payable by the client to the account custodian. Registrant does not receive any portion of the asset based transaction fees payable by the client to the account custodian. Registrant continues to believe, in limited circumstances, clients benefit from an asset based pricing arrangement. However, a client can request at any time to switch from asset based pricing to transaction based pricing. However, there can be no assurance that the volume of transactions will be consistent from year-to-year given changes in market events and security selection. Therefore, given the variances in trading volume, any decision by a client to switch to transaction based pricing could prove to be economically disadvantageous. The Registrant’s Chief Compliance Officer, Jeffrey G. Dohner, remains available to address any questions that a client or prospective client may have regarding the above arrangement. Trade Error Policy. From time to time Registrant may make an error in submitting a trade order on a client’s behalf. When this occurs, Registrant may place a correcting trade with the broker-dealer which has custody of the client’s account. When Registrant corrects an error, the client must not be disadvantaged; the client must be “made whole”, neither recognizing any loss nor gain from the error. Accordingly, if Registrant makes an error while submitting a trade for a client’s account, then Registrant, in order to comply with its fiduciary obligation to the client, must bear any costs of correcting such a trade. Client Obligations. In performing its services, Registrant shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify the Registrant, in writing, if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Registrant’s previous recommendations and/or services. Please Note: Neither the Registrant, nor any of its employees, serve as an attorney, accountant, or insurance agent for any of the Registrant’s clients, and no portion of the Registrant’s services should be construed as same. Accordingly, Registrant does not prepare estate planning documents, nor does Registrant sell insurance products. Registrant does offer income tax preparation services as disclosed herein. Please Note – Use of Mutual Funds: Most mutual funds are available directly to the public. Thus, a prospective client can obtain some of the mutual funds that may be recommended and/or utilized by Registrant independent of engaging Registrant as an investment advisor. However, if a prospective client determines to do so, he/she will not receive Registrant’s initial and ongoing investment advisory services. C. The Registrant shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, the Registrant shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on the Registrant’s services. The Registrant has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, the Registrant will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, market conditions, investment performance, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when the Registrant determines that changes to a client’s portfolio are neither necessary nor prudent. The Registrant’s advisory fee remains payable during periods of account inactivity. D. The Registrant does not participate in a wrap fee program. E. As of December 31, 2023, the Registrant had $5,210,989,000 in assets under management on a discretionary basis and $204,864,000 in assets under management on a non- discretionary basis.