ALERA GROUP, INC.

Advanced Capital Group Form ADV Part 2 | Firm Brochure 50 South Sixth Street, Suite 975 Minneapolis, MN 55402 TF: 866-225-5224 T: 612-230-3000 F: 612-230-3019 www.acgbiz.com March 31, 2025 This brochure provides information about the qualifications and business practices of Advanced Capital Group, Inc. (“ACG” or the “Advisor”). If you have any questions or concerns about the contents of this brochure, please contact us at (866) 225-5224 or (612) 230-3000. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about ACG is also available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for ACG is 109673. ACG is an SEC Registered Investment Adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training.  IARD/CRDNo: 109673 Advanced Capital Group, Inc. Form ADV Part 2A SEC File No.: 801- 69544 03/31/2025 Brochure Item 2: Material Changes ACG updates this document annually or more frequently in the event of certain material changes. This section outlines and summarizes the specific changes made since the document’s previous update. Effective March 31, 2025, Lyndsay Kim has been appointed as the Chief Compliance Officer of ACG. ACG will deliver a copy of this Part 2A to its clients within 120 days of the close of its fiscal year to make sure clients are aware of any material changes to the firm’s business philosophies and practices. ACG’s clients may request a full copy of the latest version of this document at any time by contacting Lyndsay Kim, Chief Compliance Officer, at 847-944-1417 or Lyndsay.Kim@aleragroup.com. 2  Advanced Capital Group, Inc. IARD/CRD No: 109673 Form ADV Part 2A SEC File No.: 801- 69544 Brochure 3/31/2025 Item 3: Table of Contents Item 2: Material Changes ........................................................................................................................................... 2 Item 3: ......................................................................................................................................................................... 3 Table of Contents ........................................................................................................................................................ 3 Item 4: Advisory Business ........................................................................................................................................... 5 1. Institutional Investment Consulting .............................................................................................................. 5 Employer-sponsored Retirement Plans ............................................................................... 5 Plan Benchmarking ............................................................................................................. 5 Endowments/Foundations ................................................................................................... 5 Native American Tribal Councils ....................................................................................... 6 2. Institutional Investment Management .......................................................................................................... 6 Asset Liability Immunization Strategy (ALIS) ................................................................... 6 3. Financial Wellness ........................................................................................................................................ 6 4. Individual Wealth Management .................................................................................................................... 7 Wealth Management Services ............................................................................................. 7 Compliance with PTE 2020-02 ........................................................................................... 7 Intelligent Portfolios ............................................................................................................ 8 FlexPath Managed Account Services .................................................................................. 9 DPL Financial Partners ....................................................................................................... 9 Risk of Loss......................................................................................................................... 9 Amount of Managed Assets ................................................................................................ 9 Item 5: Fees and Compensation .............................................................................................................................. 10 1. Institutional Investment Consulting ............................................................................................................ 10 2. Institutional Investment Management ........................................................................................................ 11 3. Financial Wellness ...................................................................................................................................... 11 4. Individual Wealth Management .................................................................................................................. 11 Item 6: Performance-Based Fees and Side-By-Side Management ........................................................................ 11 Item 7: Types of Clients ............................................................................................................................................ 11 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ...................................................................... 11 1. Methods of Analysis ................................................................................................................................... 11 5. Investment Strategies.................................................................................................................................. 12 2. Risk of Loss ................................................................................................................................................ 13 Pooled Funds Risk ............................................................................................................ 13 Management Risk ............................................................................................................. 13 Fixed Income Securities .................................................................................................... 13 3  Advanced Capital Group, Inc. IARD/CRD No: 109673 Form ADV Part 2A SEC File No.: 801- 69544 Brochure 3/31/2025 MBS & CMOs .................................................................................................................. 14 Government Securities Risk ............................................................................................. 15 Systems and Operational Risks Generally ........................................................................ 15 Wealth Management ......................................................................................................... 15 Item 9: Disciplinary Information ............................................................................................................................. 16 Item 10: Other Financial Industry Activities and Affiliations ............................................................................... 16 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................. 16 1. Code of Ethics ............................................................................................................................................ 16 2. Personal Trading with Material Interest..................................................................................................... 