A. Firm Information National Wealth Management Group, LLC (NWMG) was formed and registered as an investment adviser registered with the Securities and Exchange Commission (“SEC”) in 2015. National Wealth Management Group offers services through our network of investment advisor representatives (“Investment Advisor Representatives” or “IARs”). Some of our IARs have their own legal business entity whose trade name and logos are used for marketing purposes; they can appear on marketing materials and/or client statements. Any such trade name is a legal entity of the IAR, not NWMG. The IARs are under the supervision NWMG and the advisory services of the IAR are provided through NWMG. National Wealth Management Group has the arrangement described above with the following Investment Advisor Representatives:  Vivienne Schleu - Alpina Financial Consultants, LLC;  Lisa Gerardi - Gerardi Wealth Management, LLC;  Angela Howard - Model Wealth Group, LLC: and,  Brent Gargano – Infinite Wealth Planning. B. Advisory Services Offered National Wealth Management Group, LLC provides fee-based investment advisory services for compensation primarily to individual clients and high-net worth individuals based on the individual goals, objectives, time horizon, and risk tolerance of each client. Portfolio management services include, but are not limited to, the following:  Investment Strategy  Asset Allocation  Risk Tolerance  Personal investment policy  Asset Selection  Regular Portfolio Monitoring Investment Advisor Representatives are restricted to providing services and charging fees based in accordance with the descriptions detailed in this document and the account agreement. However, the exact service and fees charged to a particular client are dependent upon the representative that is working with the client. Advisors are instructed to consider the individual needs of each client when recommending an advisory platform. Investment strategies and recommendations are tailored to the individual needs of each client. Investment Advisor Representatives associated with NWMG are appropriately licensed and authorized to provide advisory services on behalf NWMG. Investment Adviser Representatives associated with NWMG are also registered representatives of LPL Financial, an SEC registered and FINRA1/SIPC2 member broker/dealer. Any securities transactions shall be directed to LPL Financial for execution. NWMG and LPL Financial are not affiliated legal entities. Additional information about LPL Financial can be found on the Investment Adviser Public Disclosure website3 Principal Owners Benjamin J. Jones (50%) – Ben serves as a Managing Director, Chief Executive Officer and Compliance Officer as well as a Financial Advisor. He earned his B.S. in Business Administration from Pepperdine University; he started his career as a financial advisor in 2006. Vivienne K. Schleu, CPA (50%) – Ms. Schleu serves as the Managing Director, Chief Financial Officer and Financial Advisor. Vivienne started in the securities industry in 1995, the first year that Florida allowed CPA's to become securities licensed. C. Client Account Management Prior to engaging NWMG to provide investment advisory services, each Client is required to enter into an investment advisory agreement / one or more agreements with the Advisor that defines the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:  Establishing an Investment Strategy – National Wealth Management Group, in connection with the Client, may a strategy that seeks to achieve the Client’s goals and destinations. The strategy is designed to address the Client’s personal goals, investment goals, and both long-term and short-term objectives. 1 FINRA (Financial Regulatory Authority) is dedicated to investor protection and market integrity through effective and efficient regulation of the securities industry. FINRA is not part of the government, but an independent, not-for-profit organization authorized by Congress to protect America’s investors by making sure the securities industry operates fairly and honestly. http://www.finra.org. 2 SIPC (Securities Investors Protection Corporation) was created under the Securities Investor Protection Act as a non- profit membership corporation. SIPC oversees the liquidation of member broker-dealers that close when the broker-dealer is bankrupt or in financial trouble, and customer assets are missing. http://sipc.org 3 An official website of the United States Government  Asset Allocation – National Wealth Management Group will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance of risk for each Client.  Portfolio Construction – National Wealth Management Group will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.  Investment Management and Supervision – National Wealth Management Group will provide investment management and ongoing oversight of the Client’s relationship’s investment portfolio. Investment Management Services National Wealth Management Group through its investment advisor representatives, provides ongoing investment advice and management on assets in the client’s custodial accounts. Advice may be discretionary or non-discretionary as indicated in the client account agreement. More specific account information and acknowledgements are further detailed on the account application. National Wealth Management Group’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held less than one year to meet the objectives of the Client or due to market conditions. National Wealth Management Group 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. Investment management services include:  Redistributing investment allocations to diversify the portfolio  Sector asset class allocations  Employing cash positions as a possible hedge against market movement  Selling positions to harvest capital gains or losses  Business or sector risk exposure to a specific security or class of securities  Overvaluation or overweighting of position[s] due to changes in risk tolerance  Generating cash to meet Client needs  Risk Management Investment strategies and recommendations generally consist of an asset allocation consistent with: 1. Income with Capital Preservation. Designed as a longer-term accumulation account, this investment objective is considered generally the most conservative. Emphasis is placed on generation of current income with minimal risk of capital loss. Lowering the risk generally means lowering the potential income and overall return. 2. Income with Moderate Growth. This investment objective emphasizes generation of current income with a secondary focus on moderate capital growth. 3. Growth with Income. This investment objective emphasizes modest capital growth with some focus on generation of current income. 4. Growth. This investment objective emphasizes achieving high long-term growth and capital appreciation. There is little focus on generation of current income. 