BRAGG FINANCIAL ADVISORS INC

The Firm Brochure Part 2A of Form ADV \\ February 24, 2025 This Brochure provides information about the qualifications and business practices of Bragg Financial Advisors, Inc. If you have any questions about the contents of this Brochure, please contact us at (704) 377‑0261 or dawn@braggfinancial.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Bragg Financial Advisors, Inc., is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Our firm’s CRD number is 108780. 1031 S. Caldwell Street, Suite 200 \\ Charlotte, North Carolina 28203 \\ www.braggfinancial.com \\ (704) 377‑0261  Item 2: Material Changes There has been no material change to this document from the previous filing date of March 5, 2024. Consistent with SEC regulations, we will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business’s fiscal year. Furthermore, we will provide you with other interim disclosures about material changes as necessary. Item 3: Table of Contents Item 1: Cover Page . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1 Item 2: Material Changes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 Item 3: Table of Contents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 Item 4: Advisory Business. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Item 5: Fees and Compensation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Item 6: Performance‑Based Fees and Side‑By‑Side Management . . . . . . . . . . . . . . . . . . . . . . . . . 9 Item 7: Types of Clients . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss . . . . . . . . . . . . . . . . . . . . . . . 9 Item 9: Disciplinary Information. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Item 10: Conflicts of Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. . . . . . . . . . 13 Item 12: Brokerage Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Item 13: Review of Accounts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Item 14: Client Referrals and Other Compensation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Item 15: Custody . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Item 16: Investment Discretion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 Item 17: Voting Client Securities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 Item 18: Financial Information. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 Brochure Supplements: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 Benton S. Bragg. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 Phillips M. Bragg . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 John F. Bragg III . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 Steven H. Scruggs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .24 Anthony Bykovsky . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 Clint Townsend . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 Evan A. Anderson . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .32 George W. Climer III . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .34 Jennifer D. Muckley. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .36 Lauren Klaiber . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .39 Lynn Araujo . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42 Marc N. Scavo . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .44 Matthew S. DeVries. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .46 Meghan Oldis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49 Thomas Benjamin Rose . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51 The Firm BrochureForm ADV Part 2A \\ February 24, 2025 Item 4: Advisory Business and institutional clients of the firm. You can read more about Benton by reading the brochure supplement to this document. Bragg Financial Advisors, Inc. Phillips M. Bragg, Vice President and Principal Shareholder – Shareholder Bragg Financial Advisors, Inc. (Bragg) is an investment advisor registered with the Securities and Exchange Commission (SEC). Our principal place of business is Charlotte, North Carolina. Bragg Financial Advisors began conducting business as a registered investment advisor in the state of North Carolina in 1997. We registered with the Securities and Exchange Commission in 2000. Phillips graduated from Wake Forest University in 1993 with a BA in English. Phillips holds the Certified Financial Planner and Accredited Estate Planner designations. Phillips provides expertise in retirement cash flow planning, estate and gift planning. He also advises clients regarding donor advised funds, charitable trusts, private foundations and conservation easement planning. You can read more about Phillips by reading the brochure supplement to this document. Bragg provides advisory services to individuals, investment companies including mutual funds, corporations, and charitable organizations. John F. Bragg III, Vice President and Principal Shareholder – Shareholder As of 12/31/2024, we were actively managing client assets of $3,904,367,607 on a discretionary basis. John graduated from Wake Forest University in 1988 with a BA in Communications. John holds the Certified Financial Planner designation. John works with individual and institutional clients of the firm. You can read more about John by reading the brochure supplement to this document. Steve H. Scruggs, Senior Portfolio Manager, Director of Research – Shareholder Our People and Our History Bragg Financial Advisors is a family‑owned business. Our firm traces its roots back to 1964 when our founder, J. Frank Bragg, Jr., first entered the financial services industry in Charlotte. Information about the firm’s founder and shareholders who are active in the management of the company is listed below. J. Frank Bragg, Jr., Founder of Bragg Financial Advisors, Inc., Chairman Emeritus Steve graduated from North Carolina State University in 1992 with a BA in Business Management. He received his MBA from Wake Forest University in 1996. Steve holds the Chartered Financial Analyst designation. Steve is our Director of Research, a member of the Investment Committee and the portfolio manager for the FPA Queens Road Small Cap Value Fund and the FPA Queens Road Value Fund. You can read more about Steve by reading the brochure supplement to this document. We offer the following advisory services to our clients: INDIVIDUAL PORTFOLIO MANAGEMENT – MANAGED ACCOUNT PROGRAM Frank grew up in Oxford, North Carolina, and graduated from Wake Forest University in 1961 with a BA in English. Frank began his career in financial services with Security Life and Trust Company in Winston‑Salem. In 1964, he moved his family to Charlotte and formed his own firm specializing in employee benefit plans. Over time, the firm evolved into a more comprehensive benefits and investment organization offering financial planning and portfolio management for individuals. The second generation of firm leadership, including Frank Bragg’s three sons and son‑in‑law, joined the firm in the 1990s as the company evolved into a comprehensive wealth management firm. Benton S. Bragg, President, CEO and Principal Shareholder – Shareholder Portfolio Management Guided by Written Investment Policy Statement: Our firm provides portfolio management of client investment accounts based on the individual needs of the client. After engaging with the client in extensive discussions about the client’s personal financial circumstances, investment goals and long‑term financial objectives, we and the client develop the client’s written Investment Policy Statement. The principal objective in developing a written investment plan is to enable you and us to protect your portfolio from ad hoc revisions to Benton graduated from Wake Forest University in 1990 with a BA in History and a minor in English. He received his MBA from Wake Forest University in 1997. Benton holds the Chartered Financial Analyst and Certified Financial Planner designations. Benton chairs the Investment Committee at Bragg and works closely with individual — 3 — The Firm BrochureForm ADV Part 2A \\ February 24, 2025 (stocks, bonds, mutual funds, ETFs, etc.) selected by Bragg Financial Advisors. The specific terms and conditions under which a client engages an independent manager will be set forth in a separate written agreement between Bragg and the designated independent manager. Clients will acknowledge in writing the terms of the engagement including the approximate amount to be managed by the independent manager and the fees to be assessed by the independent manager. a sound, long‑term plan. The written plan will help you maintain discipline when short‑term market movements may be distressing, and the plan may be questioned. The development of an investment plan follows the basic approach underlying financial planning: assessing your financial condition, setting goals, developing a strategy to meet these goals, implementing the strategy, regularly reviewing the results and adjusting the strategy or the implementation as circumstances dictate. Utilizing an investment policy statement encourages you to become more disciplined and systematic in your approach, thus increasing the probability of reaching your investment goals. the various Bragg will complete due diligence on independent managers, including but not limited to analysis of investment strategies, past performance adjusted for risk, manager tenure, manager process, research capabilities, reporting capability, reputation, financial strength, pricing and compliance record. On an ongoing basis, Bragg will monitor the performance of those accounts being managed by independent managers to ensure ongoing alignment with the investment objectives and interests of the client. Portfolio Models: Client accounts are normally assigned to a Portfolio Model as follows: Portfolio Construction and Management Process: The portfolio construction and management process to be used by Bragg Financial Advisors emphasizes diversification and strategic allocation among different asset classes. Empirical evidence and academic research suggest that with regards to portfolio performance, the impact of strategic allocation among various asset classes will far outweigh the impact of security selection, market timing, or other decisions that affect performance. The process used by Bragg emphasizes the risk‑adjusted performance of the entire portfolio; it does not emphasize the performance of the individual securities within the portfolio. Our process will not employ methods such as frequent trading, market sector rotating or market timing. Portfolio One: Aggressive Allocation with Emphasis on Capital Appreciation. Equity Portion of the portfolio to normally range between 80% and 100%. Fixed Income Portion to normally range between 0% and 20%. Portfolio Two: Aggressive Allocation with Emphasis on Capital Appreciation. Equity Portion of the portfolio to normally range between 70% and 90%. Fixed Income Portion to normally range between 10% and 30%. Portfolio Three: Moderately Aggressive Allocation with Primary Emphasis on Capital Appreciation and Secondary Emphasis on Income. Equity Portion of the portfolio to normally range between 60% and 80%. Fixed Income Portion to normally range between 20% and 40%. Portfolio Securities: Bragg constructs portfolios using securities including but not limited to publicly traded stocks (common and preferred), publicly traded bonds, no‑load mutual funds, real estate investment trusts, exchange traded funds, options and other derivative contracts, certificates of deposit, unit investment trusts, money market instruments and similar cash equivalents and other securities. Asset class exposure will include but not be limited to Large Cap Equity, Mid Cap Equity, Small Cap Equity, Foreign Equity, Real Estate, Cash Equivalents and Fixed Income Securities. Bragg periodically rebalances portfolios to maintain the desired blend of exposure to specific asset classes and security types. The investment vehicles we use to construct portfolios are not limited to any specific product or service offered by a specific broker/dealer or other financial institution. Portfolio Four: Moderate Allocation with Emphasis on Capital Appreciation and Income. Equity Portion of the portfolio to normally range between 50% and 70%. Fixed Income Portion to normally range between 30% and 50%. Portfolio Five: Moderately Conservative Allocation with Emphasis on Capital Appreciation, Capital Preservation and Income. Equity Portion of the portfolio to normally range between 40% and 60%. Fixed Income Portion to normally range between 40% and 60%. Independent Managers (Separate Account Management): In some cases, Bragg may engage an independent manager or separate account manager to manage all or a portion of a client’s account. When an independent manager is used, securities selected by the independent manager will be owned in the client account in lieu of securities — 4 — The Firm BrochureForm ADV Part 2A \\ February 24, 2025 (4) follow policies and procedures designed to ensure that we give advice that is in your best interest; (5) charge no more than what is reasonable for our services; and (6) give you basic information about our conflicts of interest. Portfolio Six: Moderately Conservative Allocation with Emphasis on Capital Preservation, Income and Moderate Capital Appreciation. Equity Portion of the portfolio to normally range between 30% and 50%. Fixed Income Portion to normally range between 50% and 70%. PORTFOLIO MANAGEMENT – SMALL CAP VALUE MANAGED ACCOUNT PROGRAM Portfolio Seven: Conservative Allocation with Emphasis on Capital Preservation and Income; Capital Appreciation is Secondary. Equity Portion of the portfolio to normally range between 20% and 40%. Fixed Income Portion to normally range between 60% and 80%. Bragg Financial Advisors offers portfolio management to individual and institutional clients who desire a specific portfolio constructed primarily of the common stocks of small companies. The Small Cap Value Managed Account Program focuses on companies that have a market capitalization generally less than the largest company in the Russell 2000 Index. Bragg Financial Advisors may offer its Small Cap Value Managed Account Program services to an Independent Advisor as sub‑advisory services to be performed on their client’s account at the direction of the Advisor. Discretionary Management: In almost all cases, our firm manages portfolios on a discretionary basis per the written Investment Policy Statement. This means Bragg will not contact the client prior to conducting buy or sell transactions in client accounts. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors and these are outlined in the Investment Policy Statement. In some cases, portfolios are managed on a non‑discretionary basis. Discretionary Management and Investment Policy Statement: Bragg manages these accounts on discretion per a written Investment Policy Statement that is developed with input from the client. Advisory Fees: Bragg charges Advisory Fees for the Managed Account Program described above. In addition to the Advisory Fees charged by Bragg, there are other costs associated with our Managed Account Program. Please review the “Fees and Compensation” section (Item 5) of this document for specific details regarding fees and charges. Advisory Fees: Bragg charges Advisory Fees for the Small Cap Value Managed Account Program described above. In addition to the Advisory Fees charged by Bragg, there may be other costs associated with our Small Cap Value Managed Account Program. Please review the “Fees and Compensation” section (Item 5) of this document for specific details regarding fees and charges. FINANCIAL PLANNING Fiduciary Acknowledgement: We are making investment recommendations to you regarding your retirement plan account or individual retirement account as fiduciaries within the meaning of Title 1 of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money or otherwise are compensated creates some conflicts with your financial interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provision, we must: (1) meet a professional standard of care when making investment recommendations (give prudent advice) to you; (2) never put our financial interests ahead of yours when making recommendations (give loyal advice); (3) avoid misleading statements about conflicts of interest, fees, and investments; Financial planning is a collaborative process that helps maximize a client’s potential for meeting life goals through financial advice that integrates relevant elements of the client’s personal and financial circumstances. As portions of our financial planning recommendations may involve tax, insurance, borrowing or legal planning considerations, we strongly recommend that clients coordinate with other advisors such as accountants, insurance professionals, implementing planning lenders, or attorneys before recommendations. We do not provide legal or tax advice. Any legal or tax issues discussed with clients should also be discussed with legal or tax counsel. — 5 — The Firm BrochureForm ADV Part 2A \\ February 24, 2025 In general, we may provide Financial Planning in the following areas: Retirement Planning: We may project annual required savings necessary to accumulate adequate assets to fund a desired stream of income in retirement. We may suggest appropriate investment vehicles for clients to consider using for retirement accumulation. In all cases we will make assumptions regarding future investment returns, savings rates, inflation and longevity. There is no guarantee that our assumptions regarding the future will prove to be accurate. a particular goal may have on other goals; (3) analyze the client’s current course of action and potential alternative course of action. We will discuss the material advantages and disadvantages of the current course and whether the current course maximizes the potential for meeting the client’s goals. We will consider and analyze one or more potential alternative courses of action, including the material advantages and disadvantages of each alternative, whether each alternative helps to maximize the potential for meeting the client’s goals and how each alternative integrates the relevant elements of the client’s personal and financial circumstances. Education Planning: We may project annual required savings necessary to accumulate adequate assets to fund education expenses. We may suggest appropriate investment vehicles for clients to consider using for the accumulation of education funds. From the potential courses of actions, we will select one or more recommendations designed to maximize the potential for meeting the client’s goals. For each recommendation we will consider (1) the assumptions and estimates used to develop the recommendation; (2) the basis for making the recommendation, including how the recommendation is designed to maximize the potential to meet the client’s goals, the anticipated material effects of the recommendation on the client’s financial and personal circumstances, and how the recommendation integrates relevant elements of the client’s personal and financial circumstances; (3) the timing and priority of the recommendation; (4) whether the recommendation is independent or must be implemented with another recommendation. the client with the Investments: We will assist you with developing and implementing an asset management strategy. Through personal discussions in which goals and objectives based on a client’s particular circumstances are established, we develop a client’s written Investment Policy Statement (IPS). We may also analyze investment alternatives such as exchange listed securities (stocks, bonds, exchange traded funds), warrants, corporate debt securities, certificates of deposit, municipal securities, variable life insurance, variable annuities, mutual fund shares, United States government securities and option contracts on securities and their effect on the client’s portfolio. We will present selected recommendation(s) and the information that was required to be considered when developing the recommendation(s). the client implement Insurance: We may review existing policies to ensure proper coverage for life, health, disability, long‑term care, liability, home and automobile. We may make specific recommendations regarding the amount and structure of any coverage currently in place or recommended by our firm. Estate Planning: Working with other professionals such as accountants and attorneys, we may assist the client in assessing and understanding the financial aspects of long‑term estate planning strategies. We will help the plan by: (1) communicating to the client the recommendation(s) being implemented and the responsibilities of your advisor, the client and any third party implementing the plan; (2) identifying, analyzing and select actions, products and services to implement the recommendation; (3) discuss with the client the basis for selecting an action, product, or service, the timing and priority of implementing the action, product, or service, and disclose and manage any material conflicts of Interest concerning the action, product, or service; (4) discuss with the client any client selection that deviates from the actions, products, and services that were recommended. Other Planning Issues: We may also provide planning in other areas including but not limited to debt structuring, cash flow planning, lease/buy decisions, conservation easement planning and charitable planning. We will discuss with the client whether we have monitoring and updating responsibilities. If we do have monitoring and updating responsibilities then we will (1) determine how and when we will monitor the recommended actions, products and services; (2) discuss the client’s responsibility to inform us of any material changes to the client’s qualitative and quantitative information; (3) determine the time frame During the financial planning process, we will (1) obtain and analyze qualitative and quantitative information from the client; (2) discuss with the client our professional assessment of the client’s financial and personal circumstances and help the client identify goals, noting the effect that selecting — 6 — The Firm BrochureForm ADV Part 2A \\ February 24, 2025 The annualized fee for the Managed Account Program will be charged as a percentage of assets under management, according to the following schedule: for updating the financial planning recommendations; (4) monitor the client’s progress at achieving their stated goals and make recommendations by collaborating with the client to obtain updated qualitative and quantitative information. Managed Account Program Assets Under Management Annual Fee MUTUAL FUND PORTFOLIO MANAGEMENT First $5 Million .85% Next $5 Million .70% Our firm provides portfolio management services to investment companies including mutual funds. Next $10 Million .60% Over $20 Million .50% The Managed Account Program will have a minimum annual advisory fee of $20,000 for new clients as of April 1, 2023. Existing clients will not be subject to the above fee schedule or the minimum annual advisory fee. A minimum of $5,000,000 of assets under management is typically required for the Managed Account Program but this minimum can be negotiated in certain circumstances. Bragg may group related client accounts for the purpose of determining the annualized fee. Bragg Financial Advisors launched and served as advisor to two no‑load mutual funds, the Queens Road Funds, in 2002. In 2020, Bragg entered into a strategic partnership with First Pacific Advisors, LP (FPA), resulting in FPA becoming the advisor to the mutual funds and in the renaming of the funds to the FPA Queens Road Small Cap Value fund and the FPA Queens Road Value fund. Bragg now serves as sub‑advisor to the Funds and continues to manage the Funds’ portfolios. In their new role as advisor to the Funds, FPA provides administration, marketing, and distribution services. Steve Scruggs, CFA, a principal at Bragg Financial Advisors, has served as portfolio manager for the Funds since their inception in 2002 and continues in that role under the new partnership. The Small Cap Value Managed Account Program is a discretionary small cap value equity asset management program. This program is described in detail in the “Advisory Business” section (Item 4) of this document. Small Cap Value Managed Account Program Interested investors should refer to the Mutual Funds’ Prospectus and Statement of Additional Information (SAI) for important information regarding objectives, investments, time‑horizon, risks, fees, and additional disclosures. These documents are available online at www.fpa.com. Assets Under Management Annual Fee First $5 Million .85% Next $5 Million .75% Over $10 Million .65% Prior to making any investment in the funds, investors and prospective investors should carefully review these documents for a comprehensive understanding of the terms and conditions applicable for investment in the Mutual Funds. Amount of Managed Assets As of 12/31/2024, we were actively managing client assets of $3,904,367,607 on a discretionary basis. A minimum of $1,000,000 of assets is required for the Small Cap Value Managed Account Program. The minimum account size may be negotiable under certain circumstances. Bragg may group related client accounts for the purpose of determining the annualized fee. Illustration of Advisory Fee Calculation: Item 5: Fees and Compensation = x Annual Fee Percentage 4 Total Quarterly Fee Total Asset Value in Account Managed Account Program Advisory Fees The Managed Account Program is a fee‑based program in which clients retain Bragg Financial Advisors to manage a specific account or group of accounts owned by the client. This program is described in detail in the “Advisory Business” section (Item 4) of this document. The advisory fee is payable quarterly in advance. The first payment is due and will be assessed within ten days following the end of the quarter following execution of the Discretionary Managed Account Agreement