16 3. Personal Trading in the Same Securities as Clients ................................................................................... 16 4. Personal Trading at Same Time as Clients ................................................................................................ 17 Item 12: Brokerage Practices ................................................................................................................................... 17 Item 13: Review of Accounts .................................................................................................................................... 17 Item 14: Client Referrals and Other Compensation ............................................................................................... 17 Item 15: Custody ....................................................................................................................................................... 18 Item 16: Investment Discretion ............................................................................................................................... 18 1. Institutional Investment Consulting ........................................................................................................... 19 2. Institutional Investment Management ........................................................................................................ 19 3. Individual Wealth Management ................................................................................................................. 19 Item 17: Voting Client Securities .............................................................................................................................. 19 Item 18: Financial Information ................................................................................................................................ 19 4  Advanced Capital Group, Inc. IARD/CRD No: 109673 Form ADV Part 2A SEC File No.: 801- 69544 Brochure 3/31/2025 Item 4: Advisory Business ACG is an Investment Advisor registered with the SEC. ACG has no broker-dealer affiliation and accepts no commissions from registered products. ACG was incorporated in Minnesota in 1998 and is a wholly owned subsidiary of Alera Group, Inc. ACG has four (4) distinct practice lines: Institutional Investment Consulting Institutional Investment Management Individual Wealth Management 1. 2. 3. Financial Wellness 4. 1. Institutional Investment Consulting In its Institutional Investment Consulting practice, ACG advises clients on the hiring, monitoring, and replacing of third-party Investment Managers, principally in the form of mutual funds and pooled products like separate accounts and collective investment trusts. Employer-sponsored Retirement Plans The biggest component (measured in assets-under-management) of this practice is employer sponsored retirement plans that are regulated by the Employee Retirement Income Security Act of 1974 (“ERISA”). In turn, most of those plans are participant directed retirement plans (401(k), 403(b), and 457) for which ACG also provides (at the option of the Plan Sponsor) participant investment education and financial wellness. ACG provides a variety of coordinated financial services to assist retirement plan participants (“participants”) with financial wellness and retirement planning through employee education sessions and investment portfolio design meant to meet the provisions of the Department of Labor’s (“DOL”) Interpretive Bulletin 96-1. In addition to participant-directed retirement plans, ACG also works with employer-sponsored traditional defined benefit plans such as cash balance defined benefit plans and 409A supplemental executive compensation plans. ACG will serve as either an ERISA Section 3(21) and/or 3(38) fiduciary investment adviser. An example of the foregoing would be whereby ACG acts as a section 3(21) co-fiduciary for the selection and monitoring of the plan’s “Designated Investment Alternatives” (DIAs) (as that term is described in 29 CFR 2550.404a-5). (ACG’s section 3(38) services are described hereinafter after in Item #16). Plan Benchmarking Besides providing investment advice, ACG is often asked to help a client benchmark its retirement plan. The scope of that exercise will reflect the needs of the plan client. Endowments/Foundations Another line of business where ACG provides institutional investment consulting is endowments/foundations. ACG uses a four-part approach to endowment/foundation investment consulting methodology - strategic asset allocation, customized cash management, passive/active manager selection/monitoring, and tactical reallocation. Many endowments/foundations have annualized (or smoothed) distribution targets but making distributions in a down market can have profound and long-lasting negative and compounded effects particularly if during the same down market donor contributions slow or cease altogether. While alternative asset class discussions dominate many conversations about endowment/foundation investments, ACG stresses the importance of 5  Advanced Capital Group, Inc. IARD/CRD No: 109673 Form ADV Part 2A SEC File No.: 801- 69544 Brochure 3/31/2025 judicious cash management and uses years of experience building strategic asset allocation portfolios and selecting and monitoring investment managers (both passive and active). Finally, endowments/foundations can tactically reallocate their investments without the requisite time delays incumbent on retirement plans because of the necessary participants’ notices. Native American Tribal Councils Our final area of institutional investment consulting is with Native American Tribal Councils. Initiatives and priorities can vary. Several disparate examples might include retirement plans for casino employees, minor’s trusts, trusts to purchase reservation lands from non-tribal members, or cash funds for ongoing construction projects. 2. Institutional Investment Management In its Investment Management practice, ACG buys and sells individual securities, almost exclusively fixed- income products. In that practice, it works with institutional clients such as pension plans, banks, and insurers. To illustrate, ACG might be hired by a bank to help manage its capital reserves. In that role, the bank might ask whether ACG will conduct independent credit analysis on its holdings to alleviate the bank from relying solely upon credit rating agencies. ACG might also be asked to measure the “efficiency” of individual holdings in the context of their capital discount weightings. Ongoing, ACG might be asked to make asset class relative value analysis in the context of prevailing and forecasted interest rates. Asset Liability Immunization Strategy (ALIS) Advanced Capital Group’s Asset Liability Immunization Strategy (ALIS) is an investment allocation methodology for pension plans seeking to stabilize their funding ratio and future contributions versus traditional pension plan management. The approach to de-risking a pension plan is through the creation of a custom glide path where a plan sponsor determines a set of targeted asset allocation levels as the plan’s funding ratio improves. Recognizing that all plans are different, the glide path should begin with an understanding of the long-term funding goal of the plan. From there, a dynamic glide path based on the funding level and ability to accept risk and return can be developed. Current strategies typically rely on some form of a pooled fixed income index product to construct the immunization strategy. Although an improvement in strategy creates the possibility of a duration mismatch in key duration segments or buckets due to the index construction. To counter that risk, ACG’s