5. Aggressive Growth. This investment objective emphasizes aggressive growth and maximum capital appreciation, with no focus on generation of current income. This objective has a very high level of risk and is for investors with a longer timer horizon. LPL Financial Sponsored Platforms - Strategic Wealth Management (SWM I and SWM II) Strategic Wealth Management is the name of the custodial account offered through LPL Financial LLC to support investment advisory services provided by NWMG. Within a SWM account, investment advisor representatives provide advice on the purchase and sale of various types of investments, such as mutual funds, exchange-traded funds (“ETFs”), variable annuity subaccounts, real estate investment trusts (“REITs”), equities, and fixed income securities. The advice is tailored to the individual needs of the client based on the investment objective chosen by the client in order to help assist clients in attempting to meet their financial goals. Accounts are reviewed on a regular basis and rebalanced as necessary according to each client’s investment profile. More specific account information and acknowledgements are further detailed in the account opening documents. Investment Advisors Representatives can offer SWM I or SWM II. The accounts offer the same investment choices and are managed in the same manner, but the fee structure is different. For SWM I, clients are charged transaction fees in addition to the advisory fee whereas for SWM II, the transactions fees are absorbed as part of the advisory fee. National Wealth Management Group offers SWM II as wrap fee program where the firm acts as the sponsor and portfolio manager. Please see Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure. The advisory fee for SWM II accounts may be higher than SWM I to account for the transaction fees. Depending on the anticipated level of trading, investment advisor representatives of NWMG will work with each client to determine the most cost-effective fee structure. The minimum account opening amount is generally $15,000, which can be by check or transfer. LPL Sponsored Wrap Fee Programs National Wealth Management Group offers a number of other wrap fee programs where LPL serves as the sponsor and portfolio manager. While LPL serves as the wrap fee sponsor and portfolio manager, NWMG manages the allocation funds between the different portfolios and available fund selections. Optimum Market Portfolios Program (OMP) The Optimum Market Portfolios (OMP) program offers clients the ability to participate in a professionally managed asset allocation program designed by LPL Financial. There are up to six Optimum Funds that may be purchased within an OMP account: 1. Optimum Large Cap Growth Fund 2. Optimum Large Cap Value Fund 3. Optimum Small Cap Growth Fund 4. Optimum Small Cap Value Fund 5. Optimum International Fund 6. Optimum Fixed Income Fund National Wealth Management Group will obtain the necessary financial data from each client and then select the proper fund portfolio program. While NWMG selects the proper portfolio program, LPL Financial will manage the underlying Optimum Funds on a discretionary basis consistent with the portfolio program objectives. LPL Financial does not directly manage fund assets on behalf of any particular client. LPL Financial follows an asset allocation investment style in constructing portfolios for the Program. Asset allocation methodology is implemented by combining investments representing various asset classes that react differently to varying market conditions. Thus, if one asset class reacts negatively to certain market events, the potential exists for another asset class to react positively. As with any investment strategy, there is no guarantee that the use of an asset allocation strategy will produce favorable results. National Wealth Management Group is responsible for educating the client about this investment style in advance of opening the Account by explaining the various asset classes (e.g., large cap growth, large cap value, etc.) being used within the selected portfolio. This educational process continues throughout the time that the client maintains the account. OMP is one of several portfolio platforms centrally managed by LPL Financial. OMP enables advisors of National Wealth Management Group to manage client assets through diversified asset allocation models, professional money management, automatic rebalancing, and online marketing and sales support. A minimum account value of $15,000 is required for OMP. Personal Wealth Portfolios Program (PWP) PWP offers clients an asset management account using third party adviser portfolio allocation models designed by LPL Financial. The PWP program is a unified managed account program in which LPL and Advisor provide ongoing investment advice and management. In PWP, clients invest in asset allocation portfolios (“Portfolios”) designed by LPL’s Research Department, which include a combination of mutual funds, exchange-traded funds (“ETFs”) and investment models (“Models”) provided to LPL by third party money managers ("PWP Advisors"). The Models typically consist of equity and fixed income securities but may include investment company securities. LPL’s Research Department selects the mutual funds, ETFs and Models to be made available in a Portfolio. The advisor obtains the necessary financial data from the client, assists the client in determining the suitability of the program and assists the client in setting an appropriate investment objective. The advisor, or client with the assistance of the advisor, selects a portfolio based on client’s investment objective and then selects among the mutual funds, ETFs and/or Models available in the portfolio. If client authorizes advisor to take discretion to make such selections on client’s behalf, the discretionary authority will be set out in the Account Agreement and Application signed by the client. Neither LPL nor a third-party money manager directly provides advisory services to the clients of National Wealth Management Group. The third-party money managers selected by LPL Financial for a program platform manage the portfolio without regard for any particular client of NWMG. National Wealth Management Group is solely responsible for the advisory services provided and selecting the proper portfolio of third-party money managers. National Wealth Management Group is not acting as promoter for LPL Financial or other third-party money managers. A minimum account value of $250,000 is required for PWP. Model Wealth Portfolios Program (MWP) Model Wealth Portfolios offers clients a professionally managed mutual fund asset allocation program. National Wealth Management Group investment advisor representatives will obtain the necessary financial data from the client, assist the client in determining the suitability of the MWP program and assist the client in setting an appropriate investment objective. The Advisor will initiate the steps necessary to open an MWP account and have discretion to select a model portfolio designed by LPL’s Research Department consistent with the client’s stated investment objective. LPL’s Research Department is responsible for selecting the mutual funds within a model portfolio and for making changes to the mutual funds selected. The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds including in certain circumstances exchange traded funds and to liquidate previously purchased securities. The client will also authorize LPL to effect rebalancing for MWP accounts. In the future, the MWP program may make available model portfolios designed by strategists other than LPL’s Research Department. If such models are made available, Advisor will have discretion to choose among the available models designed by LPL or outside strategists. A minimum account value of $25,000 is required for MWP. Manager Access Select Program (MAS) Manager Access Select provides clients access to the investment advisory services of professional portfolio management firms for the individual management of client accounts. Advisor will assist client in identifying a third-party portfolio manager (Portfolio Manager) from a list of Portfolio Managers made available by LPL. The Portfolio Manager manages client’s assets on a discretionary basis. Advisor will provide initial and ongoing assistance regarding the Portfolio Manager selection process. A minimum account value of $100,000 is required for Manager Access Select, however, in certain instances, the minimum account size may be lower or higher. Manager