and will be — 7 — The Firm BrochureForm ADV Part 2A \\ February 24, 2025 A minimum of $5,000,000 of assets under management is required for the Managed Account Program and a minimum of $1,000,000 of assets is required for the Small Cap Value Managed Account Program. The minimum account size may be negotiable under certain circumstances. Bragg may group related client accounts for the purpose of determining the annualized fee. assessed pro rata in the event this Agreement is executed at any time other than the first day of the calendar quarter. Subsequent payments will be assessed quarterly based on the value of the Account assets as of the close of business on the last business day of the preceding quarter as valued in good faith by a reliable pricing service. If assets are deposited (withdrawn) after the inception of a quarter, the fee chargeable (refundable) with respect to such assets as of the next calculation date will be prorated based on the number of days during the quarter the assets were held in the Account. There will be no fee adjustments for Deposits/ Withdrawals resulting in fee modifications of less than $50.00. For valuation purposes the assets will be treated as if they were held in the Account as of the end of the quarter. Any subsequent modification to the Discretionary Managed Account Agreement agreed to in writing by client and Advisor will become effective on the first day of the quarter following the signing of the Agreement. Limited Negotiability of Advisory Fees: Although Bragg has established the aforementioned fee schedule(s), we retain the discretion to negotiate alternative fees on a client‑by‑ client basis. Client facts, circumstances and needs will be considered in determining the fee schedule. These include the complexity of the client’s financial position, the amount of assets to be placed under management, anticipated future deposits or withdrawals, related accounts managed by Advisor, portfolio style, account composition, reporting requirements and other factors. The specific annual fee schedule will be identified in the contract between the Advisor and each client. Advisory Fee rates may differ from the schedule listed here and among clients for various reasons including but not limited to the circumstances listed above. The quarterly investment advisory fee will be calculated as one fourth (1/4) of the annual fee as stated in the Discretionary Managed Account Agreement. Client will receive a billing statement showing the applicable billing rate, the value of assets in the account at the time the fee was calculated, and the amount of the fee as well as any pro rata adjustments for additions or withdrawals from the account for the previous quarter. Discounts, not generally available to our advisory clients, may be offered to family members and friends of associated persons of our firm. The Discretionary Managed Account Agreement will continue in effect until terminated by either party. Either party may terminate the Agreement at any time by giving thirty (30) days signed written notice to the other party. Grandfathering of Fees: The fee scheduled listed above will generally be applicable for all new clients contracting for advisory services with Bragg. This schedule may differ from the fee schedule in place for some existing clients and there is no requirement that existing clients contract for services at the rates listed above. In the event that either party terminates the Discretionary Managed Account Agreement, any fees will be prorated to the date of termination and client will be refunded any unearned portion of those fees. Termination of the Agreement will not affect the validity of any action previously taken by Bragg, any liabilities or obligations of the parties for transactions initiated before termination; or the client’s obligation to pay and Bragg’s right to retain fees for services rendered under the Agreement. If a party terminates the Discretionary Managed Account Agreement, Advisor is not obligated to recommend or take any action with regard to the securities, cash or other investments in client’s account or liquidate any assets in client’s account after the termination date. It shall be client’s exclusive responsibility to provide written instructions to Bragg regarding any assets in the account following termination. Waivers of Advisory Fees for Certain Assets Invested in the Managed Account Program: Any portion of a client account that is invested in shares of the FPA Queens Road Funds will be excluded from our Quarterly Advisory Fee calculation described above. As disclosed in the “Advisory Business” section (Item 4) of this document, Bragg Financial Advisors serves as a sub‑advisor to the FPA Queens Road Funds and is compensated by the FPA Queens Road Funds for these services. Therefore, participants in our Managed Account Program who own shares of the FPA Queens Road Funds within the Managed Account Program will pay only those fees charged to investors by the Mutual Funds directly for that portion of the account. Effective September 1, 2018, shares of the Funds will not be purchased in accounts managed by Advisor in the Managed Account Program. However, clients who participated in the Managed Account — 8 — The Firm BrochureForm ADV Part 2A \\ February 24, 2025 Program prior to September 1, 2018, may own existing shares of the Funds within accounts managed by Advisor in the Managed Account Program. certain cases, existing clients of Advisor may not meet current minimum account size requirements but will remain clients due to grandfathering. Advisory Fees in General: Clients should note that similar advisory services may (or may not) be available from other registered (or unregistered) investment advisors for similar or lower fees. Advisory Fees Charged to Investment Companies Including Mutual Funds Bragg Financial Advisors charges an asset‑based advisory fee for management of the FPA Queens Road Small Cap Value Fund and the FPA Queens Road Value Fund. The fee arrangement is described in the Mutual Fund’s Prospectus and Statement of Additional Information (SAI). Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees in excess of $1,200 more than six months in advance of services rendered. Other Investment Costs and Important Disclosures Best Execution: Bragg Financial Advisors performs best execution testing for securities transactions monthly. The testing is designed to ensure that Bragg has a reasonable basis to believe that clients are receiving the best execution on their securities transactions. If you have any questions regarding best execution testing please call (704) 377‑0261 and ask for the Chief Compliance Officer. Item 6: Performance-Based Fees and Side-By- Side Management Bragg does not charge performance‑based fees. Item 7: Types of Clients Bragg provides advisory services to the following types of clients: Fees Charged by Mutual Funds and Other Investment Vehicles: All fees paid to Bragg Financial Advisors for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds, exchange traded funds or other investment vehicles that may be purchased or held in account of client in the Managed Account Program. These fees and expenses are described by the prospectus that is specific to the investment vehicle being purchased. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. Accordingly, the client should review both the fees charged by the funds and our advisory fees to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. ƒ Individuals (other than high‑net‑worth individuals) ƒ High‑net‑worth individuals ƒ Investment companies (including mutual funds) ƒ Charitable organizations ƒ Corporations Independent Manager Fees: For certain clients who have an independent manager managing some or all of their portfolio, such independent manager will deduct advisory fees directly from the client’s account in accordance with the Independent Manager’s Form ADV Part 2A and as disclosed and acknowledged in writing by the client. Bragg does not receive a portion of these fees. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss We use the following methods of analysis in formulating our investment advice and/or managing client assets: Additional Fees and Expenses: In addition to our advisory fees, clients are responsible for the fees and expenses charged by their broker/dealer or custody firm, including, but not limited to, any transaction charges imposed by the broker/dealer when Advisor effects transactions for the client’s account(s). An example of this would be a transaction fee charged when a trade is made in a client account. Fundamental Analysis: We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). IF APPLICABLE—Grandfathering of Minimum Account Requirements: The minimum account size required to become a client of Advisor has increased over time. In — 9 — The Firm BrochureForm ADV Part 2A \\ February 24, 2025 Fundamental analysis does not attempt to anticipate broad stock market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. able to with your available cash and allows us to purchase stock without selling other holdings. Investing on margin can expose an investor to greater levels of risk. Clients who wish to invest using margin must sign a margin agreement and a margin disclosure document before any security can be purchased on margin. Risk of loss: Securities investments are not guaranteed, and you may lose money on your investments. We ask that you work with us to help us understand your tolerance for risk. Risks for all forms of analysis: Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities are providing accurate and thorough and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. Item 9: Disciplinary Information We are required to disclose any legal or disciplinary events that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management. is characterized by the Investment Strategies Our Investment Portfolio utilized within the Managed following Account Program descriptions. Our firm and our management personnel have no reportable disciplinary events to disclose. Broad Diversification by Asset Class and Market Sector: Emphasis is placed on broad exposure to asset classes such as Large Cap US Equities, Small Cap US Equities, Foreign Equities, Investment Grade Corporate Bonds, Government Bonds, etc. In addition, emphasis is placed on diversification by market sector or industry including, but not limited to, technology, healthcare, financial, consumer discretionary, utilities, consumer staples, real estate, basic materials, communications and energy. While shares of individual companies may be owned in the portfolio, it is recognized that the primary determinants of portfolio return are asset class weightings and market sector weightings. Item 10: Conflicts of Interest Identifying Bragg Financial Advisors’ Material Conflicts of Interest has been and remains fundamental to our development of reasonable and prudent policies and procedures which are designed to prevent such conflicts from causing violations of Impartial Conduct Standards, among other considerations. A Material Conflict of Interest exists when a Financial Institution or Advisor has a financial interest that a reasonable person would conclude could affect the exercise of its best judgment in rendering advice to an Investor. Long-term purchases: We purchase securities with the idea of holding them in the client’s account for a year or longer. Typically, we employ this strategy when we believe the securities to be currently undervalued, and/or we want exposure to a particular asset class or sector over time regardless of the current consensus outlook for the asset class or sector. Financial Institutions are therefore required to mitigate the impact of any Material Conflicts of Interest, and to provide a description of such conflicts to an existing or prospective investor. Furthermore, Financial Institutions must designate a person or persons responsible for addressing such Material Conflicts of Interest and monitoring employee adherence to the Impartial Conduct Standards. Accordingly, Bragg Financial Advisors has designated Dawn Cannon, Chief Compliance Officer, as the firm’s Conflict Officer. A risk in a long‑term purchase strategy is that by holding the security for this length of time, we may not take advantage of short‑term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Margin transactions: We may purchase stocks for your portfolio on margin (using borrowed funds) at your request. This allows you to purchase more stock than you would be Description of Compensation Arrangements and Conflicts of Interest Managed Account Program: The primary investment management service offered by Bragg Financial Advisors is the Managed Account Program. Clients choosing the Managed Account Program engage Bragg to manage an account on discretion per a written investment policy — 10 — The Firm BrochureForm ADV Part 2A \\ February 24, 2025 .95% Management Fee for FPA Queens Road Value Fund per Prospectus dated September 30, 