Information about Our Firm Important Information Throughout this document, CGN Advisors, LLC shall be referred to by the following terms: the “firm,” “we,” “us,” or “our”. The client or prospective client may be referred to as: “you,” your,” etc. Associates operating in offices located throughout the country are authorized to utilize other business names in conjunction with their offering investment advisory services through our firm. Please refer to the current listing accompanying this brochure. This brochure contains 34 pages and should not be considered complete without all pages. Form ADV Part 2A – March 2024 Page 5 of 34 CGN Advisors, LLC is a Kansas Limited Liability Company formed in 2011. Our firm is a wholly owned subsidiary of CGN Companies, LLC, which is directly owned by Mr. Justin Nichols, Mr. Michael Greim and Mr. Chad Chase, the firm’s principals. In addition to our 2011 registration as an SEC investment advisor, our firm and its associates notice-file, register or meet certain exemptions to registration in other jurisdictions in which we conduct investment advisory business. Mr. Nichols serves as the firm’s Managing Principal – Operations, Mr. Chase serves as the firm’s Managing Principal – Senior Advisor, and Mr. Greim serves as the firm’s Managing Principal – Investments and Chief Compliance Officer. Our firm provides a broad range of investment advisory and ancillary services to people from all walks of life. Our primary focus is providing financial planning services, which includes such areas as cash flow and budgeting, education funding, retirement planning, risk management and estate planning. We offer investment advice through periodic consultations (which we term investment consultation) or portfolio monitoring services, neither of which include ongoing management of an investment account. We also provide ongoing and continuous supervision of clients’ portfolios through our investment supervisory services offering, as well as investment management services through the engagement of institutional third-party investment managers which are described in further detail in a separate advisory services brochure. Some of our associates also provide tax preparation services when appropriate. We hold ourselves to a fiduciary standard, which means our firm and its associates will act in the utmost good faith and perform in a manner believed to be in the best interest of our clients. As fiduciaries, we are obligated to put you – our client – first. We feel this sets us apart from other types of firms in the securities industry such as broker/dealers that may be held to a, perhaps lesser, “suitability” standard. Such firms may not be required under current regulation to place clients’ interests ahead of their own or to fully disclose conflicts of interest involving their recommendations to clients. Getting Started To begin, a complimentary interview is conducted by a qualified representative of our firm to determine the scope of services to be provided. During or prior to this meeting, we will provide you with our current ADV Part 2A brochure that incorporates our Privacy Policy, and you will receive an ADV Part 2B – Brochure Supplement (Advisory Personnel) and Form CRS from your investment advisor representative who is assisting you. The firm will also ensure any material conflicts of interest are disclosed regarding our firm and its associates that could be reasonably expected to impair the rendering of unbiased and objective advice. Should you wish to engage our firm, we must first enter into a written agreement; thereafter, discussion and analysis will be conducted to determine your financial needs, goals, holdings, etc. Depending on the scope of the engagement, we may require current copies of the following documents early in the process:
• Wills, codicils and trusts;
• Insurance policies;
• Mortgage information;
• Tax returns;
• Current financial specifics including W2s or 1099s;
• Information on current retirement plans and benefits provided by your employer;
• Statements reflecting current investments in retirement and non-retirement accounts; and
• Completed risk profile questionnaires or other forms provided by our firm. Form ADV Part 2A – March 2024 Page 6 of 34 It is important that the information and financial statements you provide is accurate. We may, but are not obligated to, verify the information you have provided, which will then be used in the financial planning or investment advisory process. Financial Planning and Investment Consultation Services Under our Financial Planning engagements, we provide advice to you on subjects such as cash flow analysis, retirement capital needs, education funding, risk management, estate planning, or other specific needs as you may request. The following are general examples, which may change based on your situation and needs. Cash Flow Analysis – A review of your income and expenses to determine the current surplus or deficit along with advice on prioritizing how any surplus should be used or how to reduce expenses if they exceed your income. Advice may be provided on which debts to pay off first based on factors such as the interest rate of the debt and any income tax ramifications. Advice is also provided on the appropriate cash reserve that should be considered for emergencies and other financial goals, a review of accounts (such as money market funds) for such reserves, plus strategies to save the desired amounts. Education Funding – Our education funding review may include projecting the amount that will be needed to achieve college or other post-secondary education funding goals, along with advice on ways for you to save the desired amount. Advice might also include the “pros-and-cons” of various college savings vehicles, such as Section 529 college savings plans and any advantages to you (i.e., reduction of income taxes) of using a particular state’s Section 529 plan, prepaid savings plan or another plan, such as a Coverdell Education Savings Account. Risk Management Analysis – Our services include an analysis of your exposure to major risks that could have a significant adverse impact on