Access Network Program (MAN) Manager Access Network enables high-net-worth investors to access a variety of institutional portfolio managers at significantly lower account minimums. By using separate account managers, clients can enjoy a higher level of specialization and service through the ownership of individual securities. A broad range of portfolio managers and multiple investment styles are available, including equity, fixed income, asset classes, mutual funds, ETFs, and specialty strategies. Clients contract directly with the portfolio managers for discretionary asset management services. LPL Financial provides brokerage, custodial, and administrative services to clients. Due diligence and portfolio monitoring is not provided by LPL Research. Minimum account balances vary by portfolio manager, but typically start at $100,000 for equity strategies and $250,000 for fixed income strategies. Guided Wealth Portfolios (GWP) GWP offers clients the ability to participate in a centrally managed, algorithm-based investment program, which is made available to users and clients through a web-based, interactive account management portal (“Investor Portal”). Investment recommendations to buy and sell open-end mutual funds and exchange-traded funds are generated through proprietary, automated, computer algorithms (collectively, the “Algorithm”), based upon model portfolios constructed by LPL and selected for the account as described below (such model portfolio selected for the account, the “Model Portfolio”). Communications concerning GWP are intended to occur primarily through electronic means (including but not limited to, through email communications or through the Investor Portal), although NWMG will be available to discuss investment strategies, objectives or the account in general in person or via telephone. A preview of the Program (the “Educational Tool”) is provided for a period of up to forty-five (45) days to help users determine whether they would like to become advisory clients and receive ongoing financial advice from LPL and NWMG by enrolling in the advisory service (the “Managed Service”). The Educational Tool and Managed Service are described in more detail in the GWP Program Brochure. Users of the Educational Tool are not considered to be advisory clients of LPL, NWMG, do not enter an advisory agreement with LPL or NWMG, do not receive ongoing investment advice or supervisions of their assets, and do not receive any trading services. A minimum account value of $5,000 is required to enroll in the Managed Service.  Features of the Educational Tool - Users of the Educational Tool (each, a “user”) agree to a terms of use (“Terms of Use”) and complete an investor profile. An investment objective (“Investment Objective”) and Model Portfolio is assigned to each user based upon factors in the investor profile, including risk tolerance and the number of years remaining until the age of retirement (such time being referred to herein as the “Retirement Age”). (See description in “Features of the Managed Service” below for information regarding the design of the Model Portfolios.) Based on the Investment Objective and Model Portfolio, the Educational Tool generates sample analysis, advice and investment recommendations (“Sample Recommendations”). o The Educational Tool provides Sample Recommendations that may assist users in determining whether to utilize the Managed Service. Access to the Educational Tool is limited to a period of forty-five (45) days. The Educational Tool is intended to be used for educational and informational purposes only. The Educational Tool does not provide comprehensive financial planning and is not intended to constitute legal, financial or tax advice. There may be other relevant factors and financial considerations (e.g., debt load or financial obligations) that LPL and NWMG do not take into consideration in formulating any Sample Recommendations provided. The Sample Recommendations made are meant solely as a sample of the types of recommendations available through the Managed Service. LPL and NWMG are not responsible for any actions taken with respect to the Sample Recommendations, and users are solely responsible for making their own investment decisions. The Educational Tool is only one of many tools that users may use as part of a comprehensive investment analysis process. Users should not rely on the Educational Tool as the sole basis for investment decisions. o Although LPL is an investment adviser and broker-dealer registered with the SEC and a member of the Financial Industry Regulatory Authority, in providing access to the Educational Tool, LPL and NWMG do not intend to establish an advisory relationship, or in the case of LPL, a brokerage relationship, with users of the Educational Tool. Users are not charged an advisory fee or any other fee or expense to use the Educational Tool. The scope of any investment advisory relationship with LPL and NWMG begins when users enroll in the Managed Service. The output that users receive by using the Educational Tool, including the Sample Recommendations, may differ materially from the advice users would receive as an advisory client of LPL and NWMG. o Neither LPL nor NWMG provides ongoing investment management or trading services for assets of users of the Educational Tool, makes any determination as to whether the website through which the Program is accessed or the Educational Tool is appropriate for any user, can access any assets in any accounts users aggregate in the Educational Tool, places any trades on behalf of users of the Educational Tool, or provides ongoing supervision of assets of users of the Educational Tool. The Sample Recommendations provided are intended as an informational preview of the Managed Service, and the Sample Recommendations are being provided to demonstrate the types of analysis, advice and recommendations provided by the Managed Service.  Features of the Managed Service - Investors participating in the Managed Service (each, a “client”) complete an account application (the “Account Application”) and enter into an account agreement (the “Account Agreement”) with LPL, NWMG. As part of the account opening process, clients are responsible for providing complete and accurate information regarding, among other things, their age, risk tolerance, and investment horizon (collectively, “Client Profile”). LPL and NWMG rely on the information in the Client Profile in order to provide services under the Program, including but not limited to, determination of suitability of the Program for clients and an appropriate Investment Objective and Model Portfolio for clients. The Model Portfolios have been designed and are maintained by LPL or, in the future, a third-party investment strategist (as applicable, the “Portfolio Strategist”) and shall include a list of securities holdings, relative weightings and a list of potential replacement securities for tax harvesting purposes. None of the client, NWMG or can access, change or customize the Model Portfolios. Only one Model Portfolio is permitted per account. o Based upon a client’s risk tolerance as indicated in the Client Profile, the client is assigned an investment allocation track (currently Fixed Income Tilt, Balance Tilt or Equity Tilt), the purpose of which is to slowly rotate the client’s equity allocation to fixed income over time. LPL Research created these tracks using academic research on optimal retirement allocations, the industry averages as calculated by Morningstar for the target date fund universe, and input from. o Within the applicable allocation track and based upon a client’s chosen Retirement Age in the Client Profile, the client will be assigned a Model Portfolio and