2024 * .66% Management Fee for FPA Queens Road Small Cap Value Fund per Prospectus dated September 30, 2024 statement. Client and Bragg enter a contract for this service at an agreed upon Advisory Fee. Accounts managed within the Managed Account Program at Bragg typically own the following types of securities including but not limited to publicly traded stocks (common and preferred), publicly traded bonds, no‑load mutual funds, real estate investment trusts, exchange traded funds, options and other derivative contracts, certificates of deposit, unit investment trusts, money market instruments and similar cash equivalents and other securities. WE HAVE THE FOLLOWING POTENTIAL MATERIAL CONFLICTS OF INTEREST RELATED TO THE MANAGED ACCOUNT PROGRAM: *The adviser has contractually agreed to reimburse the Fund for operating expenses in excess of 0.65% of average net assets of the Fund, excluding interest, taxes, brokerage fees and commissions payable by the Fund in connection with the purchase or sale of portfolio securities, fees and expenses of other funds in which the Fund invests, and extraordinary expenses, including litigation expenses not incurred in the Fund’s ordinary course of business, until September 30, 2025. These expense reimbursements are subject to possible recoupment by the adviser from the Fund in future years (within the three years from the date when the amount is waived or reimbursed) if such recoupment can be achieved within the lesser of the foregoing expense limits or the then current expense limits. Similarly, the adviser is permitted to seek reimbursement from the Fund, subject to certain limitations, of fees waived or payments made by adviser to the Predecessor Fund (defined below) prior to the Predecessor Fund’s reorganization on July 28, 2023 for a period ending three years after the date of the waiver or payment. This agreement may be terminated only by the Fund’s Board of Trustees (the “Board”), upon written notice to the adviser. Managed Account Program Advisory Fee** Assets Under Management Annual Fee First $5 Million .85% Next $5 Million .70% the Managed Account Proprietary Products within Program: For these purposes, Proprietary Products are defined as products that are managed, issued or sponsored by a Financial Institution or any of its Affiliates. Bragg Financial Advisors (Advisor) serves as a Sub‑Advisor to the FPA Queens Road Small Cap Value Fund and the FPA Queens Road Value Fund. The FPA Queens Road Funds (the Funds) are open‑end, continuously offered, no‑load mutual funds. Pursuant to a management contract between the Sub‑Advisor and the Funds, the Sub‑Advisor is paid a management fee from the assets of the Funds for investment management services provided by the Sub‑Advisor. As such, the Funds are considered proprietary products. The cost of the management fee of the Funds is borne by investors in the Funds as described by the prospectus for the Funds. Effective September 1, 2018, shares of the Funds will not be purchased in accounts managed by Advisor in the Managed Account Program described in this document. However, clients who participated in the Managed Account Program prior to September 1, 2018, may own existing shares of the Funds within accounts managed by Advisor in the Managed Account Program. Client is under no obligation to invest in shares of the Funds. Next $10 Million .60% Over $20 Million .50% The Managed Account Program will have a minimum annual advisory fee of $20,000 for new clients as of April 1, 2023. Existing clients will not be subject to the above fee schedule or the minimum annual advisory fee. **This advisory fee waived for any portion of Managed Account Program assets invested in the FPA Queens Road Funds. Because Advisor is compensated directly by the FPA Queens Road Funds pursuant to its management contract, Advisor will waive the account Investment Advisory Fee that is charged to accounts in the Managed Account Program for any portion of the Managed Account Program account assets invested in the Funds. Notwithstanding the waiver of the Advisory Fee that is charged to accounts for any portion of the account invested in the Funds, Advisor has a conflict of interest in owning the Funds in accounts within the Managed Account Program. It should be noted here that while Advisor benefits incrementally by using the FPA Queens Road Funds in the client’s account, the client also benefits from this arrangement due to the fact that Advisor waives the Managed Account Program Advisory Fee for any portion of — 11 — The Firm BrochureForm ADV Part 2A \\ February 24, 2025 the client account that is invested in the FPA Queens Road Funds. The alternative to this arrangement would involve Advisor utilizing a fund managed by a third party on behalf of the client. In this case the client would bear the cost of the underlying fund in addition to the cost of the Managed Account Program account advisory fee. charges a fixed percentage of assets under management on an ongoing basis potentially creates a material conflict of interest. To mitigate such conflicts, Bragg Financial Advisors’ policies and procedures require an assessment of whether a commission‑based or fee‑based account is more suitable for the particular client (e.g., a review of trading activity, requirements for ongoing monitoring and/or investment advice, among other considerations). Furthermore, in the event Bragg recommends that a client or prospective client rollover/transfer from another IRA to an IRA managed by Bragg or switch from a commission‑ based account to fee‑based program such as the Managed Account Program, the specific fee must be disclosed to the client in advance. Bragg maintains required documentation reflecting the reason(s) such arrangement is in the best interest of the client, and specifically details the services that will be provided for the stated fee. Negotiability of Fees within the Managed Account Program: Bragg Financial Advisors retains the authority to negotiate fees within the Managed Account Program offered to clients based on a variety of factors, such as the size of a client’s account, the agreed upon level of services to be provided, grandfathering of pre‑existing fee arrangements, and preferential fee arrangements not generally available to clients (e.g., fees reduced or waived for related persons, family and friends), among others. This negotiability of fees may represent a conflict of interest. Other Conflicts related to the Managed Account Program: Representatives of third parties with whom we conduct business (such as custody/clearing firms, mutual funds, software vendors, consultants, accountants, etc.) on behalf of our clients may invite representatives of our firm to educational events, meetings, seminars or other events where meals, educational literature, promotional items, entertainment or other activities are provided at no cost to our representatives. This may create an incentive for Bragg and its representatives to use products/services offered by these firms and this may represent a material conflict of interest. Other Conflicts of Interest SUPERVISION Pursuant to industry studies, financial services regulators have noted that a firm’s failure to provide employee training or providing inadequate training to employees regarding the firm’s Impartial Conduct Standards and the policies and procedures adopted to implement and ensure compliance with these standards creates an increased potential for violations. IRA Rollover/IRA Transfer Recommendations for the Managed Account Program: A Retirement Investor or prospective Retirement leaving an employer Investor typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the Retirement Investor’s age, result in adverse tax consequences). If a representative of Bragg recommends that a client or potential client roll over/transfer their retirement plan assets into an account to be managed by Bragg Financial Advisors, such recommendation potentially creates a material conflict of interest insofar as the firm will earn an advisory fee on the rolled‑over/transferred assets. Bragg has adopted reasonable and prudent procedures to facilitate and document the consideration of the Retirement Investor’s investment alternatives which requires an assessment of the existing plan and available options. As applicable, such assessment will evaluate the fees and expenses of each option, including whether the employer pays for some or all of the plan’s administrative expenses, and the different levels of services and investments available under each option, among other considerations. Recommendations for the Managed Account Program: A recommendation that a client or prospective client (i) roll/ transfer money out of a retirement plan or any other type of account into a fee‑based account such as the Managed Account Program that will generate ongoing fees for Bragg that would not otherwise be received, even if those fees do not vary with the assets recommended or invested, or (ii) switch from a commission‑based account to an account that Bragg Financial Advisors’ policies and procedures when viewed as a whole, are reasonably and prudently designed to avoid a misalignment of the interests of our representatives with the interests of the clients they serve. Our firm’s supervisory procedures include careful screening of potential hires including verification of industry qualification and employment history, and an assessment of past misconduct and disciplinary history, if any. Firm procedures include initial and ongoing training of employees based on the nature of their responsibilities, mandating periodic reporting and/or certification of their adherence to the — 12 — The Firm BrochureForm ADV Part 2A \\ February 24, 2025 firm’s policies and procedures, and conducting periodic monitoring and testing of our policies to prevent or detect any violations of them. Individuals found to have violated procedures will be subject to disciplinary action by our firm based on the nature of the infraction. Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions reports as well as initial and annual securities holdings reports that must be submitted by the firm’s access persons. Among other things, our Code of Ethics also requires the prior approval of any acquisition of securities in a limited offering (e.g., private placement) or an initial public offering. Our code also provides for oversight, enforcement and record keeping provisions. Clients should be aware that the existence of the conflicts of interest listed in this document may impair the objectivity of our firm and our representatives when making advisory recommendations. Bragg endeavors always to put the interest of its clients first as part of our duty as a registered investment advisor. We take the following steps to address these conflicts: Bragg’s Code of Ethics further includes the firm’s policy prohibiting the use of material non‑public information. While we do not believe that we have any particular access to non‑public information, all employees are reminded that such information may not be used in a personal or professional capacity. ƒ we disclose to clients the existence of all material conflicts of interest, including the potential for our firm and our employees to earn compensation from advisory clients in addition to our firm’s advisory fees; ƒ we disclose to clients that they are not obligated to purchase recommended investment products from our employees or affiliated companies; A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by email sent to dawn@braggfinancial.com, or by calling us at (704) 377‑0261. Bragg or individuals associated with our firm will not buy securities for the firm or for themselves from our advisory clients, or sell securities owned by the firm or the individual(s) to our advisory clients. Bragg and individuals associated with our firm will not engage in agency cross transactions. ƒ we collect, maintain and document accurate, complete and relevant client background information, including the client’s financial goals, objectives and risk tolerance; ƒ our firm’s management conducts regular reviews of each client account to verify that all recommendations made to a client are suitable to the client’s needs and circumstances; ƒ we require that our employees seek prior approval of any outside employment activity so that we may ensure that any conflicts of interests in such activities are properly addressed; As previously disclosed in this Brochure, Bragg is the investment advisor to an affiliated mutual fund. Please refer to “Advisory Business” (Item 4) and “Fees and Compensation” (Item 5) for a detailed explanation of this relationship and important conflict of interest disclosure. ƒ we periodically monitor these outside employment activities to verify that any conflicts of interest continue to be properly addressed by our firm; and All access persons of our firm are required to report all personal securities transactions conducted in our affiliated mutual fund(s). ƒ we educate our employees regarding