Institutional Investment Management team will construct a custom allocation that attempts to optimize the match between a plan’s liability duration buckets and asset durations. This customization can enhance the effectiveness of a plan’s overall hedge ratio and is designed to immunize the portfolio against interest rate shocks due to duration mismatch. All asset management services are included in ACG’s stated advisory fee. 3. Financial Wellness The Well is a financial wellness suite of services built by ACG to help answer and support participants financial questions and goals no matter their stage of life. Financially stressed participants cost employers thousands of dollars in lost productivity and increased medical costs. Debt burdens, paying for college, or wondering if retirement is possible can compile to make participants financially unwell and distracted at work. Education, inspiration, and tools aim to get participants on track to healthier financial lives. Education consultations and The Well are more than employee financial education; they help participants take action, no matter their stage of life. Financial wellness benefits aim to increase participation in employer-sponsored retirement plans, reduce medical costs, increase employee productivity 6  Advanced Capital Group, Inc. IARD/CRD No: 109673 Form ADV Part 2A SEC File No.: 801- 69544 Brochure 3/31/2025 and engagement, and act as a powerful recruiting and retention tool. The Well has three parts which can be offered independently or in tandem: 1. Group education can be tailored to your retirement plan and delivered in-person or online. Partial and full- day options are available and may include one-on-one retirement-related Q&A. Foundational education topics include: • Your Retirement Plan - Help participants make the most of their plan • Finances for Life Planning - Inspire participants to manage their finances • Pre-Retirement Planning - Strategies to leverage retirement savings • Legacy Planning - Prepare for life after work 2. Interactive Learning Modules deliver engaging and personalized learning through bite-sized modules on a variety of topics like budgeting, building emergency savings, considering home ownership, funding higher education and more. The mobile-friendly platform can : Include personalized and group educational materal 5. Be customizable and able to incorporate your unique benefits 6. Be supported by implementation, promotion, and marketing collateral 7. 3. Personal Financial Advice can give participants the freedom and flexibility to receive individualized guidance on financial topics that matter most to them, via one-on-one consultations with a supervised person of ACG. Personal financial advisory offers: Industry leading, goals-based planning software • Comprehensive and goal-based planning—including live assistance for specific questions • Unbiased and tailored advice from a fiduciary, based on their best interest • 4. Individual Wealth Management Wealth Management Services In its Individual Wealth Management practice, ACG services clients who engaged ACG directly or were introduced to ACG through the individual’s participation in a retirement plan that is also served by ACG. As part of our wealth management services, we conduct at least one initial meeting with clients to understand their current financial situation, existing resources, financial goals, and tolerance for risk. Based on what we learn, we propose an investment approach to the client. Upon the client’s agreement with the proposed investment plan, we work with the client to establish or transfer investment accounts so that we can manage the client’s portfolio. Once the relevant accounts are under our management, we review such accounts on a regular basis. We may periodically rebalance or adjust client accounts under our management. When a client experiences any significant changes to his/her financial or personal circumstances, the client must notify us so that we can consider such information in managing the client’s investments. Under certain circumstances, financial planning services will be provided at no additional cost to our Wealth Management clients. Compliance with PTE 2020-02 When the Advisor provides investment advice to Clients regarding certain retirement accounts or individual retirement arrangements (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. 7  Advanced Capital Group, Inc. IARD/CRD No: 109673 Form ADV Part 2A SEC File No.: 801- 69544 Brochure 3/31/2025 When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll the assets into an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). The Advisor will discuss the options with the Client and provide the Client with the rationale for the recommendation. When a rollover or retirement account transfer is part of the recommendation, additional information regarding fees and comparison of services available will be documented and provided to the client. Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. In December 2020, the DOL adopted a new exemption, Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) under ERISA. PTE 2020-02 can be relied upon by, among others, SEC registered investment advisers and their investment professionals that are deemed investment advice fiduciaries, so long as the exemption’s requirements are met. Intelligent Portfolios Institutional Intelligent Portfolios® (“IIP”) is an automated technology and service platform made available by Schwab Performance Technologies (“SPT”) to independent investment advisors who maintain a business relationship with Schwab Advisor Services™, a division of Charles Schwab & Co., Inc. (“Schwab”). IIP allows ACG to build a customized suite of portfolios for clients, based on ACG’s investment approach. ACG has selected the types of strategies offered, the number of different portfolios across the risk spectrum from more conservative to more aggressive, the asset classes and their weightings in each portfolio, and the specific mutual funds or exchange-traded funds (ETFs) that are available. Schwab, a registered broker-dealer, and member SIPC, provides custody, trading and support services. SPT and Schwab are separate companies affiliated as subsidiaries of The Charles Schwab Corporation, but 8  Advanced Capital Group, Inc. IARD/CRD No: 109673 Form ADV Part 2A SEC File No.: 801- 69544 Brochure 3/31/2025 their products and services are independent from each other. FlexPath Managed Account ServicesFlexPath Managed Account Service is a defined contribution retirement plan investment service whereby ACG, in conjunction with NFP/Retirement Plan Advisory Group, builds a set of model portfolios and partners with Morningstar who sets the asset allocation amongst those model portfolios in order to create a unique portfolio for a defined contribution retirement plan participant. The managed account’s asset allocation is designed to reflect the participant’s age, and other personal information, and can be affected when additional data, including a spouse’s information, is provided by the participant. The underlying model portfolios used by Morningstar are monitored by ACG and NFP/Retirement Plan Advisory Group and are periodically rebalanced by FlexPath. Fees for the managed account service can be paid by either the plan sponsor or the participant and are split amongst NFP/Retirement Plan Advisory Group, and Morningstar. DPL Financial Partners DPL acts as ACG’s outsourced insurance department, providing in-depth analysis of clients’ existing policies and access to new, commission-free insurance solutions that offer value, choice and transparency to fiduciary advisors like ACG. Risk of Loss Generally, the greater the anticipated return of an investment, the higher the risk of loss associated with that investment. There is no assurance that an investment will provide positive performance over any period of time. Past performance, while important, is no guarantee of future results and different periods and market conditions and asset allocation may result in significantly different outcomes. Specific types of risk each client should understand, as they may be applicable to unique investment assets in a portfolio, include: • • Market Risk: The performance of the managed account may drop in reaction to certain events and conditions. For example, political, economic, and social conditions may trigger market events. Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. • Asset Allocation Risk: Asset allocation may have a more significant effect on account value when one of the heavily weighted asset classes is performing more poorly than the others. Diversification and strategic asset allocation do not assure profit or protect against loss in declining markets. Amount of Managed Assets As of December 31, 2024, ACG had a total of $27,844,415,263 of assets under management. On a 9  Advanced Capital Group, Inc. IARD/CRD No: 109673 Form ADV Part 2A SEC File No.: 801- 69544 Brochure 3/31/2025 discretionary basis, ACG managed $1,159,725,388 while providing non-discretionary advice on an additional $26,684,689,875. Item 5: Fees and Compensation ACG’s ongoing advisory fees can be expressed as a flat dollar amount, a percentage of the total assets being managed (“asset-based”), or a combination of the two. Fees are negotiated with your Financial Advisor and are documented in your investment advisory service agreement. Clients can choose to have fees deducted from assets or be billed directly. In either case, ACG’s arrangements for payment can be monthly or quarterly in arrears or in advance. ACG may also charge fees on either a project or hourly basis. If ACG is paid for services in arrears, and a client terminates their contract at any time during the billing period, there are no advanced fees that are paid that would require a refund. If ACG is paid for services in advance, and the client terminates their contract at any time during the billing period, any unearned fees resulting from the paid advance billing will be returned, prorated by the number of days where financial services will not be performed in that billing period. This payment will be remitted within 30 days of contract termination. ACG does not accept compensation for the sale of securities or other investment products, including asset- based sales charges or service fees from the sale of mutual funds. It therefore has no conflict of interest with those investments and does not recommend them based on the compensation received but, rather, on a client’s needs. Clients of ACG have the option to purchase investment products that ACG recommends through other brokers, agents, or investment advisors not affiliated with ACG. ACG does not use products that pay sales commissions. ACG’s sole source of compensation is the fee disclosed in ACG’s service agreement. ACG’s clients are typically charged transaction fees or a recordkeeping fee by their selected trustee or custodian. Those fees may be either assessed against the client’s account or paid directly by the client. These fees are in addition to the advisory fees that ACG charges for its advisory services. ACG does not derive any revenue from such fee(s). Finally, the decision of how that fee is paid is made by the client and not ACG. Mutual funds and other types of pooled accounts generally have management fees (expressed as expense ratios) embedded in them. Expense ratios generally negatively affect the return of investment vehicles. While expense ratios are generally disclosed in advance by the pooled vehicles, other expenses embedded in them can be more difficult to discern. A case in point is actual per-share trading fees. Except for per- share trading fees, most expenses are accounted for in the fund’s prospectus or in the case of a separate account are generally available upon request of the separate account’s management. ACG relies on publicly available software systems to calculate expense ratios. Trading expenses and various “other” expenses are not generally tracked by those publicly available software systems and ACG does not otherwise account for them. ACG does not accept any soft dollars. To explain how its fees are calculated, each of ACG’s three practice areas will be discussed separately. 1. Institutional Investment Consulting 10  Advanced Capital Group, Inc. IARD/CRD No: 109673 Form ADV Part 2A SEC File No.: 801- 69544 Brochure 3/31/2025 Fees are charged in the form of a percentage of assets under management, a fixed dollar amount, or a combination of both. Fees may be billed in advance or in arrears, depending upon the option chosen by the client. Asset-based fees are charged quarterly in arrears and calculated based upon the average daily balance during the advisory period. Some ACG clients choose to pay ACG directly while others pass ACG’s fees through, in whole or in part, to the plan trust (where allowed). This decision is made by the plan client. ACG does not have a standard fee schedule when providing its Institutional Investment Consulting services as its fees depend on many factors and complexity. All fees are negotiated. 2. Institutional Investment Management ACG’s fees are negotiable but are generally charged monthly in arrears based upon the average daily balance during the billing period. Annual Institutional Investment Management fees will not exceed 0.50% (50 basis points) unless pre-approved by Compliance. 3. Financial Wellness ACG provides an assortment of participant support and financial wellness services and the method of compensation differs from service to service, as well as by size of Client (e.g., participant head count). Fees may be charged as a flat fee or as a per participant fee. 4. Individual Wealth Management Clients are charged an asset-based fee, quarterly in arrears, based upon the average daily balance during the advisory period, which clients can choose to pay from outside their account or have deducted from their account. ACG currently requires a $5,000 initial minimum investment and its management fee generally will not exceed 100 basis points (1.00%) for the construction and oversight of a broadly diversified portfolio. Item 6: Performance-Based Fees and Side-By-Side Management ACG does not charge performance-based fees. Item 7: Types of Clients Institutional Investment Consulting: ACG works primarily with employer sponsored retirement plans, foundations/endowments, and Native American Tribal Councils. ACG does not have a minimum account size. Institutional Investment Management: ACG works primarily with pension plans, corporations, banks, and insurers. ACG will accommodate startup plans holding no existing assets. Financial Wellness: This is generally an additional service provided for our institutional clients. Individual Wealth Management: ACG’s current minimum account is $5,000, but in certain cases will consider other amounts if requested through an existing client relationship. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss 1. Methods of Analysis The focus of ACG’s Institutional Investment Consulting practice is on portfolio analytics. For most accounts, 11  Advanced Capital Group, Inc. IARD/CRD No: 109673 Form ADV Part 2A SEC File No.: 801- 69544 Brochure 3/31/2025 ACG follows the principles of Modern Portfolio Theory. ACG’s goal is to build portfolios along an efficient frontier and then discuss the pros and cons of taking on more or less risk along that arc with each client. ACG’s Institutional Investment Management decisions for institutional clients generally take into consideration the duration of the liabilities as well as the interest rate risk of the assets. Throughout ACG’s investment management practice, credit analysis is also a significant focus. Those are not the only considerations, but they are predominant. ACG’s Individual Wealth Management practice is mostly comprised of three different types of clients: ones for whom ACG builds a portfolio from pooled investment products, others for whom it manages a fixed income portfolio, and those who use a combination of the two. ACG’s investment and portfolio analytics rely solely on historical data and do not predict future outcomes. Thus, in extraordinary events, the use of historical data may not be helpful. The financial market changes in 2008 and early 2009 is an example. In ordinary market environments ACG seeks to provide superior risk- adjusted returns compared to the broad market itself. To assist our review process, we acquire our investment manager data from several primary external sources: InvestmentMetrics, Bloomberg, Morningstar Direct, Morningstar Office, and Steele Data Systems. We support that data by having direct contact and interviews with fund personnel and managers. We utilize Bloomberg for real- t i m e investment and industry news related to the managers and management firms used within our client’s retirement plans. This news is delivered real time to our investment consultants and research analysts for further consideration. ACG has also developed a propriety analysis tool we refer to as Rolling Periods of Time (“RPT”). This tool allows us to analyze a manager over several unique rolling time-periods rather than just one static period. For example, a manager with a 4-year performance history will have only one three-year performance period to analyze. The RPT tool allows us to construct thirteen 3-year periods of time and analyze the manager’s risk and return characteristics over those periods to determine the manager’s ability to deliver value consistently rather than just one time. In addition to these research tools, ACG has also developed internal asset class valuation metrics and on a quarterly basis we prepare our own detailed economic review. These tools are not utilized to anticipate the future path of economic growth, they are utilized to track the relative valuation of various asset classes and how those relationships affect the performance of the asset managers our clients utilize. By understanding the market environment that an asset manager is operating in, their performance relative to their peers and the broad market can be better understood. 5. Investment Strategies In its Institutional Investment Consulting practice, ACG generally uses mutual funds, separate accounts and/or collective investment trusts to construct broadly diversified portfolios using the Client’s Investment Policy Statement (IPS) as its guide. Each IPS will vary from client to client, but in general terms will address the following services: • Development and oversight of the IPS; • Preparation of monitoring reports; • Attendance at Investment Committee meetings; • Preparation and distribution of i n v e s t m e n t reports; and • Evaluation of alternative share classes and revenue sharing, if applicable. For its employer-sponsored retirement plan clients, ACG is often retained as an ERISA section 3(21) Advisor or ERISA section 3(38) investment manager to coordinate with the Plan’s recordkeeper to provide 12  Advanced Capital Group, Inc. IARD/CRD No: 109673 Form ADV Part 2A SEC File No.: 801- 69544 Brochure 3/31/2025 particpants with retirement plan and investment education which may include model portfolios consistent with the education safe harbors enunciated in Department of Labor Interpretive Bulletin 96-1. In conjunction with their construction and automatic rebalancing, ACG is often retained to educate the Plans’ participants about model portfolios if they are included in the plan. Delivery methods include, but are not limited to: In-person (e.g., group and/or one-on-one meetings), Internet- b a s e d seminars, • • • Recorded videos and/or • Conference calls. In its Institutional Investment Management practice, ACG works with pensions, banks, and insurers to deliver consultative, transactional, and reporting benefits. In that capacity, ACG acts as outsourced portfolio managers and analysts. With the Clients’ input, ACG designs portfolio strategies that are unique to the client and recommends sectors and structures based on relative value. In consultation with the Client, ACG trades fixed income securities for the portfolios. ACG’s general philosophy is buy-and- hold. That said, at various times ACG has either shortened or lengthened the duration depending on market and economic conditions and there have been times in ACG’s Institutional Investment Management practice that fixed income securities have been sold shortly after their purchase due to a sudden and dramatic movement in interest rates that was beneficial to its clients. Transactions are done competitively, and trade execution is documented. Finally, its quarterly reports are designed to provide management with the ability to make portfolio trading decisions against the backdrop of capital reserve weightings and efficiency. In its Individual Wealth Management practice, ACG has several different investment strategies. The most generic is a broadly diversified risk-based portfolio consisting p r i m a r i l y of pooled investment products and/or fixed income securities but may also include individual securities. For the appropriate Individual Wealth Management client, ACG will also build customized fixed income portfolios. Many of these portfolios have been built using municipal bondsSeparate Account Networks (“”) . 2. Risk of Loss All investing involves risk of loss. Pooled Funds Risk The material risks associated with ACG’s Investment Consulting practice are common to all pooled products like mutual funds, separate accounts and collective trust funds. The risks can include non-systematic risks like a) management, or company risk, which reflect the decisions a company’s managers make that affect the performance of its stock or it can be b) credit, or default risk, which is the risk the company or entity fails to make bond interest or principal payments on a timely basis. The risks could also be systematic and include: a) inflation (increasing inflation can reduce the value of an investment, in particular bonds), b) the change in value of a bond due to changes in interest rates, c) the change in value of one currency versus another, d) the inability to buy or sell an investment quickly due to its lack of liquidity and/or e) the possibility that political or social unrest will affect investment performance and market function. Management Risk In ACG’s Institutional Investment Management practice, risk can be, a) management risk, which reflects the decisions the managers or civic leaders make that affect the performance of its bond or it can be, b) credit, or default risk, which is the risk the company or governmental entity fails to make bond interest or principal payments on a timely basis. The risks could also be systematic and include, a) inflation, b) the change in value of a bond due to changes in interest rates, c) the change in value of one currency versus another, d) the inability to buy or sell an investment quickly due to its lack of liquidity and/or, e) the possibility that political or social unrest will affect investment performance. Fixed Income Securities 13  Advanced Capital Group, Inc. IARD/CRD No: 109673 Form ADV Part 2A SEC File No.: 801- 69544 Brochure 3/31/2025 In its Institutional Investment Management practice, ACG also buys an assortment of taxable fixed income