your financial picture, such as premature death, disability or the need for long-term care. Advice is provided on ways to minimize such risks and about weighing the costs and benefits and, likewise, the potential costs of not purchasing insurance (self- insuring). We may consult with your insurance agent, other insurance agents or brokers and/or other insurance experts to assist you in making prudent risk management decisions and to help you select any appropriate insurance policies if needed. Estate Planning – This may include an analysis of your exposure to estate taxes or a review of your current estate plan, including wills, powers of attorney, trusts and other related documents. Our advice typically includes ways for your financial assets and personal items to transfer smoothly and as you desire, as well as methods to minimize or avoid future estate taxes by implementing appropriate estate planning strategies such as the use of applicable trusts. We always recommend that you consult with a qualified attorney when you initiate, update, or complete estate planning activities. We may provide you with contact information for attorneys who specialize in estate planning if you wish to hire an attorney for such purposes. From time to time, we will participate in meetings or phone calls between you and your attorney with your approval or request. Investment Consultation Form ADV Part 2A – March 2024 Page 7 of 34 Our investment consultation engagements involve providing information on the types of investment vehicles available, employee stock options, investment analysis, asset selection, or assisting you in establishing your own investment account at the broker/dealer or custodian of your choosing. We may offer projections of the likelihood of achieving your financial goals, with financial independence usually the primary goal. For situations in which projections show less than the desired results, we may make recommendations that include showing you the impact on those projections by making changes in certain variables (i.e., working longer, saving more, spending less, taking more risk with investments to potentially get a better return). If you are near retirement or already retired, advice may be given on appropriate distribution strategies to minimize the likelihood of running out of money or having to significantly reduce spending during your retirement years. Real-Time Planning Sessions Our real-time planning sessions are limited-scope engagements designed to assist you in determining how best to invest your time with one of our financial planning professionals. These sessions are typically 90 to 120 minutes in length and generally focus on more pressing issues you may have. Therefore, all issues, urgent or not, may not be addressed in this brief time frame. All work may either be performed in your presence or, possibly, approximately 30 minutes may be assigned for follow up. A summary report is provided at the conclusion of the meeting or shortly following the session to address key points that

were discussed during the planning session. You may also choose to re-engage your financial planner for additional real-time planning sessions at a later date. Educational Workshops We provide educational workshops on an “as announced” basis for groups desiring general advice on investments and personal finance. Topics include issues related to financial planning, educational and estate planning, retirement strategies, or various other economic and investment topics. Our workshops are educational in nature and do not involve the sale of insurance or investment products. Information presented will not be based on any one person’s need nor do we provide individualized investment advice to attendees during our general sessions. Tax Return Preparation We may provide tax return preparation services through select locations, performed by qualified associates under the guidance of industry professionals. Coordinating income tax return preparation with financial planning may provide you with a thorough, coordinated understanding of your finances. Under each type of engagement, we will provide you with written recommendations and deliverables as specified in your agreement. Our services and subsequent recommendations may either be broad- based or more narrowly focused, as you desire. Note that when these services focus only on certain areas of your interest or need, your overall financial situation or needs may not be fully addressed due to the limitations you have established. In all instances, you will retain full discretion over all implementation decisions and are free to accept or decline any recommendation we make. Further, it remains your responsibility to promptly notify us if there is any change in your financial situation or investment objectives for the purpose of our reviewing, evaluating, or revising previous recommendations and/or services. Form ADV Part 2A – March 2024 Page 8 of 34 Upon completion of our presentation or delivery of advice, our engagements are typically concluded unless your agreement calls for continued services and support (i.e., a retainer engagement, etc.). If your agreement is for a single engagement, you are encouraged to contact our firm at any time in the future to re-engage our services and, we may also contact you to determine if you are in need of a review. Further information about our review process can be found in Item 13 of this brochure. Implementation You may also engage our firm to implement investment strategies that we have recommended to you. Depending on your risk profile, needs, among other considerations, your portfolio may involve the employment of one or more investment strategies, and as well as either a broad range or more narrowly focused choice of investment vehicles, each of which is described in further detail in Item 8 of this brochure. Our Portfolio Monitoring Services allow you to engage us to provide periodic review of your assets held at your selected broker/dealer or custodian. This engagement does not involve our providing daily account supervision or account trading; however, we generally provide quarterly account monitoring and offer recommendations as necessary to meet your investment objectives. You will then need to affect the necessary transactions to meet the suggested allocation. We provide our Investment Supervisory Services under a discretionary or non-discretionary authority agreement (defined in Item 16), and our may services include the following:
• Investment strategy,
• Investment policy statement,
• Asset allocation,
• Asset selection,
• Risk tolerance, and
• Regular portfolio management. Where appropriate, we will assist you in preparing an investment profile summary (IPS), or similar document, reflecting your investment objectives, time horizon, tolerance and appetite for risk, as well as any account constraints you may have for the portfolio. Your investment profile summary will be designed to be specific enough to provide future guidance while allowing flexibility to work with changing market conditions. Since the IPS, to a large extent, will be a product of information and data you have provided, you will be responsible for reviewing and providing final approval of the document/plan. Following our review of your situation, and if appropriate for your preferences and investment strategy, we may recommend an institutional-level third-party investment manager (also a registered investment advisor) to implement their strategy for some of or your entire portfolio. Prior to recommending a third-party investment manager, our firm will conduct what we believe to be an appropriate level of due diligence to include ensuring the firm is appropriately registered or notice- filed within your jurisdiction, if required. At least annually thereafter, a due diligence review will be performed from both a compliance and performance perspective to determine that the selected third- party manager remains an appropriate fit. Our firm’s investment committee will review each third-party Form ADV Part 2A – March 2024 Page 9 of 34 investment manager’s performance over an extended period of time and on a continuing basis, as well as at least quarterly to discuss any potential concerns or recommended changes of program third-party managers. Under this type of engagement, we will gather information from you about your financial situation, investment objectives, reasonable restrictions you may want to impose on the management of the account, and we will then provide this data to the third-party investment manager to develop the portfolio. Third-party managers will invest on behalf of a client account in accordance with the strategies set forth in their own requisite documents which will be provided to you by our firm prior to your portfolio employing their strategies. Please keep in mind that third-party investment managers typically assume discretionary authority over an account (see Item 16), and some of these programs may not be available for those clients who prefer an account to be managed under a non-discretionary engagement. Also note that our firm will not manage or obtain discretionary authority over those accounts participating in a third-party manager program. Investment Management Sub-Advisory Services We may engage selected registered investment adviser firms not affiliated with us to provide investment management sub-advisory services for our clients. Through this type of engagement, we recommend the sub-advisor’s investment strategy and services to clients, when appropriate, based on each client’s individual needs. CGN Advisors, LLC will generally serve as the communication conduit between the client and the sub- advisor. We will be available to answer questions the client may have regarding their account and will provide account reviews on a schedule agreed upon with the client. The sub-advisor will generally have discretionary authority to determine the securities to be purchased and sold for the client’s accounts it manages. Discretionary authority is described in more detail in Item 16 of this brochure. Wrap Fee Programs We do not sponsor or serve as a portfolio manager in any investment program involving wrap fees. Assets Under Management As of December 31, 2023, the firm managed over $1,135,218,974.00 of client assets; $1,121,047,331.00 under discretionary account agreements and $14,171,643.00 under non-discretionary account agreements. Please see Item 16 of this brochure for more information about investment discretion. General Information Some of our representatives may offer legal, tax preparation or accounting services. Such services will be offered under a separate agreement and there is no requirement to utilize these advisors for these separate services. With your consent, we may work with your other professional advisors to assist with coordination and implementation of recommended strategies. You should be aware that these other advisors will bill you separately for their services and these fees will be in addition to those of our firm. Our firm will use its best judgment and good faith effort in rendering its services; however, our firm and its associates cannot warrant or guarantee any particular level of account performance, that your Form ADV Part 2A – March 2024 Page 10 of 34 account will be profitable over time, or that your financial planning goals will be met. Past performance is not necessarily indicative of future results. Except as may otherwise be provided by law, our firm will not be liable to the client, heirs, or assignees for any loss that an account may suffer by reason of an investment decision made or other action taken or omitted in good faith by our firm with the degree of care, skill, prudence and diligence under the circumstances that a prudent person acting in a fiduciary capacity would use; any loss arising from our adherence to your direction or that of your legal agent; or any act or failure to act by a service provider maintaining an account. Notwithstanding the preceding, nothing within our client agreement is intended to diminish in any way our fiduciary obligation to act in your best interest, or in any way limit or waive your rights under federal or state securities laws or the rules promulgated pursuant to those laws.