our responsibilities to our clients, including the need for having a reasonable and independent basis for the investment advice provided to clients. Our Code of Ethics is designed to assure that the personal securities transactions, activities and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that we require of our employees, including compliance with applicable federal securities laws. Our firm and/or individuals associated with our firm may buy or sell for their personal accounts, securities identical to or different from those recommended to our clients. In addition, any related person(s) may have an interest or position in certain securities which may also be recommended to a client. Bragg and our personnel owe a duty of loyalty, fairness and good faith towards our clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code. — 13 — The Firm BrochureForm ADV Part 2A \\ February 24, 2025 Item 12: Brokerage Practices It is the expressed policy of our firm that no person employed by us may purchase or sell any security prior to a transaction(s) being implemented for an advisory account, thereby preventing such employee(s) from benefiting from transactions placed on behalf of advisory accounts. As these situations represent actual or potential conflicts of interest to our clients, we have established the following policies and procedures for implementing our firm’s Code of Ethics, to ensure our firm complies with its regulatory obligations and provides our clients and potential clients with full and fair disclosure of such conflicts of interest: Selecting Custodians Bragg does not maintain custody of the assets that we manage or advise on behalf of our clients (for further information, see Item 15: Custody). Client assets must be maintained in an account at a “qualified custodian,” which is generally a broker, a bank or a trust company. We use Charles Schwab & Co. and Pershing, LLC to provide broker‑dealer and custodial services for our clients. We are independently owned and operated and are not affiliated with Charles Schwab & Co. or Pershing, LLC. 1. No principal or employee of our firm may put his or her own interest above the interest of an advisory client. 2. No principal or employee of our firm may buy or sell securities for their personal portfolio(s) where their decision is a result of information received as a result of his or her employment unless the information is also available to the investing public. In selecting recommended providers of broker‑dealer and custodial services, we weigh such criteria as the provider’s experience, size, reputation, financial strength, past exhibited service levels, cost to our clients, breadth of available investment products and the ability to efficiently execute trades in client accounts. We periodically evaluate the providers with whom we work and compare them to other firms available in the marketplace using the aforementioned criteria to ensure that our recommended providers of broker‑dealer and custodial services continue to serve the best interests of our clients. 3. It is the expressed policy of our firm that no person employed by us may purchase or sell any security prior to a transaction(s) being implemented for an advisory account. This prevents such employees from benefiting from transactions placed on behalf of advisory accounts. Bragg requires that it be provided with the client’s written authorization to determine the provider of broker‑dealer and custodial services to be used for client accounts. 4. Our firm requires prior approval for any IPO or private placement investments by related persons of the firm. 5. We maintain a list of all reportable securities holdings for our firm and anyone associated with this advisory practice that has access to advisory recommendations (“access person”). These holdings are reviewed on a regular basis by our firm’s Chief Compliance Officer or his/her designee. 6. We have established procedures for the maintenance of all required books and records. Clients will open their account(s) with the broker‑dealer/ custodian by filling out the applicable paperwork that we prepare for their review and signature. Bragg will not provide investment advisory services to clients who maintain accounts with broker‑dealer/custodial firms with which we do not have an arrangement for conducting trading and management services. 7. All of our principals and employees must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. 8. We require delivery and acknowledgement of the Code of Ethics by each supervised person of our firm. 9. We have established policies requiring the reporting of Code of Ethics violations to our senior management. 10. Any individual who violates any of the above restrictions is subject to disciplinary action or termination. Trade Aggregation and Allocating Trades The primary objective in placing trades for the purchase and sale of securities for client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of order, 3) difficulty of execution, 4) confidentiality, and 5) skill required of the custodian. Bragg will execute transactions through the Custodian. At times, Bragg may aggregate orders in a block trade or trades when securities are purchased or sold through the custodian for multiple accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre‑allocation or other — 14 — The Firm BrochureForm ADV Part 2A \\ February 24, 2025 written statement. This will be done in a way that does not consistently advantage or disadvantage any particular client account. REPORTS: In addition to the monthly statements and confirmations of transactions that clients receive from their broker‑dealer/custodian, we provide quarterly reports detailing account performance, balances, holdings, and fees to be charged. Financial Planning Services REVIEWS: While reviews may occur at different stages depending on the nature and terms of the specific engagement, typically no formal reviews will be conducted for Financial Planning clients unless otherwise contracted for. While Bragg may periodically use aggregated firmwide trading for client accounts, this is not the typical process employed due to a number of factors including client‑ specific objectives and/or constraints such as taxable gain tolerances, cash/liquidity requirements, outstanding/ pending trade recommendations, position size limitations, and/or asset allocation considerations. Due to these factors, the majority of trading is completed at the account level as opposed to being completed on an aggregated firmwide basis. REPORTS: Additional reports will not typically be provided unless otherwise contracted for. Mutual Fund Portfolio Management REVIEWS: Bragg continually reviews and monitors the Mutual Funds’ holdings in accordance with the investment objectives as detailed in the Funds’ Prospectus. Soft Dollars Soft dollars are revenue programs offered by a broker/dealer or custodian whereby an advisor enters into an agreement to place security trades with a broker/dealer or custodian in exchange for research and other services. Bragg does not participate in soft dollar programs sponsored or offered by any broker/dealer or custodian. REPORTS: Clients should refer to the Funds’ Prospectus for information regarding regular reports to the fund by Bragg. Item 14: Client Referrals and Other Compensation It is Bragg’s policy not to engage solicitors or to pay related or non‑related persons for referring potential clients to our firm. Discretionary Authority Bragg manages client accounts on discretion with few exceptions. If client desires to impose any limitation to Bragg’s discretionary authority, this limitation must be provided to Bragg in writing and agreed to by Bragg. Client may change/amend these limitations as desired and if agreed to by Bragg. Such amendments must be provided to us in writing. Item 13: Review of Accounts It is Bragg’s policy not to accept or allow our related persons to accept any form of compensation, including cash, sales awards or other prizes, from a non‑client in conjunction with the advisory services we provide to our clients. Item 15: Custody We previously disclosed in the “Fees and Compensation” section (Item 5) of this Brochure that our firm directly debits advisory fees from client accounts. Individual Portfolio Management‑Managed Account Program REVIEWS: While the underlying securities within Individual Portfolio Management Services accounts are continually monitored, these accounts are reviewed periodically to adhere to the allocations as described in the investment policy statement. Accounts are reviewed in the context of each client’s stated investment objectives and guidelines. More frequent reviews may be triggered by material changes in variables such as the client’s individual circumstances, or the market, political or economic environment. These accounts are reviewed by Benton S. Bragg. As part of this billing process, the client’s third‑party custodian is advised of the amount of the fee to be deducted from that client’s account. On at least a quarterly basis, the custodian is required to send to the client a statement showing all transactions, including fees charged, within the account during the reporting period. — 15 — The Firm BrochureForm ADV Part 2A \\ February 24, 2025 other type events pertaining to the client’s investment assets. Clients are responsible to instruct each custodian to forward the client copies of all proxies and shareholder communications relating to the client’s investment assets. We do not offer any consulting assistance regarding proxy issues to clients. Bragg calculates client advisory fees using a portfolio management and billing system provided by a third‑party software firm. Because the broker‑dealer/custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review their custodial statements to verify the accuracy of the fee calculation. Clients should contact us directly if they believe that there may be an error in their statement or in the calculation of fees. We only vote proxies for the following types of accounts: ƒ Discretionary ERISA Accounts ƒ FPA Queens Road Mutual Funds In addition to the periodic statements that clients receive directly from their broker‑dealer/custodian, Bragg also produces and provides separate account statements directly to our clients on a quarterly basis. We urge our clients to carefully compare the statements provided directly by Bragg to the statements directly provided by the broker‑dealer/custodian. Our firm does not have actual or constructive custody of client accounts. We will vote proxies in accordance with our established policies and procedures. Our firm will retain all proxy voting books and records for the requisite period of time, including a copy of each proxy statement received, a record of each vote cast, a copy of any document created by us that was material to making a decision on how to vote proxies, and a copy of each written client request for information on how the advisor voted proxies. If our firm has a conflict of interest in voting a particular action, we will notify the client of the conflict and retain an independent third party to cast a vote. Clients may obtain a copy of our complete proxy voting policies and procedures by contacting Dawn Cannon at (704) 377‑0261. Item 16: Investment Discretion to provide discretionary asset Clients may hire us management services, in which case we place trades in a client’s account without contacting the client prior to each trade to obtain the client’s permission. Our discretionary authority includes the ability to do the following without contacting the client: 1. Determine the security to buy or sell; and/or 2. Determine the amount of the security to buy or sell We will neither advise nor act on behalf of the client in legal proceedings involving companies whose securities are held in the client’s account(s), including, but not limited to, the filing of “Proofs of Claim” in class action settlements. If desired, clients may direct us to transmit copies of class action notices to the client or a third party. Upon such direction, we will make commercially reasonable efforts to forward such notices in a timely manner. Clients give us discretionary authority when they sign a Discretionary Managed Account Agreement with our firm and may limit this authority by giving us written instructions. Clients may also change/amend such limitations by once again providing us with written instructions. Item 18: Financial Information Bragg has no additional financial circumstances to report. Under no circumstances do we require or solicit payment of fees in excess of $1,200 per client more than six months in advance of services rendered. Therefore, we are not required to include a financial statement. responsibility Bragg has not been the subject of a bankruptcy petition at any time during the past ten years. Item 17: Voting Client Securities As a matter of firm policy, we do not vote proxies on behalf of clients. Therefore, although our firm may provide investment