one of five of LPL’s standard investment objectives. Both the client and NWMG are required to review and approve the initial Investment Objective. As a client approaches the Retirement Age, the Algorithm will automatically adjust the client’s asset allocation. Any change to the Investment Objective directed by a client due to changes in the Client’s risk tolerance and/or Retirement Age will require written approval from the client and NWMG before implementation. Failure to approve the change in Investment Objective may result in a client remaining in a Model Portfolio that is no longer aligned with the applicable Client Profile. The Investment Objective selected for the account is an overall objective for the entire account and may be inconsistent with a particular holding and the account’s performance at any time and may be inconsistent with other asset allocations suggested to client by LPL, NWMG or prior to client entering into the Account Agreement. Achievement of the stated investment objective is a long-term goal for the account, and asset withdrawals may impair the achievement of client’s investment objectives. A Client Profile that includes a conservative risk tolerance over a long-term investment horizon may result in the selection of an Investment Objective that is riskier than would be selected over a shorter-term investment horizon. Clients should contact NWMG if they believe the Investment Objective does not appropriately reflect the Client Profile, such as their risk tolerance. o By executing the Account Agreement, clients authorize LPL and NWMG to have discretion to buy and sell only open-end mutual funds (“Mutual Funds”) and exchange-traded funds (“ETFs”) (collectively, “Program Securities”) according to the Model Portfolio selected and, subject to certain limitations described in the Account Agreement, hold or liquidate previously purchased non-model securities that are transferred into the account (“Legacy Securities”). In order to be transferred into an account, Legacy Securities must be Mutual Funds with which LPL has a full or partial selling agreement, ETFs or individual U.S. listed stocks. Securities that are not Program Securities included within the Model Portfolio will not be purchased for an account, and, in its sole discretion, will determine whether to hold or sell Legacy Securities, generally, but not solely, with the goal of optimizing tax impacts for accounts that are subject to tax. Additional Legacy Securities will not be purchased for the account. Clients may not impose restrictions on liquidating any Legacy Securities for any reason. Clients should not transfer in Legacy Securities that they are not willing to have liquidated at the discretion of LPL. o In addition, uninvested cash may be invested in money market funds, the Multi-Bank Insured Cash Account (“ICA”) or the Deposit Cash Account (“DCA”), as applicable, as described in the Account Agreement. Dividends paid by the Program Securities in the account will be contributed to the cash allocation and ultimately reinvested into the account based on the Model Portfolio once the tolerance within cash allocation is surpassed. o Pursuant to the Account Agreement, NWMG is authorized to perform tax harvesting when deemed acceptable by the Algorithm. None of the client, NWMG or LPL can alter trades made for tax harvesting purposes. In order to permit trading in a tax-efficient manner, the Account Agreement also grants the authority to select specific tax lots when liquidating securities within the account. Although the Algorithm attempts to achieve tax efficiencies, by doing so the client’s portfolio may not directly align with Model Portfolio. As a result, the client may receive advice that differs from the advice received by accounts using the same Model Portfolio, and the client’s account may perform differently than other accounts using the same Model Portfolio. o During the term of the Account Agreement, the manager will perform a daily review of the account to determine if rebalancing is appropriate based on tolerance thresholds established by LPL. At each rebalancing review, the account will be rebalanced if at least one of the account positions is outside such thresholds, subject to a minimum transaction amount established by LPL. In addition, LPL may review the account for rebalancing in the event that the Portfolio Strategist changes a Model Portfolio, which may delay placing rebalancing transactions for non- qualified accounts by a number of days, to be determined by , in an attempt to limit short-term tax treatment for any position being sold. In addition, trading in the account at any given time is also subject to certain conditions, including but not limited to, conditions related to trade size, compliance tests, the target cash allocation and allocation tolerances. None of the client, NWMG or LPL can alter the rebalancing frequency.  Selection of as Third-Party Robo Advisor - Under NWMG agreement with LPL, NWMG was provided the opportunity to offer GWP, which utilizes ’s Algorithm as described herein, to prospective clients. National Wealth Management Group, LLC. (NWMG) is not otherwise affiliated with LPL.  National Wealth Management Group, believes that certain clients will benefit from GWP’s advisor- enhanced advisory services, particularly due to the relatively low minimum account balance and the combination of a digital advice solution with access to an advisor. Unlike direct-to-consumer Robo platforms, NWMG is responsible on an ongoing basis as investment advisor and fiduciary for the client relationship, including for recommending the program for the client; providing ongoing monitoring of the program, the performance of the account, the services of LPL; determining initial and ongoing suitability of the program for the client; reviewing clients’ suggested portfolio allocations; reviewing and approving any change in Investment Objective due to changes clients make to their Client Profile; answering questions regarding the program, assisting with paperwork and administrative and operational details for the account; and being available to clients to discuss investment strategies, changes in financial circumstances, objectives or the account in general in person or via telephone. National Wealth Management can also recommend other suitable investment programs if clients have savings goals or investment needs for which GWP is not the optimal solution. Schwab Managed Account Platforms The Managed Account Select® (“Select”) and Managed Account Access® (“Access”) programs make up Schwab’s single-contract offering. Select and Access are wrap fee programs that offer brokerage, custody, and money manager (“manager”) services. Schwab Institutional Intelligent Portfolios National Wealth Management Group offers an automated investment program (the "Program") through which clients are invested in a range of investment strategies we have constructed and manage, each consisting of a portfolio of exchange traded funds ("ETFs") and a cash allocation. The client may instruct us to exclude up to three ETFs from their portfolio. The client's portfolio is held in a brokerage account opened by the client at Charles Schwab & Co., Inc. ("CS&Co"). National Wealth Management Group uses the Institutional Intelligent Portfolios® platform ("Platform"), offered by Schwab Performance Technologies ("SPT”), a software provider to independent investment advisors and an affiliate of CS&Co., to operate the Program. National Wealth Management Group is independent of and not owned by, affiliated with, or sponsored or supervised by SPT, CS&Co., or their affiliates (together, "Schwab"). National Wealth Management Group is the client's investment advisor and responsible for determining the appropriateness of the Program for the client, choosing a suitable investment strategy and portfolio for the client's investment needs and goals, and managing that portfolio on an ongoing basis. National Wealth Management Group has contracted with SPT to provide the Platform, which consists of technology and related trading and account management services for the Program. The Platform enables National Wealth Management Group to make the Program available to clients online and includes a system that automates certain key parts of our investment process (the "System"). The System includes an online questionnaire that helps to determine the client's investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that National Wealth Management Group will recommend a portfolio via the System in response to the client’s answers to the online questionnaire. The client