securities. The most common types are corporate bonds, mortgage backed securities (“MBS”), collateralized mortgage obligations (“CMO”), and securities issued by government agencies. Risks associated with investing in fixed income securities include: • Interest rate risk: The risk that changing interest rates may adversely affect the value of an investment. An increase in prevailing interest rates typically causes the value of fixed income investments to fall. Changes in interest rates will likely affect the value of longer-duration fixed income investments more than shorter term investments and higher-quality investments more than lower- quality securities. When interest rates are falling, some fixed income investments provide that the issuer may repay them earlier than the maturity date, and if this occurs the Fund or Account may have to invest these repayments at lower interest rates. A fixed income portfolio may face a heightened level of interest rate risk due to certain changes in monetary policy, such as certain types of interest rate changes by the Federal Reserve. Interest rate changes can be sudden and unpredictable and are influenced by a number of factors including government policy, inflation expectations and supply and demand. A substantial increase in interest rates may have an adverse impact on the liquidity of a security, especially those with longer maturities. Changes in government monetary policy, including changes in tax policy or changes in a central bank’s implementation of specific policy goals, may have a substantial impact on interest rates. There can be no guarantee that any particular government or central bank policy will be continued, discontinued or changed nor that any such policy will have the desired effect on interest rates. The risks associated with rising interest rates may be more pronounced in the near future as interest rates rise from historically low rates. During periods when interest rates are low or there are negative interest rates, fixed income portfolio’s yield (and total return) also may be low or the portfolio may be unable to maintain positive returns or minimize the volatility of the portfolio’s net asset value. • Credit risk: The issuer may default on its obligation to pay principal or interest, may have its credit rating downgraded by a rating organization or may be perceived by the market to be less creditworthy. Lower rated bonds or loans are more likely to be subject to an issuer’s default than investment grade (higher rated) bonds or loans. Lower-rated bonds or loans may have less liquidity and be more difficult to value, particularly in declining markets. • Prepayment risk: If interest rates decline, the issuer of an investment may exercise its right to prepay principal earlier than scheduled, forcing the account to reinvest in lower yielding investments. • Extension risk: If interest rates rise, the average life of investments backed by debt obligations is extended because of slower than expected payments. This will lock in a below-market interest rate, increase the investment’s duration and reduce the value of the investment. • Counterparty risk: The risk that the counterparty to the transaction will default on its obligations under the relevant contract, including due to its financial failure or insolvency, and the related risks of having concentrated exposure to such a counterparty. MBS & CMOs MBS and CMOs possess a unique risk known as prepayment risk. The securities are backed by residential mortgages which can be prepaid without penalty at any time. The individual MBS and CMOs can trade at a premium which is at risk if the mortgage prepays. This type of risk is managed by knowing the specific characteristics of the individual mortgages (such as loan size, geographic diversification, mortgage term, rate etc.) and how the specific security will react to changes in prepayment behavior. The risk unique to agency backed bonds (FNMA, FHLB, FHLMC and FFCB) is call risk. A call feature allows the issuer to redeem the security on or after a specific date at a specific price. Unfortunately, the call feature tends to be exercised by the issuer at the time most disadvantageous to the investor. The easiest way to avoid this type of risk is by not purchasing securities with a call feature. The more common method is to purchase securities with a call feature as a small percentage of the total portfolio. An investor earns a higher yield if a security contains a call feature versus one that does not so there is a benefit to the investor. Call risk is common with agency and municipal issued securities. The second major risk is the risk of default. This only applies to privately issued MBS as the government guarantees the payment of principal for MBS issued by Fannie Mae, Freddie Mac, and Ginnie Mae. (Note: 14  Advanced Capital Group, Inc. IARD/CRD No: 109673 Form ADV Part 2A SEC File No.: 801- 69544 Brochure 3/31/2025 Ginnie Mae, Freddie Mac, and Fannie Mae involve mortgage and home loans. The key difference between Ginnie Mae and the others is that Ginnie Mae is a federally owned corporation. The others are government- sponsored enterprises (GSEs) or federally chartered corporations that are owned by private shareholders. Ginnie Mae guarantees only securities that comprise mortgages guaranteed by federal agencies, such as the FHA and VA, while Freddie Mac and Fannie Mae may back securities whose mortgages are not insured by those federal bodies.1 ) 1. https://www.investopedia.com/terms/g/ginniemae.asp Privately issued MBS set aside funds to cover some defaults (called credit support) and we typically purchase those tranches that have the highest percentage of credit support for a given issue. This type of security also receives the highest credit rating from the rating agencies. It is rare that a tranche originally rated AAA (the highest credit rating) suffers a loss of principal. It was more common during the 2008 – 2009 recession but private MBS issued after that time have much more credit support. Prior to 2008 the percentage was typically 2% - 3% and after 2008 the percentage increased to 10% - 12%. Underwriting standards also increased like lower loan to value ratios giving the investor additional protection. Government Securities Risk Yields available from U.S. Government and agency securities are generally lower than yields from many other fixed income investments. Further, there is a risk that the U.S. Government will not provide financial support to U.S. government agencies, instrumentalities or sponsored enterprises if it is not obligated to do so by law. Although many types of Government Securities, such as those issued by the Federal National Mortgage Association (“Fannie Mae”), Federal Home Loan Mortgage Corporation (“Freddie Mac”) and Federal Home Loan Banks may be chartered or sponsored by Acts of Congress, their securities are neither issued nor guaranteed by the U.S. Department of the Treasury and, therefore, are not backed by the full faith and credit of the United States. Systems and Operational Risks Generally Clients depend on ACG to develop and implement appropriate systems for their activities. Certain of ACG’s activities with respect to its clients will be dependent upon systems operated by third parties, including brokers, administrators, market counterparties and other service providers, and ACG may not be in a position to verify the risks or reliability of such third-party systems. Failure in such systems and similar clearance and settlement facilities or with other parties could result in mistakes made in the confirmation or settlement of transactions, or in transactions not being properly booked, evaluated or accounted for. Disruptions in ACG’s operations may cause a client