advisory services relative to client investment assets, clients maintain exclusive for: (1) directing the manner in which 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 — 16 — The Firm BrochureForm ADV Part 2A \\ February 24, 2025 Benton S. Bragg Part 2B of Form ADV \\ September 9, 2024 This brochure supplement provides information about Benton S. Bragg that supplements the Bragg Financial Advisors brochure. You should have received a copy of that brochure. Please contact Dawn Cannon if you did not receive BFA’s brochure or if you have any questions about the contents of this supplement. Additional information about Benton S. Bragg is available on the SEC’s website at www.adviserinfo.sec.gov 1031 S. Caldwell Street, Suite 200 \\ Charlotte, North Carolina 28203 \\ www.braggfi nancial.com \\ (704) 377‑0261 — 17 —  Benton S. Bragg Form ADV Part 2B \\ September 9, 2024 ƒ Chartered Financial Analyst; CFA Institute; 2000 Item 2: Educational, Background and Business Experience Full Legal Name: Benton S. Bragg Born: 1968 Education ƒ Wake Forest University; BA, History with a minor in English; 1990 ƒ Wake Forest University; MBA, Masters in Business Administration; 1997 Business Experience ƒ Bragg Financial Advisors, Inc.; President & CEO, Chairman of Investment Committee, and Client Advisor; from 05/1993 to Present ƒ Nations Bank of NC; Branch Manager; from 06/1990 to 05/1993 Designations The Chartered Financial Analyst (CFA) charter is a globally respected, graduate‑level investment credential established in 1962 and awarded by CFA Institute — the largest global association of investment professionals. There are currently more than 90,000 CFA charter holders working in 134 countries. To earn the CFA charter, candidates must: 1) pass three sequential, six‑ hour examinations; 2) have at least four years of qualifi ed professional investment experience; 3) join CFA Institute as members; and 4) commit to abide by, and annually reaffi rm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. High Ethical Standards: The CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an active professional conduct program, require CFA charter holders to: ƒ Place their clients’ interests ahead of their own ƒ Maintain independence and objectivity ƒ Act with integrity ƒ Maintain and improve their professional competence ƒ Disclose confl icts of interest and legal matters Benton S. Bragg has earned the following designations and is in good standing with the granting authorities: ƒ Certifi ed Financial Planner; Certifi ed Financial Planner Board of Standards; 1995 curriculum provides a In order to be licensed to use the CFP® mark, an individual must meet the following qualifi cations, as specifi ed by the Certifi ed Financial Planner Board of Standards, Inc. (CFP® Board): Examination: An individual must successfully complete the CFP® Board’s comprehensive certifi cation examination, which tests the individual’s knowledge on a multitude of key fi nancial planning topics. Experience: Depending on the level of degree work completed in a collegiate setting, an individual must acquire three to fi ve years of fi nancial planning‑related experience prior to receiving the right to use the CFP® mark. Ethics: An individual must voluntarily ascribe to the CFP® Board’s code of ethics and additional requirements as mandated. This voluntary decision empowers the CFP® Board to take action if a CFP® licensee should violate the code of ethics. Such violations could lead to disciplinary action, including the permanent revocation of the right to use the CFP® mark. Education: A CFP® licensee must obtain 30 hours of continuing education every two years in the body of knowledge pertaining to fi nancial planning areas such as estate planning, retirement planning, investment management, tax planning, employee benefi ts and insurance. Global Recognition: Passing the three CFA exams is a diffi cult feat that requires extensive study (successful candidates report spending an average of 300 hours of study per level). Earning the CFA charter demonstrates mastery of many of the advanced skills needed for investment analysis and decision making in today’s quickly evolving global fi nancial industry. As a result, employers and clients are increasingly seeking CFA charter holders—often making the charter a prerequisite for employment. Additionally, regulatory bodies in 22 countries and territories recognize the CFA charter as a proxy for meeting certain licensing requirements, and more than 125 colleges and universities around the world have incorporated a majority of the CFA Program curriculum into their own fi nance courses. Comprehensive and Current Knowledge: The CFA Program comprehensive framework of knowledge for investment decision making and is fi rmly grounded in the knowledge and skills used every day in the investment profession. The three levels of the CFA Program test a profi ciency with a wide range of fundamental and advanced investment topics, including ethical and professional standards, fi xed‑income and equity analysis, alternative and derivative investments, economics, fi nancial reporting standards, portfolio management, and wealth planning. The CFA Program curriculum is updated every year by experts from around the world to ensure that candidates learn the most relevant and practical new tools, ideas, — 18 —  Benton S. Bragg Form ADV Part 2B \\ September 9, 2024 learn more about the CFA charter, visit and investment and wealth management skills to refl ect the dynamic and complex nature of the profession. To www.cfainstitute.org. Item 5: Additional Compensation Benton S. Bragg does not receive any economic benefi t from a non‑advisory client for the provision of advisory services. Item 3: Disciplinary Information Benton S. Bragg has no reportable disciplinary history. Item 6: Supervision Benton S. Bragg reports directly to Dawn M. Cannon, Chief Compliance Offi cer. Dawn can be reached at 704‑714‑7713 and at dawn@braggfi nancial.com. Item 4: Other Business Activities A. Investment‑Related Activities ƒ Member of Finance Committee, Board of Advisors, and Investment Committee of various non‑profi t organizations. Benton does not receive any form of compensation from these activities. B. Non Investment‑Related Activities ƒ Investments in passive real estate partnerships. — 19 —  Phillips M. Bragg Part 2B of Form ADV \\ February 27, 2025 This brochure supplement provides information about Phillips M. Bragg that supplements the Bragg Financial Advisors brochure. You should have received a copy of that brochure. Please contact Dawn Cannon if you did not receive BFA’s brochure or if you have any questions about the contents of this supplement. Additional information about Phillips M. Bragg is available on the SEC’s website at www.adviserinfo.sec.gov 1031 S. Caldwell Street, Suite 200 \\ Charlotte, North Carolina 28203 \\ www.braggfi nancial.com \\ (704) 377‑0261 — 20 —  Phillips M. Bragg Form ADV Part 2B \\ February 27, 2025 Item 2: Educational, Background and Business Experience Full Legal Name: Phillips M. Bragg Born: 1971 Education ƒ Wake Forest University; BA, English; 1993 Business Experience ƒ Bragg Financial Advisors, Inc.; Vice President, Director of Estate & Charitable Planning, and Client Advisor; from 06/1996 to Present ƒ Wachovia Bank; Trust Offi cer; from 06/1993 to 06/1996 Designations Phillips M. Bragg has earned the following designations and is in good standing with the granting authorities: ƒ Certifi ed Financial Planner; Certifi ed Financial Planner Board of Standards; 1996 Professional discipline engaged in estate planning requirement—The applicant must be presently and signifi cantly engaged in “estate planning activities” as an attorney, an accountant, an insurance professional and fi nancial planner, or a trust offi cer. Experience requirement: A minimum of fi ve (5) years of experience engaged in estate planning and estate planning activities is required in one or more of the professional disciplines described above to apply for the designation. Membership requirement: AEP® applicants are required to be members of, and continuously maintain membership in, an affi liated local or regional estate planning council where such membership is available. Professional reputation and character requirement: An applicant must continuously be in good standing with the applicant’s respective professional organization and/or license authority. Commitment to NAEPC Code of Ethics requirement: The applicant must sign a declaration statement to continuously abide by the NAEPC Code of Ethics. Dedicated to team concept requirement: The applicant must acknowledge a commitment to the team concept of estate planning by signing a declaration statement. Continuing education requirement: The applicant must satisfy a minimum of thirty (30) hours of continuing education during the previous twenty‑four (24) months. Item 3: Disciplinary Information Phillips M. Bragg has no reportable disciplinary history. Item 4: Other Business Activities A. Investment‑Related Activities None B. Non Investment‑Related Activities ƒ Investment in business ventures. ƒ Investments in passive real estate partnerships. ƒ Investment in residential rental property. ƒ Treasurer of a fi shing club. In order to be licensed to use the CFP® mark, an individual must meet the following qualifi cations, as specifi ed by the Certifi ed Financial Planner Board of Standards, Inc. (CFP® Board): Examination: An individual must successfully complete the CFP® Board’s comprehensive certifi cation examination, which tests the individual’s knowledge on a multitude of key fi nancial planning topics. Experience: Depending on the level of degree work completed in a collegiate setting, an individual must acquire three to fi ve years of fi nancial planning‑related experience prior to receiving the right to use the CFP® mark. Ethics: An individual must voluntarily ascribe to the CFP® Board’s code of ethics and additional requirements as mandated. This voluntary decision empowers the CFP® Board to take action if a CFP® licensee should violate the code of ethics. Such violations could lead to disciplinary action, including the permanent revocation of the right to use the CFP® mark. Education: A CFP® licensee must obtain 30 hours of continuing education every two years in the body of knowledge pertaining to fi nancial planning areas such as estate planning, retirement planning, investment management, tax planning, employee benefi ts and insurance. Item 5: Additional Compensation Phillips M. Bragg does not receive any economic benefi t from a non‑advisory client for the provision of advisory services. ƒ Accredited Estate Planner; National Association of Estate Planners and Councils; 2013 In order to be licensed to use the AEP® mark, an individual must meet the following qualifi cations, as specifi ed by the National Association of Estate Planners & Councils: Item 6: Supervision Phillips M. Bragg reports directly to Dawn M. Cannon, Chief Compliance Offi cer. Dawn can be reached at 704‑714‑7713 and at dawn@braggfi nancial.com. — 21 —  John F. Bragg III Part 2B of Form ADV \\ February 27, 2025 This brochure supplement provides information about John F. Bragg III that supplements the Bragg Financial Advisors brochure. You should have received a copy of that brochure. Please contact Dawn Cannon if you did not receive BFA’s brochure or if you have any questions about the contents of this supplement. Additional information about John F. Bragg III is available on the SEC’s website at www.adviserinfo.sec.gov 1031 S. Caldwell Street, Suite 200 \\ Charlotte, North Carolina 28203 \\ www.braggfi nancial.com \\ (704) 377‑0261 — 22 —  John F. Bragg III Form ADV Part 2B \\ February 27, 2025 Item 2: Educational, Background and Business Experience Full Legal Name: John F. Bragg III Born: 1966 Education ƒ Wake Forest University; BA, Communications; 1988 Business Experience Ethics: An individual must voluntarily ascribe to the CFP® Board’s code of ethics and additional requirements as mandated. This voluntary decision empowers the CFP® Board to take action if a CFP® licensee should violate the code of ethics. Such violations could lead to disciplinary action, including the permanent revocation of the right to use the CFP® mark. Education: A CFP® licensee must obtain 30 hours of continuing education every two years in the body of knowledge pertaining to fi nancial planning areas such as estate planning, retirement planning, investment management, tax planning, employee benefi ts and insurance. ƒ Bragg Financial Advisors, Inc.; Vice President, Director of Corporate Plans, and Client Advisor; from 12/1990 to Present ƒ Hinrichs Financial Group.; Sales Associate; from 08/1988 to 12/1990 Item 3: Disciplinary Information John F. Bragg III has no reportable disciplinary history. Designations Item 4: Other Business Activities A. Investment‑Related Activities John F. Bragg III has earned the following designation and is in good standing with the granting authority: ƒ Certifi ed Financial