may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but National Wealth Management Group then makes the final decision and select a portfolio based on all the information we have about the client. The System also includes an automated investment engine through which client portfolios are managed on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). National Wealth Management does not pay SPT fees for the Platform so long as we maintain $100 million in client assets in accounts at CS&Co. that are not enrolled in the Program. If we do not meet this condition, then we pay SPT an annual licensing fee of .10% (10 basis points) on the value of our clients' assets in the Program. This fee arrangement gives us an incentive to recommend or require that our clients with accounts not enrolled in the Program be maintained with CS&Co. D. Wrap Fee Programs National Wealth Management Group includes securities transaction fees together with its investment advisory fees. Including these fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes its investment management services for its Clients. The Advisor sponsors the NWMG Wrap Fee Programs solely as a supplemental disclosure regarding the combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid its own transaction fees. Please see Appendix 1 –Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure. E. Assets Under Management As of December 31, 2023 National Wealth Management Group manages the following assets: Assets Under Management Assets Discretionary Assets $295,347,196 Non-Discretionary Assets $1,505,159 Total $296,852,355  Investment advisor representatives of NWMG also provide consulting services to variable annuity assets under advisement held in brokerage accounts at LPL Financial that are not actively managed, there is no trading authority and no advisory fee. Clients may request more current information at any time by contacting the Advisor. F. Retirement Plan Consulting Investment advisor representatives of NWMG may assist clients that are trustees or other fiduciaries to retirement plans (“Plans”) by providing fee-based consulting and/or advisory services. Investment advisor representatives may perform one or more of the following services, as selected by the client in the client agreement:  Assistance in the preparation or review of an investment policy statement (“IPS”) for the Plan based upon consultation with client to ascertain Plan’s investment objectives and constraints.  Acting as a liaison between the Plan and service providers, product sponsors or vendors.  Ongoing monitoring of investment manager(s) or investments in relation to the criteria specified in the Plan’s IPS or other written guidelines provided by the client to IAR.  Preparation of reports describing the performance of Plan investment manager(s) or investments, as well as comparing the performance to benchmarks.  Ongoing recommendations, for consideration and selection by client, about specific investments to be held by the Plan or, in the case of a participant-directed defined contribution plan, to be made available as investment options under the Plan.  Education or training for the members of the Plan investment committee with regard to various matters, including plan features, retirement readiness matters, service on the committee, and fiduciary responsibilities.  Assistance in enrolling Plan participants in the Plan, including conducting an agreed upon number of enrollment meetings. As part of such meetings, IARs may provide participants with information about the Plan, which may include information on the benefits of Plan participation, the benefits of increasing Plan contributions, the impact of pre-retirement withdrawals on retirement income, the terms of the Plan and the operation of the Plan. If the Plan makes available publicly traded employer stock (“company stock”) as an investment option under the Plan, investment advisor representatives do not provide investment advice regarding company stock and are not responsible for the decision to offer company stock as an investment option. In addition, if participants in the Plan may invest the assets in their accounts through individual brokerage accounts, a mutual fund window, or other similar arrangement, or may obtain participant loans, investment advisor representatives do not provide any individualized advice or recommendations to the participants regarding these decisions. Furthermore, investment advisor representatives do not provide individualized investment advice to Plan participants regarding their Plan assets. In addition, if client elects to engage an Investment Advisor Representative to perform ongoing investment monitoring and ongoing investment recommendation services to a Plan subject to ERISA in the client agreement, such services will constitute “investment advice” under Section 3(21)(A)(ii) of ERISA. Therefore, the investment advisor representatives will be deemed a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of ERISA in connection with those services. Clients should understand that to the extent the IAR is engaged to perform services other than ongoing investment monitoring and recommendations, those services are not “investment advice” under ERISA and therefore, the IAR will not be a “fiduciary” under ERISA with respect to those other services. From time to time the NWMG may make the Plan or Plan participants aware of and may offer services available from IAR that are separate and apart from the services provided under Retirement Plan Consulting. Such other services may be services to the Plan, to a client with respect to client's responsibilities to the Plan and/or to one or more Plan participants. In offering any such services, the IAR is not acting as a fiduciary under ERISA with respect to such offering of services. If any such separate services are offered to a client, the client will make an independent assessment of such services without reliance on the advice or judgment of the IAR. Such service may include:  Assistance with investment education seminars and meetings for Plan participants. Such meetings may be on a group or individual basis, and may include information about the investment options under the Plan (e.g., investment objectives, risk/return characteristics, and historical performance), investment concepts (e.g., diversification, asset classes, and risk and return), and how to determine investment time horizons and assess risk tolerance. Such meetings do not include specific investment advice about investment options under the Plan as being appropriate for a particular participant.  Assistance at client’s direction in making changes to investment options under the Plan.  As part of the ongoing investment recommendation service set out above, assistance in identifying investment options in connection with the “broad range” requirement of Section 404(c) of the Employee Retirement Income Security Act of 1974 (“ERISA”).  