to suffer, among other things, financial loss, the disruption of trading or investment operations, liability to third parties, regulatory intervention or reputational damage. Any of the foregoing failures or disruptions could have a material adverse effect on a client. Wealth Management ACG’s Individual Wealth Management risk varies depending upon the Client’s chosen strategy. For Clients who engage ACG to build a risk-based portfolio, the risks can include non- systematic risks like: a) management, or company risk, which reflect the decisions a company’s managers make that affect the performance of its stock or it can be, b) credit, or default risk, which is the risk the company fails to make bond interest or principal payments on a timely basis. The risks could also be systematic and include: a) inflation (increasing inflation can reduce the value of an investment, in particular bonds), b) the change in value of a bond due to changes in interest rates, c) the change in value of one currency versus another, d) the inability to buy or sell an investment quickly due to its lack of liquidity and/or, e) the possibility that political or social unrest will affect investment performance and market function. For its individual wealth management, fixed income clients, security selection is also a substantial risk. Today, an investor in municipal bonds needs to accept the fact that municipalities have in the past and may in the future default on their bonds. ACG works to mitigate this risk by employing a rigorous credit analysis process, 15  Advanced Capital Group, Inc. IARD/CRD No: 109673 Form ADV Part 2A SEC File No.: 801- 69544 Brochure 3/31/2025 but this process still cannot guarantee success. Today, there is a special and opaque risk associated with the true cost of the liabilities municipalities have promised to their retirees. That risk is substantial, and buyers of municipal bonds need to be aware of it. As noted earlier, it is possible for municipalities to default on their bonds and even go into bankruptcy. It has happened in the past. The Great Depression saw several municipalities default or declare bankruptcy. Historically, defaults of essential purpose and general obligation municipal bonds have been rare. Inflation and security specific defaults have been and will continue to be a principal risk for municipal bonds. Item 9: Disciplinary Information There are no legal, regulatory, or disciplinary events to disclose involving ACG or its management persons. The backgrounds of the Advisor and its Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 109673. Item 10: Other Financial Industry Activities and Affiliations The following SEC Registered Investment Advisors are owned by Alera Group, Inc. and under common control with ACG: Alera Investment Advisors, LLC; The Ascent Group LLC; JB Capital LLC; Alera Retirement Advisors; and Wharton Business Group LLC. ACG will not receive any direct compensation for referring Clients to an affiliate; however, a conflict exists when ACG recommends that a Client use the services of an affiliate because Alera Group will benefit economically from this recommendation. Certain Supervised Persons of ACG are shareholders of Alera Group and therefore will also benefit economically when an affiliate is chosen over an unaffiliated Investment Advisor. Clients are under no obligation to implement an affiliate’s services when recommended by ACG or any of its Advisory Representatives. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 1. Code of Ethics ACG has implemented a Code of Ethics (the “Code”) that defines our fiduciary commitment to each Client. This Code applies to all Supervised Persons associated with ACG. The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. ACG and its Supervised Persons owe a duty of loyalty, fairness, and good faith towards each Client. It is the obligation of ACG Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (866) 225-5224 or ws.compliance@aleragroup.com. 2. Personal Trading with Material Interest ACG allows the purchase or sale of the same securities that may be recommended to and purchased on behalf of Clients. ACG does not act as principal in any transactions. In addition, ACG does not act as the general partner of a hedge fund or serve as the advisor of an investment company (i.e., a mutual fund). ACG does not have a material interest in any securities traded in Client accounts. 3. Personal Trading in the Same Securities as Clients ACG allows the purchase or sale of the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted a Code which addresses insider trading (material non-public information controls) and personal securities reporting procedures. When trading for personal accounts, Supervised Persons 16  Advanced Capital Group, Inc. IARD/CRD No: 109673 Form ADV Part 2A SEC File No.: 801- 69544 Brochure 3/31/2025 of ACG have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by ACG requiring reporting of personal securities trades by its employees for review by the Alera Compliance Team under supervision of the Chief Compliance Officer (“CCO”). The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. 4. Personal Trading at Same Time as Clients While ACG allows the purchase or sale of the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. At no time will ACG transact in any security to the detriment of any Client. Item 12: Brokerage Practices In its Institutional Investment Consulting and Institutional Investment Management practices, ACG works with the qualified custodian of the client’s choice. In the case of the former, trades are initiated through the client’s chosen qualified custodian so seeking external best execution is not an option. In the case of the latter, ACG will generally seek best execution on the open market which entails delivery-versus-payment coordination between the external broker and the client’s custodian. In the case of Individual Wealth Management accounts, ACG recommends that clients establish brokerage accounts (to maintain custody of clients’ assets and to affect trades for their accounts) with either Charles Schwab & Co., Inc., or Fidelity, both of whom are “qualified” custodians, FINRA member broker- dealers, and members of SIPC. If a client wishes to use an alternate qualified custodian, ACG will make best efforts to accommodate the client. When possible, client purchases and sales are aggregated to achieve the most efficient execution. Reasonable efforts are used with the goal being that fixed income purchases are to be allocated among accounts using the following prioritization; suitability for type of account (municipal, short-duration taxable accounts, etc.), percentage of account not invested (percentage of the account in cash), duration of the position relative to account duration (in the context of the duration of the relevant benchmark duration) and finally subjective fit for a specific account (i.e., if a position were non-callable it would be most appropriate to place it in an account with a significant amount of call risk as opposed to an account comprised entirely of non- callable bonds - all proceeding factors being equal). Item 13: Review of Accounts On a quarterly basis, each of ACG’s Institutional Investment Consulting clients is provided with a comprehensive investment overview. Their preparation is a team effort, as is their internal review, which would be led by ACG’s assigned investment advisor. Typically, meetings are held quarterly with those clients’ investment committees to review those reports. ACG’s Institutional Investment Management clients receive regular statements directly from the custodians holding their investments. Item 14: Client Referrals and Other Compensation For clients obtained through ACG’s prior