Planner; Certifi ed Financial Planner None Board of Standards; 1996 B. Non Investment‑Related Activities Investments in passive real estate partnerships. Item 5: Additional Compensation John F. Bragg III does not receive any economic benefi t from a non‑advisory client for the provision of advisory services. Item 6: Supervision John F. Bragg III reports directly to Dawn M. Cannon, Chief Compliance Offi cer. Dawn can be reached at 704‑714‑7713 and at dawn@braggfi nancial.com. In order to be licensed to use the CFP® mark, an individual must meet the following qualifi cations, as specifi ed by the Certifi ed Financial Planner Board of Standards, Inc. (CFP® Board): Examination: An individual must successfully complete the CFP® Board’s comprehensive certifi cation examination, which tests the individual’s knowledge on a multitude of key fi nancial planning topics. Experience: Depending on the level of degree work completed in a collegiate setting, an individual must acquire three to fi ve years of fi nancial planning‑related experience prior to receiving the right to use the CFP® mark. — 23 —  Steven H. Scruggs Part 2B of Form ADV \\ March 7, 2022 This brochure supplement provides information about Steven H. Scruggs that supplements the Bragg Financial Advisors brochure. You should have received a copy of that brochure. Please contact Dawn Cannon if you did not receive BFA’s brochure or if you have any questions about the contents of this supplement. Additional information about Steven H. Scruggs is available on the SEC’s website at www.adviserinfo.sec.gov 1031 S. Caldwell Street, Suite 200 \\ Charlotte, North Carolina 28203 \\ www.braggfi nancial.com \\ (704) 377‑0261 — 24 —  Steven H. Scruggs Form ADV Part 2B \\ March 7, 2022 Item 2: Educational, Background and Business Experience Full Legal Name: Steven H. Scruggs Born: 1969 Education ƒ North Carolina State University; BA, Business Management; 1992 ƒ Wake Forest University; MBA; Masters in Business Administration; 1996 Business Experience curriculum provides a ƒ Bragg Financial Advisors, Inc.; Director of Research, Member of Investment Committee and Senior Portfolio Manager; from 01/2000 to Present ƒ Reliance Personal Insurance; Product Manager; from 02/1999 to 12/1999 ƒ Integon Insurance; Product Manager; from 05/1996 to 02/1999 Designations Steven H. Scruggs has earned the following designation and is in good standing with the granting authority: ƒ Chartered Financial Analyst; CFA Institute; 2002 learn more about the CFA charter, visit study per level). Earning the CFA charter demonstrates mastery of many of the advanced skills needed for investment analysis and decision making in today’s quickly evolving global fi nancial industry. As a result, employers and clients are increasingly seeking CFA charter holders—often making the charter a prerequisite for employment. Additionally, regulatory bodies in 22 countries and territories recognize the CFA charter as a proxy for meeting certain licensing requirements, and more than 125 colleges and universities around the world have incorporated a majority of the CFA Program curriculum into their own fi nance courses. Comprehensive and Current Knowledge: The CFA Program comprehensive framework of knowledge for investment decision making and is fi rmly grounded in the knowledge and skills used every day in the investment profession. The three levels of the CFA Program test a profi ciency with a wide range of fundamental and advanced investment topics, including ethical and professional standards, fi xed‑income and equity analysis, alternative and derivative investments, economics, fi nancial reporting standards, portfolio management, and wealth planning. The CFA Program curriculum is updated every year by experts from around the world to ensure that candidates learn the most relevant and practical new tools, ideas, and investment and wealth management skills to refl ect the dynamic and complex nature of the profession. To www.cfainstitute.org. Item 3: Disciplinary Information Steven H. Scruggs has no reportable disciplinary history. Item 4: Other Business Activities A. Investment‑Related Activities None B. Non Investment‑Related Activities Investments in passive real estate partnerships. Item 5: Additional Compensation Steven H. Scruggs does not receive any economic benefi t from a non‑advisory client for the provision of advisory services. The Chartered Financial Analyst (CFA) charter is a globally respected, graduate‑level investment credential established in 1962 and awarded by CFA Institute — the largest global association of investment professionals. There are currently more than 90,000 CFA charter holders working in 134 countries. To earn the CFA charter, candidates must: 1) pass three sequential, six‑ hour examinations; 2) have at least four years of qualifi ed professional investment experience; 3) join CFA Institute as members; and 4) commit to abide by, and annually reaffi rm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. High Ethical Standards: The CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an active professional conduct program, require CFA charter holders to: ƒ Place their clients’ interests ahead of their own ƒ Maintain independence and objectivity ƒ Act with integrity ƒ Maintain and improve their professional competence ƒ Disclose confl icts of interest and legal matters Item 6: Supervision Steven H. Scruggs reports directly to Dawn M. Cannon, Chief Compliance Offi cer. Dawn can be reached at 704‑714‑7713 and at dawn@braggfi nancial.com. Global Recognition: Passing the three CFA exams is a diffi cult feat that requires extensive study (successful candidates report spending an average of 300 hours of — 25 —  Anthony Bykovsky Part 2B of Form ADV \\ March 7, 2022 This brochure supplement provides information about Anthony Bykovsky that supplements the Bragg Financial Advisors brochure. You should have received a copy of that brochure. Please contact Dawn Cannon if you did not receive BFA’s brochure or if you have any questions about the contents of this supplement. Additional information about Anthony Bykovsky is available on the SEC’s website at www.adviserinfo.sec.gov 1031 S. Caldwell Street, Suite 200 \\ Charlotte, North Carolina 28203 \\ www.braggfi nancial.com \\ (704) 377‑0261 — 26 —  Anthony Bykovsky Form ADV Part 2B \\ March 7, 2022 ƒ Act with integrity ƒ Maintain and improve their professional competence ƒ Disclose confl icts of interest and legal matters Item 2: Educational, Background and Business Experience Full Legal Name: Anthony Bykovsky Born: 1983 Education ƒ Anderson University; BA, Business Management, Minor in Economics; 06/2006 ƒ Ball State University; Master of Business Administration, Concentration in Finance; 07/2009 Business Experience ƒ Bragg Financial Advisors, Inc.; Portfolio Manager, Member of the Investment Committee; from 08/2021 to Present ƒ Barings; Associate Director, Global Business Development Group; 11/2017 to 07/2021 ƒ Bedel Financial Consulting, Inc.; Portfolio Manager, curriculum provides a Operations Manager and Associate Portfolio Manager; 05/2012 to 08/2017 ƒ City Real Estate Advisors; Financial Analyst; 02/2010 to 05/2012 Designations Anthony Bykovsky has earned the following designation and is in good standing with the granting authority: ƒ Chartered Financial Analyst; CFA Institute; 2014 learn more about the CFA charter, visit Global Recognition: Passing the three CFA exams is a diffi cult feat that requires extensive study (successful candidates report spending an average of 300 hours of study per level). Earning the CFA charter demonstrates mastery of many of the advanced skills needed for investment analysis and decision making in today’s quickly evolving global fi nancial industry. As a result, employers and clients are increasingly seeking CFA charter holders—often making the charter a prerequisite for employment. Additionally, regulatory bodies in 22 countries and territories recognize the CFA charter as a proxy for meeting certain licensing requirements, and more than 125 colleges and universities around the world have incorporated a majority of the CFA Program curriculum into their own fi nance courses. Comprehensive and Current Knowledge: The CFA Program comprehensive framework of knowledge for investment decision making and is fi rmly grounded in the knowledge and skills used every day in the investment profession. The three levels of the CFA Program test a profi ciency with a wide range of fundamental and advanced investment topics, including ethical and professional standards, fi xed‑income and equity analysis, alternative and derivative investments, economics, fi nancial reporting standards, portfolio management, and wealth planning. The CFA Program curriculum is updated every year by experts from around the world to ensure that candidates learn the most relevant and practical new tools, ideas, and investment and wealth management skills to refl ect the dynamic and complex nature of the profession. To www.cfainstitute.org. Item 3: Disciplinary Information Anthony Bykovsky has no reportable disciplinary history. Item 4: Other Business Activities A. Investment‑Related Activities None B. Non Investment‑Related Activities None The Chartered Financial Analyst (CFA) charter is a globally respected, graduate‑level investment credential established in 1962 and awarded by CFA Institute — the largest global association of investment professionals. There are currently more than 90,000 CFA charter holders working in 134 countries. To earn the CFA charter, candidates must: 1) pass three sequential, six‑ hour examinations; 2) have at least four years of qualifi ed professional investment experience; 3) join CFA Institute as members; and 4) commit to abide by, and annually reaffi rm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. High Ethical Standards: The CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an active professional conduct program, require CFA charter holders to: ƒ Place their clients’ interests ahead of their own ƒ Maintain independence and objectivity — 27 —  Anthony Bykovsky Form ADV Part 2B \\ March 7, 2022 Item 5: Additional Compensation Anthony Bykovsky does not receive any economic benefi t from a non‑advisory client for the provision of advisory services. Item 6: Supervision Anthony Bykovsky reports directly to Dawn M. Cannon, Chief Compliance Offi cer. Dawn can be reached at 704‑714‑7713 and at dawn@braggfi nancial.com. — 28 —  Clint Townsend Part 2B of Form ADV \\ June 14, 2023 This brochure supplement provides information about Clint Townsend that supplements the Bragg Financial Advisors brochure. You should have received a copy of that brochure. Please contact Dawn Cannon if you did not receive BFA’s brochure or if you have any questions about the contents of this supplement. Additional information about Clint Townsend is available on the SEC’s website at www.adviserinfo.sec.gov 1031 S. Caldwell Street, Suite 200 \\ Charlotte, North Carolina 28203 \\ www.braggfi nancial.com \\ (704) 377‑0261 — 29 —  Clint Townsend Form ADV Part 2B \\ June 14, 2023 Item 2: Educational, Background and Business Experience Full Legal Name: Clinton D. Townsend Born: 1988 Education ƒ North Carolina State University; BS, Business in Finance; BS, Administration, Concentration Accounting, Concentration in Financial Analysis; 2010 ƒ North Carolina State University; Masters, Accounting; 2011 Business Experience curriculum provides a ƒ Bragg Financial Advisors, Inc.; Client Advisor; from 05/2023 to Present ƒ Laurel Wealth Advisors, LLC; Client Advisor; from 01/2016 to 04/2023 ƒ Dixon Hughes Goodman, LLP; Senior Associate, from 01/2014 to 01/2016 ƒ Miller McNeish Breedlove, PLLC; Associate from 06/2011 to 12/2013 Designations Clint Townsend has earned the following designations and is in good standing with the granting authorities: ƒ Chartered Financial Analyst; CFA Institute; 2020 learn more about the CFA charter, visit candidates report spending an average of 300 hours of study per level). Earning the CFA charter demonstrates mastery of many of the advanced skills needed for investment analysis and decision making in today’s quickly evolving global fi nancial industry. As a result, employers and clients are increasingly seeking CFA charter holders—often making the charter a prerequisite for employment. Additionally, regulatory bodies in 22 countries and territories recognize the CFA charter as a proxy for meeting certain licensing requirements, and more than 125 colleges and universities around the world have incorporated a majority of the CFA Program curriculum into their own fi nance courses. Comprehensive and Current Knowledge: The CFA comprehensive Program framework of knowledge for investment decision making and is fi rmly grounded in the knowledge and skills used every day in the investment profession. The three levels of the CFA Program test a profi ciency with a wide range of fundamental and advanced investment topics, including ethical and professional standards, fi