ADV Part 2A, Item 4 Wall Capital Group, Inc. (“WCG”) is an SEC-registered investment adviser. Prior to March 2018, WCG did business as Wall & Associates and Wall Wealth Advisors. Associated persons of WCG are referred to herein as “Advisory Representatives.” WCG was incorporated in the State of Illinois and began its advisory business in May 1990. The principal owners are David J. Wall and his wife Colleen M. Wall. Each owns 50% of the firm’s outstanding stock. Until March 2018, the firm’s corporate name was Money Matters Financial Group, Inc. The firm changed its name to reflect the Wall brand that its clients have known over the years while operating using the names Wall & Associates and Wall Wealth Advisors. Investment Management and Consulting WCG provides continuous discretionary investment supervisory management services, personal financial planning services and non-discretionary institutional consulting/advisory services. As of the date of this brochure, approximately 85% of WCG’s advisory services assets managed are for institutional clients. Approximately 15% of advisory services assets managed are personal financial planning and individual asset management services. We have more individual clients, however, than institutional clients. For a more detailed discussion of our clients, please see Item 7, Types of Clients, in this brochure. We provide individual personal financial planning and asset management. WCG’s institutional clients are primarily police and fire pension accounts. WCG will evaluate and provide analysis with respect to the liquidity of the pension account, develop a written investment policy statement, assist in defining risk tolerance, perform separate account manager search and due diligence, monitor manager and plan/account performance, assist in complying with pension code guidelines, and provide regular quarterly performance reports. Asset Management Program Clients wanting to engage WCG to manage client’s account will need to establish an account (“Account”) with Charles Schwab and Company (“Charles Schwab”) or a broker/dealer or other custodian of client’s choice and grant trading authorization to WCG. Clients who choose another broker/dealer are advised that the broker/dealer should be able to provide duplicate statements and confirmations to WCG and accept trades from WCG. Additionally, if possible, WCG should be given electronic access to client’s account. WCG will not maintain custody of client’s funds or securities. WCG offers asset management services on a discretionary basis using mutual funds and Exchange Traded Funds (ETF’s). Advisory Representatives will gather information on a client’s financial history, goals, objectives, and financial concerns and assist client in developing an asset allocation strategy. All information gathered from client is confidential. Client will establish an account and deposit cash, cash equivalents and securities and engage an Advisory Representative to manage the Account. Based on client’s investment objectives, risk tolerance, and financial situation, WCG will provide the advisory services requested by the client. WCG will exercise discretionary authority to purchase, sell, and exchange and otherwise transact securities in accounts receiving continuous supervisory management services. Therefore, securities transactions will be conducted without discussing the securities transactions with the client prior to the transactions. WCG does not normally allow restrictions. Financial Planning Services WCG offers financial, tax, estate, retirement, and educational planning services.

WCG will gather financial information and history from the client including, but not limited to, retirement and financial goals, investment objectives, investment horizon, financial needs, cash flow analysis, cost of living needs, education needs, savings tendencies, and other applicable financial information required by WCG in order to provide the investment advisory services requested. Based WCG’s analysis of a client’s information and needs, WCG will provide clients with recommendations. Financial plans are based on the client’s financial situation at the time and are based on financial information disclosed by the client to WCG. Clients are advised that certain assumptions may be made with respect to interest and inflation rates and use of past trends and performance of the market and economy. However, past performance is in no way an indication of future performance. WCG cannot offer any guarantees or promises that a client’s financial goals and objectives will be met. Further, each client must continue to review any plan and update the plan based upon changes in the client’s financial situation, goals, or objectives or changes in the economy. Should a client’s financial situation or investment goals or objectives change, clients must notify WCG promptly of the changes. Advisory Representatives may offer advice and tailor insurance needs for WCG’s clients. WCG employees are licensed to recommend and sell life insurance and annuities products in the States of Illinois and Arizona. WCG may make recommendations to purchase certain insurance products when it satisfies a client’s investment goals and objectives. WCG will prepare personal financial plans for a fee. Fees are negotiable because there may be differences in the complexity of the services requested. Our standard fee to create a financial plan is set forth in Item 5, Fees and Compensation. Needs of Our Clients Personal asset management and financial planning services are tailored to meet specific client goals and objectives as well. Client data is gathered using questionnaires which aid in establishing those goals and objectives. Exhibits displaying the historical risk and return characteristics of various stock and bond asset mixes are available to assist in evaluating the merits of various investment allocations. Models using unmanaged market indices are used to illustrate this information and are not actual returns of client’s investment portfolios, but merely illustrations based upon historical capital market behavior. After identifying the client’s specific goals, objectives, and risk tolerance, accounts are managed to one of the following asset mix targets: 1. Preservation of capital - 100% fixed income and cash; 2. Conservative - 30% equity and 70% fixed income; 3. Moderate Conservative - 40% equity and 60% fixed income; 4. Moderate - 50% equity and 50% fixed income; 5. Moderate Aggressive - 60% equity and 40% fixed income; and 6. Aggressive - 70% equity and 30% fixed income. Portfolios are rebalanced back to targets when asset class weights are plus or minus 5% from the intended target. Police and fire advisory services are tailored to meet the liquidity, risk tolerance, plan objectives and statutory requirements of the plan. These are identified by meeting with the Board of Trustees and discussing the specifics of their plan. Wrap Fee Program WCG does not participate in any wrap fee programs. Assets Under Management As of December 31, 2023, discretionary assets were approximately $259,615,000 and non- discretionary assets were approximately $398125,000, for a total of approximately $657,740,000 (all rounded to the nearest thousand.)