participation in Schwab’s SAN program, ACG pays Schwab a Participation Fee on client accounts that were referred that are maintained in custody at Schwab and a non- Schwab Custody Fee on all accounts that are maintained at, or transferred to, another custodian. The Participation Fee paid by ACG is a percentage of the fees the client owes to ACG or a percentage of the value of the assets in the client's account, subject to a minimum Participation Fee. ACG pays Schwab the Participation Fee for so long as the SAN client's account remains in custody at Schwab. The Participation Fee is billed to ACG quarterly and may be increased, decreased, or waived by Schwab from time to time. The Participation Fee is paid by ACG and not by the client. ACG has agreed not to charge clients referred through the Service fees or costs 17  Advanced Capital Group, Inc. IARD/CRD No: 109673 Form ADV Part 2A SEC File No.: 801- 69544 Brochure 3/31/2025 greater than the fees or costs ACG charges clients with similar portfolios who were not referred through the Service. These are legacy payments and ACG no longer actively participates in Schwab’s SAN program. ACG generally pays Schwab a non-Schwab Custody Fee if custody of a referred client's account is not maintained by, or assets in the account are transferred from Schwab. This Fee does not apply if the client was solely responsible for the decision not to maintain custody at Schwab. The non-Schwab Custody Fee is a one- time payment equal to a percentage of the assets placed with a custodian other than Schwab. The non-Schwab Custody Fee is higher than the Participation Fees advisors generally would pay in a single year. Thus, ACG will have an incentive to recommend that client accounts be held in custody at Schwab. The Participation and non-Schwab Custody Fees will be based on assets in accounts of ACG’s clients who were referred by Schwab and those referred clients' family members living in the same household. Thus, ACG will have incentives to encourage household members of clients referred through the Service to maintain custody of their accounts and execute transactions at Schwab and to instruct Schwab to debit ACG’s fees directly from the accounts. For accounts of ACG’s clients maintained in custody at Schwab, Schwab will not charge the client separately for custody but will receive compensation from ACG’s clients in the form of commissions or other transaction-related compensation on securities trades executed through Schwab. Schwab also will receive a fee (generally lower than the applicable commission on trades it executes) for clearance and settlement of trades executed through broker-dealers other than Schwab. Schwab's fees for trades executed at other broker-dealers are in addition to the other broker-dealer's fees. Thus, ACG may have an incentive to cause trades to be executed through Schwab rather than another broker- dealer. ACG nevertheless, acknowledges its duty to seek best execution of trades for client accounts. Trades for client accounts held in custody at Schwab may be executed through a different broker-dealer than trades for ACG’s other clients. Thus, trades for accounts custodied at Schwab may be executed at different times and different prices than trades for other accounts that are executed at other broker-dealers. Item 15: Custody “Custody” is understood to entail not only physical possession of client assets, but also to authority to direct a qualified custodian who has physical possession of client assets to send such assets to a third party. Examples of this include an adviser directing the custodian to deduct management fees, an adviser acting as a conduit through which a client sends assets to the qualified custodian, or an adviser directing the custodian to make distributions from a client account. In reference to these instances, ACG performs the following: • Have clients maintain an account at a qualified custodian, from whom clients will receive periodic statements and ACG will not take possession of client assets. ACG encourages clients to compare qualified custodian statements to any account reports it produces to verify accuracy. • Receipt of client assets intended for the qualified custodian are logged and generally returned to • the client with instructions to send directly to the qualified custodian. Instructs the qualified custodian to withdraw any authority it may have given ACG to direct distributions to third parties. The goal of the foregoing is to give a comprehensive, succinct but logical overview of the SEC’s Custody Rule and ACG’s actions to avoid having Custody or to fall within a safe harbor. Item 16: Investment Discretion Clients can engage ACG to provide discretionary or non-discretionary asset management. If a client hires us to provide discretionary investment services, we place trades in a client's account without contacting the client 18  Advanced Capital Group, Inc. IARD/CRD No: 109673 Form ADV Part 2A SEC File No.: 801- 69544 Brochure 3/31/2025 prior to each trade to obtain the client's permission. Our discretionary authority includes the ability to do the following without contacting the client: • Determine the security to buy or sell; • Determine the amount of the security to buy or sell; and/or • Determine the timing of when to buy or sell, this includes periodic rebalancing of the client’s account. Clients give us discretionary authority when they sign a discretionary agreement with our firm and can limit this authority by giving us written instructions. Clients can also change/amend such limitations by once again providing us with written instructions. Finally, ACG’s service agreement directs each client to review that contract with a lawyer of their choosing. 1. Institutional Investment Consulting ERISA section 3(38) allows a Plan Sponsor to delegate to a Registered Investment Advisor (or bank or insurance company) its investment management oversight responsibilities. When the Pension Protection Act was passed, it provided for Qualified Default Investment Alternatives (QDIA) with one option being to have them customized for the Plan by a section 3(38) Investment Manager. Today, ACG serves as a section 3(38) manager to several customized QDIAs. In some cases, Plan Sponsors have engaged ACG to act as a section 3(38) manager for all their Plans’ investment offerings. 2. Institutional Investment Management ACG prefers to have discretionary management of fixed income portfolios. 3. Individual Wealth Management In our Individual Wealth Management practice area, we offer discretionary and non-discretionary client accounts. The type of discretion used is the client’s decision. Item 17: Voting Client Securities As a matter of firm policy, we do not vote proxies or approve tender offers on behalf of clients. Therefore, although our firm may provide investment advisory services relative to client investment assets, clients maintain exclusive responsibility for: (1) directing the way proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. Clients are responsible for instructing each custodian of the assets to forward to the client copies of all proxies and shareholder communications relating to the client’s investment assets. Item 18: Financial Information ACG has no financial circumstances to report. ACG is not required to attach a balance sheet since we do not require or solicit prepayment of more than $1,200 in fees per client six months in advance, or otherwise. ACG is unaware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. 19  Advanced Capital Group, Inc. IARD/CRD No: 109673 Form ADV Part 2A SEC File No.: 801- 69544 Brochure 3/31/2025 Neither ACG nor Alera Group have been the subject of a bankruptcy petition at any time during the past ten years (or at any time). 20