As part of the ongoing investment recommendation service set out above, assistance in identifying an investment fund product or model portfolio in connection with the definition of a “Qualified Default Investment Alternative” (“QDIA”) under ERISA.  Assistance with the preparation, distribution and evaluation of Request for Proposals, finalist interviews, and conversion support in connection with vendor analysis and service provider support.  Preparation of comparisons of Plan data (e.g., regarding fees and services and participant enrollment and contributions) to data from the Plan’s prior years and/or a benchmark group of similar plans.  Assistance in identifying the fees and other costs borne by the Plan for, as specified by client, investment management, recordkeeping, participant education, participant communication and/or other services provided with respect to the Plan. G. Plan Participant Advisory Services (PPAS) Investment advisor representatives of NWMG, can be engaged to provide asset allocation and/or specific investment recommendations for retirement plan assets based on the investment options available and the financial information provided by the client. The Investment Advisor Representative tailors the recommendation to the individual needs of the client based upon their investment objectives. Depending on the available options offered by the plan custodian, investment advisor representatives may have discretionary authority to directly execute trades on behalf of clients or the client may retain the sole responsibility for determining whether to implement any recommendations and for placing transactions. The Investment Advisor Representative is responsible for determining the fee to charge each client based on factors such as total amount of assets involved in the relationship and the complexity of the services. Clients should consider the level and complexity of the services to be provided when negotiating the fee with IAR. Clients pay the fee by a check made payable to National Wealth Management Group. The client may terminate the arrangement at any time, and may request a refund of unearned fees, if any, based on the time and effort completed prior to the termination of the agreement. The agreement terminates upon delivery of a written or verbal recommendation. No refunds will be made after delivery of the recommendation, except when the number of actual hours is less than the estimated number of hours expected. H. Variable Sub-Account Management Services National Wealth Management Group is available to manage variable annuity and/or variable life sub- accounts by selecting, monitoring and exchanging as necessary between the available investment choices. Sub-accounts are managed based on a particular client’s financial goals, risk tolerance and time horizon while taking into account certain restrictions. I. Financial Planning Services National Wealth Management Group will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals, objectives and financial situation. A particular client’s financial plan will include the relevant types of planning specific to their needs and objectives such as:  Business Succession – planning for the continuation of a business in a smooth a transition as possible with the use of buy-sell agreements, key-man insurance and engaging independent legal counsel as needed.  Cash Flow/ Budget Planning – planning to manage expenses against current and projected income.  College / Education – planning to pay the future college / education expenses of a child or grandchild.  Divorce – planning for the financial impact of divorce such as change in income, retirement benefits and tax considerations.  Estate Planning – planning that focuses on the most efficient and tax friendly option to pass on an estate to a spouse, other family members or a charity.  Final Expenses – planning to leave assets to cover final expenses such as funeral, debts and potential business continuity.  Insurance Needs – planning for the financial needs of survivors to satisfy such financial obligations as housing, dependent childcare and spousal arrangements as well as education.  Investment Planning – planning an investment strategy consistent with some particular objectives, time horizons and risk tolerances.  Major Purchase – Evaluation of the pros and cons of home ownership verse renting as well as buying or leasing a car, for example.  Retirement – planning an investment strategy with the objective of providing inflation- adjusted income for life.  Tax Planning – planning a tax efficient investment portfolio to maximize deductions and off- setting losses.  Wealth Accumulation – planning to build wealth within a portfolio that takes into consideration risk tolerance and time horizon. The services take into account information collected from the client such as financial status, investment objectives and tax status, among other data. Fees for such services are negotiable and detailed in the client agreement. The financial plan may include generic recommendations as to general types of investment products or specific securities which may be appropriate for the Client to purchase given his/her financial situation and objectives. The Client is under no obligation to act upon the investment adviser’s recommendation or purchase such securities. However, if the Client desires to purchase securities or advisory services in order to implement his/her financial plan, NWMG may make a variety of products and services available through its IARs. This may result in the payment of normal and customary commissions, advisory fees or other types of compensation to National Wealth Management Group, LLC and the investment advisor representative. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. J. Coaching Services Once a financial plan has been created, you may engage NWMG for ongoing coaching. This differs from the financial planning process in that the wealth coach or stewardship coach is engaged to help you make progress toward your stated goals. Coaching is intended to assist you to stay on a prescribed plan for working toward financial goals Additionally, coaching may help reduce the frequency of needed financial plan updates. Coaching services may include one or more of the following services, as elected by the client on the coaching services agreement. o BUCKETGRAM COACHING - We use your personalized version of the Bucketgram, a pictorial document that summarizes your assets, liabilities, insurances and estate planning documents, to help identify areas of opportunity or concern in your financial journey. First Year  Investment Coaching  Up to 4 meeting per year (if necessary)  Utilization of Bucketgram for prudent financial decision-making Additional Years After 1st  Investment Coaching  Quarterly or semi-annual meetings  Ongoing updates to Bucketgram  Utilization of Bucketgram for prudent financial decision-making  Cash flow analysis and planning o WEALTH COACHING - We begin by helping you identify your most important life goals and continue with the development of your personal values based financial planning and maintenance of the strategies to help you work toward your financial goals. Emphasis is placed on taking you through the Wealth Optimization Process: Discovery -- Planning -- Implementation -- Maintenance. Maintenance Wealth Coaching - uses the final stage of the Wealth Optimization Process (Maintenance) to monitor and maintain the financial path that has been created.  Investment coaching  Semi-annual meetings (more if needed)  Quarterly snapshots and client planning portal maintenance  Values based financial planning is aggregated with eMoney,Money Guide Pro, Right Capital, Orion Planning, or Asset Map, or Holistaplan  No new concepts presented, only maintenance of current strategies Active Wealth Coaching - uses all 4 stages of the Wealth Optimization Process (Discovery, Planning, Implementation, and Maintenance) to create new strategies and discover new opportunities to build your financial future.  Investment coaching  Quarterly meetings  Quarterly snapshots  Tax Review Family Office Coaching - that focuses on Intergenerational Stewardship Coaching and may involve multiple households within a family.  Investment coaching  Monthly telephone calls to review status/progress updates with patriarch/matriarch  Quarterly intergenerational stewardship coaching with patriarch/matriarch (more if necessary) Annual family meeting with appropriate intergenerational involvement  Optional mentoring for next generation stewards (Proverbs 20:21, Proverbs 13:22)  Quarterly snapshots  Coordination of entire financial team  Ongoing use the Wealth Optimization Process  Tax Review Stewardship Coaching- an optional service available that helps you to understand integration of faith and finances as it pertains to all topics discussed using a biblical world view. There is no additional charge for this style of coaching. You need only to make your advisor aware of your desire for Stewardship Coaching. K. Trust & Will National Wealth Management Group can offer estate planning services to clients that consist of education on estate planning topics and the collection of general information necessary to complete a new estate plan or review a current estate plan. National Wealth Management Group can also assist a client in gathering the required information needed by an independent third-party estate planning firm4. Any and all fees paid by the client for outside services can be paid to the provider directly or depending on the client specific agreement such fees can be paid by National Wealth Management Group. L. Hourly Consulting Services National Wealth Management Group representatives, may can provide consulting services including, as selected by the client in the consulting agreement, advice regarding tax planning, investment planning, retirement planning, estate planning, cash flow/budget planning, business planning, education planning, and personal financial planning. The services take into account information collected from the client such as financial status, investment objectives and tax status, among other data. Investment Advisor Representatives may or may not deliver to the client a written analysis or report as part of the services. Investment Advisor Representatives tailor the hourly consulting services to the individual needs of the client based on the investment objective chosen by the client. The engagement terminates upon final consultation with the client. Fees for such services are negotiable and detailed in the client agreement. M. Portfolio Review Service – “Second Opinion Analysis” Within the scope of the NWMG hourly consulting services, an Investment Advisor Representative can perform a review, or an existing portfolio held elsewhere. The purpose of the review would be to evaluate the appropriateness of portfolio holdings based on a client’s investment objective, time horizon and risk tolerance. Clients will have the option to reallocate positions, as appropriate, with their current custodian or they can bring the account to NWMG, who can manage the account accordingly. N. Third Party Advisory Services National Wealth Management Group can establish agreements with a third-party adviser where that Adviser offers various types of directly sponsored programs. All third-party investment advisers to whom NWMG may refer clients will be licensed as investment advisers by their resident state and any applicable jurisdictions or Registered Investment Advisers with the SEC. After gathering information about a client's financial situation and investment objectives, NWMG may assist the client in selecting a particular third-party program. National Wealth Management Group receives compensation pursuant to its agreements with these third-party advisers for introducing clients to these third-party advisers and 4 Certain Investment Advisor Representatives, that are not dually registered as Registered Representatives of a broker/dealer utilize the services of Trust & Will, a third-party digital estate planning service for clients who have the need for estate planning review, creation or updates (https://trustandwill.com/). Clients are not required to utilize any third-party products, services or referrals and can select the service provider of their choice. The introduction and/or use of such service providers does not amount to the practice of law; National Wealth Management Group does not provide legal services. for certain ongoing services provided to clients. Fees shared will not exceed with any limit imposed by any federal and/or state regulatory agency. This compensation is disclosed in a separate disclosure document and is typically equal to a percentage of the investment advisory fee charged by that third-party adviser or a fixed fee. The disclosure document provided by NWMG will clearly state the fees payable to NWMG and the impact to the overall fees due to these payments. Since the compensation paid to NWMG may differ depending on the agreement with each third-party adviser, NWMG has an incentive to recommend one third-party advisers over another however the firm has a fiduciary duty to act in the best interests of the client. Clients who are referred to third-party investment advisers will receive full disclosure, including services rendered and fee schedules, at the time of the referral, by delivery of a copy of the relevant third-party adviser's Form ADV 2A as well as the Form ADV 2A for NWMG. In addition, if the investment program recommended to a client is a wrap fee program the client will also receive the wrap fee program brochure provided by the sponsor of the program. Clients will be required to enter into an advisory agreement and complete other account specific documents with the third-party money manager in order to establish an account. While NWMG will assist in determining an appropriate third-party adviser, NWMG does not participate in the management of account established with a third-party money manager. O. IRA Rollover Considerations When National Wealth Management Group provides investment advice to clients regarding retirement plan accounts or individual retirement accounts the firm 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 National Wealth Management Group make money creates some conflicts with a client’s interests, so National Wealth Management Group operates under a special rule that requires the firm to act in a client’s best interest and not put the firm’s interests ahead of a client. Alternatively, National Wealth Management Group can provide an education only approach regarding rolling over assets to an individual retirement account ("IRA") that the firm can manage on a behalf of a client. Educated clients that elect to rollover assets to an IRA will pay an asset management fee, which is a conflict of interest. Clients are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of each. An employee will typically have four options: 1. Leaving the funds in your employer's (former employer's) plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an IRA for us to manage here are a few points to consider before you do so: 1. Determine whether the investment options in your employer's retirement plan address your needs or whether you might want to consider other types of investments.  Employer retirement plans generally have a more limited investment menu than IRAs.  Employer retirement plans may have unique investment options not available to the public such as employer securities, or previously closed funds. 2. Your current plan may have lower fees than our fees. 3. Our strategy may have higher risk than the option(s) provided to you in your plan. 4. Your current plan may also offer financial advice. 5. If you keep your assets titled in a 401k or retirement account, participants could potentially delay their required minimum distribution beyond age 70½. 6. A 401(k) may offer more liability protection than a rollover IRA; each state may vary.  Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies.  However, there can be some exceptions to the general rules so you should consult with an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. Participants may be able to take out a loan on your 401k, but not from an IRA. 8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or the purchase of a home. 9. If company stock is owned in a plan, participants may be able to liquidate those shares at a lower capital gains tax rate. 10. Plans may allow NWMG to be hired as the manager and keep the assets titled in the plan name. It is important to understand the differences between these types of accounts and to decide whether a rollover is the best option. Prior to proceeding, if you have questions contact your Investment Adviser Representative, or call our main number as listed on the cover page of this brochure. If an Investment Advisor Representative (IAR) with NWMG recommends that a client roll over their retirement plan assets, such a recommendation creates a conflict of interest because NWMG and that IAR will earn an advisory fee on the rolled over assets. No client is under any obligation to rollover retirement plan assets to an account managed by NWMG. National Wealth Management Group’s Chief Compliance Officer, Benjamin J. Jones, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. P. Unaffiliated Third-Party Technology Resources National Wealth Management Group has incorporated certain third-party technology resources to help manage operations and regulatory Compliance. Orion Portfolio Solutions, LLC Orion Portfolio Solutions is a turnkey asset management program and investment manager that exists to help advisors manage their clients, investments and business with confidence. Through a proprietary SMA optimization platform, Orion Portfolio Solutions delivers and manages a suite of custom stock and direct indexing portfolios. A tech-focused approach enables personalized portfolio design, enhanced tax management capabilities and agile model creation to align with current market dynamics. Schwab Advisor Services provides Orion Portfolio Solutions with access to its institutional brokerage, trading, custody, reporting and related services, many of which are not typically available to Schwab retail customers. Q. Conflicts of Interest Under federal and state law, National Wealth Management Group is a fiduciary and must fully disclose all material facts relating to an advisory relationship. As a fiduciary, the firm seeks to avoid conflicts of interest or, at a minimum, make full disclosure to provide sufficiently specific facts for clients to understand and appreciate the risk associated with a conflict of interest. The disclosure goal is to allow clients to provide informed consent or to decide not to engage National Wealth Management Group for services. Clients are encouraged to consider and ask questions about the select conflicts of interest listed below. Insurance Products Investment advisor representatives of National Wealth Management Group can also be insurance agents able to sell insurance products for commission compensation.  Advisory fees are not charged on funds used to purchase insurance products.  Advisory fees are not reduced due to compensation received for insurance commissions.  The receipt of commissions provides an incentive to purchase insurance products.  Advisory fees are not reduced due to commission compensation received. Money Managers and Product Sponsors Investment advisor representatives will, on occasion, have an opportunity to attend a training event or participate in a due diligence visit where the Money Manager or Product Sponsor will cover the associated travel expenses such as airfare, hotel and meals. Training opportunities are often held at luxury resorts where amenities such as golf, spas and entertainment are provided. Such accommodations represent a conflict of interest that can influence the evaluation of the Money Manager or Product sponsor based on factors other than the quality of services. Additional Compensation National Wealth Management Group can receive an economic benefit for providing advisory services from sources other than the client. Economic benefits include sales awards and gifts, an occasional meal, as well as entertainment such as a concert, show or sporting event. Such compensation is not directly related to the advice or services provided to a particular client, but it does create a conflict of interest that can influence the selection of services based on the compensation received. Industry Professionals When it is in the best interests of the client, National Wealth Management Group can introduce the services of other professionals for certain non-investment purposes (i.e., attorneys and accountants). In particular, Clients can receive tax preparation services as a complementary or discounted service through a separate legal entity subsidiary, Alpina Tax & Accounting Services (ATAS). Introductions represent a conflict of interest because they create a relationship where the other professional has an implied obligation to introduce potential new clients to National Wealth Management Group. Clients are under no obligation to engage the services of any such professional. If the client engages any such professional, and a dispute arises, any recourse will be exclusively from and against the engaged professional. Financial Planning Depending on the type of account that could be used to implement a financial plan, compensation can include (but is not limited to) advisory fees, advisory program wrap fees; commissions; mark-ups and mark-downs; transaction charges; confirmation charges; small account fees; mutual fund 12b-1 fees; mutual fund sub-transfer agency fees; hedge fund, managed futures, and variable annuity investor servicing fees; retirement plan fees; fees in connection with an insured deposit account program; marketing support payments from mutual fund, annuity and insurance sponsors; administrative servicing fees for trust accounts; referral fees; compensation for directing order flow; and bonuses, awards or other things of value. To the extent that IAR recommends that Client invest in products and services that will result in compensation being paid to NWMG and the IAR, this presents a conflict of interest. This compensation to IAR and NWMG may be more or less depending on the product or service that IAR recommends. Therefore, the IAR has a financial incentive to recommend that a financial plan be implemented using a certain product or service over another product or service. Clients are under no obligation to act upon the recommendations contained in a financial plan. If the client elects to act on any of the recommendations, there is under no obligation to affect the transaction through the investment adviser. Conflicts of interest are mitigated by the fiduciary duty to always act in a client’s best interest and acting accordingly. Benjamin Jones, the Chief Compliance Office, is available to discuss any concerns that exist due to a conflict of interest.