xed‑income and equity analysis, alternative and derivative investments, economics, fi nancial reporting standards, portfolio management, and wealth planning. The CFA Program curriculum is updated every year by experts from around the world to ensure that candidates learn the most relevant and practical new tools, ideas, and investment and wealth management skills to refl ect the dynamic and complex nature of the profession. To www.cfainstitute.org. ƒ Certifi ed Public Accountant; North Carolina State Board of CPA Examiners; 2012 the The Chartered Financial Analyst (CFA) charter is a globally respected, graduate‑level investment credential established in 1962 and awarded by CFA Institute — the largest global association of investment professionals. There are currently more than 90,000 CFA charter holders working in 134 countries. To earn the CFA charter, candidates must: 1) pass three sequential, six‑ hour examinations; 2) have at least four years of qualifi ed professional investment experience; 3) join CFA Institute as members; and 4) commit to abide by, and annually reaffi rm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. High Ethical Standards: The CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an active professional conduct program, require CFA charter holders to: ƒ Place their clients’ interests ahead of their own ƒ Maintain independence and objectivity ƒ Act with integrity ƒ Maintain and improve their professional competence ƒ Disclose confl icts of interest and legal matters Global Recognition: Passing the three CFA exams is a diffi cult feat that requires extensive study (successful In order to be licensed as a CPA in the state of North following individual must meet Carolina, an qualifi cations as specifi ed by the North Carolina State Board of CPA Examiners: Examination: An individual must successfully pass all parts of the CPA exam. Experience: Individuals must have completed one of the following for licensure: one year in public accounting or the fi eld of accounting under the direct supervision of a properly licensed CPA, four years in the fi eld of accounting, four years teaching accounting at an accredited college or university, four years of experience as a self employed individual in accounting. Ethics: Within one year prior to applying for certifi cation with North Carolina, a certifi cate applicant must complete an eight hour course on the North Carolina Accountancy Statutes and Rules. Upon receiving a CPA certifi cate, all individuals must complete an ethics course each year. Education: All North Carolina CPAs must complete 40 hours of continuing education each year. — 30 —  Clint Townsend Form ADV Part 2B \\ June 14, 2023 Item 3: Disciplinary Information Clint Townsend has no reportable disciplinary history. Item 5: Additional Compensation Clint Townsend does not receive any economic benefi t from a non‑advisory client for the provision of advisory services. Item 4: Other Business Activities A. Investment‑Related Activities None B. Non Investment‑Related Activities Item 6: Supervision Clint Townsend reports directly to Dawn M. Cannon, Chief Compliance Offi cer. Dawn can be reached at 704‑714‑7713 and at dawn@braggfi nancial.com. None — 31 —  Evan A. Anderson Part 2B of Form ADV \\ March 5, 2024 This brochure supplement provides information about Evan A. Anderson that supplements the Bragg Financial Advisors brochure. You should have received a copy of that brochure. Please contact Dawn Cannon if you did not receive BFA’s brochure or if you have any questions about the contents of this supplement. Additional information about Evan A. Anderson is available on the SEC’s website at www.adviserinfo.sec.gov 1031 S. Caldwell Street, Suite 200 \\ Charlotte, North Carolina 28203 \\ www.braggfi nancial.com \\ (704) 377‑0261 — 32 —  Evan A. Anderson Form ADV Part 2B \\ March 5, 2024 Item 2: Educational, Background and Business Experience Full Legal Name: Evan A. Anderson Born: 1977 Education: A CFP® licensee must obtain 30 hours of continuing education every two years in the body of knowledge pertaining to fi nancial planning areas such as estate planning, retirement planning, investment management, tax planning, employee benefi ts and insurance. Education ƒ Certifi ed Public Accountant; North Carolina State Board ƒ University of North Carolina at Chapel Hill; BA, of CPA Examiners; 2004 Exercise and Sport Science, Minor in Chemistry; 1999 ƒ University of North Carolina at Chapel Hill; Masters, the Accounting; 2003 Business Experience ƒ Bragg Financial Advisors, Inc.; Director of Advice and Client Advisor; from 08/2021 to Present ƒ Wells Fargo; Regional Wealth Planning Manager; from 04/2013 to 07/2021 ƒ Wells Fargo; Senior Wealth Planner and Regional Financial Planner; from 06/2005 to 04/2013 ƒ Deloitte Tax, LLP; Staff Consultant; from 06/2003 to 06/2005 Designations Evan A. Anderson has earned the following designations and is in good standing with the granting authorities: ƒ Certifi ed Financial Planner; Certifi ed Financial Planner Board of Standards; 2005 In order to be licensed as a CPA in the state of North Carolina, an following individual must meet qualifi cations as specifi ed by the North Carolina State Board of CPA Examiners: Examination: An individual must successfully pass all parts of the CPA exam. Experience: Individuals must have completed one of the following for licensure: one year in public accounting or the fi eld of accounting under the direct supervision of a properly licensed CPA, four years in the fi eld of accounting, four years teaching accounting at an accredited college or university, four years of experience as a self employed individual in accounting. Ethics: Within one year prior to applying for certifi cation with North Carolina, a certifi cate applicant must complete an eight hour course on the North Carolina Accountancy Statutes and Rules. Upon receiving a CPA certifi cate, all individuals must complete an ethics course each year. Education: All North Carolina CPAs must complete 40 hours of continuing education each year. Item 3: Disciplinary Information Evan A. Anderson has no reportable disciplinary history. Item 4: Other Business Activities A. Investment‑Related Activities None B. Non Investment‑Related Activities None Item 5: Additional Compensation Evan A. Anderson does not receive any economic benefi t from a non‑advisory client for the provision of advisory services. In order to be licensed to use the CFP® mark, an individual must meet the following qualifi cations, as specifi ed by the Certifi ed Financial Planner Board of Standards, Inc. (CFP® Board): Examination: An individual must successfully complete the CFP® Board’s comprehensive certifi cation examination, which tests the individual’s knowledge on a multitude of key fi nancial planning topics. Experience: Depending on the level of degree work completed in a collegiate setting, an individual must acquire three to fi ve years of fi nancial planning‑related experience prior to receiving the right to use the CFP® mark. Ethics: An individual must voluntarily ascribe to the CFP® Board’s code of ethics and additional requirements as mandated. This voluntary decision empowers the CFP® Board to take action if a CFP® licensee should violate the code of ethics. Such violations could lead to disciplinary action, including the permanent revocation of the right to use the CFP® mark. Item 6: Supervision Evan A. Anderson reports directly to Dawn M. Cannon, Chief Compliance Offi cer. Dawn can be reached at 704‑714‑7713 and at dawn@braggfi nancial.com. — 33 —  George W. Climer III Part 2B of Form ADV \\ July 18, 2024 This brochure supplement provides information about George W. Climer III that supplements the Bragg Financial Advisors brochure. You should have received a copy of that brochure. Please contact Dawn Cannon if you did not receive BFA’s brochure or if you have any questions about the contents of this supplement. Additional information about George W. Climer III is available on the SEC’s website at www.adviserinfo.sec.gov 1031 S. Caldwell Street, Suite 200 \\ Charlotte, North Carolina 28203 \\ www.braggfi nancial.com \\ (704) 377‑0261 — 34 —  George W. Climer III Form ADV Part 2B \\ July 18, 2024 Item 2: Educational, Background and Business Experience Full Legal Name: George W. Climer III Born: 1971 Education ƒ University of North Carolina at Chapel Hill; BA, English; Minor, Business; 1993 ƒ Wake Forest University; MBA, Masters in Business Administration; 2000 Ethics: An individual must voluntarily ascribe to the CFP® Board’s code of ethics and additional requirements as mandated. This voluntary decision empowers the CFP® Board to take action if a CFP® licensee should violate the code of ethics. Such violations could lead to disciplinary action, including the permanent revocation of the right to use the CFP® mark. Education: A CFP® licensee must obtain 30 hours of continuing education every two years in the body of knowledge pertaining to fi nancial planning areas such as estate planning, retirement planning, investment management, tax planning, employee benefi ts and insurance. Business Experience ƒ Bragg Financial Advisors, Inc.; Director of Market Strategy and Client Advisor; from 07/2013 to Present ƒ Sun Trust Bank; Client Advisor and Senior Vice Item 3: Disciplinary Information George W. Climer III has no reportable disciplinary history. President; from 10/2002 to 06/2013 ƒ Wachovia Bank; Branch Manager; from 06/1994 to 06/1998 Item 4: Other Business Activities A. Investment‑Related Activities Designations ƒ George W. Climer III is a member of the First Presbyterian Church of Charlotte’s Finance and Investment Committees; George does not receive any form of compensation from this activity. George W. Climer III has earned the following designation and is in good standing with the granting authority: ƒ Certifi ed Financial Planner; Certifi ed Financial Planner Board of Standards; 2003 ƒ George W. Climer III is a member of the Myers Park High School Foundation Finance Committee; George does not receive any form of compensation from this activity. B. Non Investment‑Related Activities None Item 5: Additional Compensation George W. Climer III does not receive any economic benefi t from a non‑advisory client for the provision of advisory services. In order to be licensed to use the CFP® mark, an individual must meet the following qualifi cations, as specifi ed by the Certifi ed Financial Planner Board of Standards, Inc. (CFP® Board): Examination: An individual must successfully complete the CFP® Board’s comprehensive certifi cation examination, which tests the individual’s knowledge on a multitude of key fi nancial planning topics. Experience: Depending on the level of degree work completed in a collegiate setting, an individual must acquire three to fi ve years of fi nancial planning‑related experience prior to receiving the right to use the CFP® mark. Item 6: Supervision George W. Climer III reports directly to Dawn M. Cannon, Chief Compliance Offi cer. Dawn can be reached at 704‑714‑7713 and at dawn@braggfi nancial.com. — 35 —  Jennifer D. Muckley Part 2B of Form ADV \\ March 5, 2024 This brochure supplement provides information about Jennifer D. Muckley that supplements the Bragg Financial Advisors brochure. You should have received a copy of that brochure. Please contact Dawn Cannon if you did not receive BFA’s brochure or if you have any questions about the contents of this supplement. Additional information about Jennifer D. Muckley is available on the SEC’s website at www.adviserinfo.sec.gov 1031 S. Caldwell Street, Suite 200 \\ Charlotte, North Carolina 28203 \\ www.braggfi nancial.com \\ (704) 377‑0261 — 36 —  Jennifer D. Muckley Form ADV Part 2B \\ March 5, 2024 Item 2: Educational, Background and Business Experience Full Legal Name: Jennifer D. Muckley Born: 1983 Education: A CFP® licensee must obtain 30 hours of continuing education every two years in the body of knowledge pertaining to fi nancial planning areas such as estate planning, retirement planning, investment management, tax planning, employee benefi ts and insurance. Education ƒ Certifi ed Trust and Financial Advisor; 2010 ƒ Binghamton University; BS; Business Management, Concentration in Finance; 2005 ƒ Wake Forest University, MBA, Masters in Business Administration; 2015 Business Experience ƒ Bragg Financial Advisors, Inc.; Chief Operating Offi cer, Director of Family Offi ce Services and Client Advisor; from 04/2018 to Present ƒ Abbot Downing; Vice President, Wealth Planner; from 04/2016 to 03/2018 ƒ Abbot Downing; Vice President, Senior Client Service Consultant; from 10/2010 to 04/2016 ƒ Calibre; Offi cer, Client Service Consultant; from 04/2007 to 10/2010 ƒ US Trust Company; Offi cer, Client Relationship Associate; from 03/2005 to 04/2007 Designations In order to be licensed to use the CTFA® mark, an individual must meet the following qualifi cations, as specifi ed by the American Bankers Association: Examination: An individual must successfully pass the proctored CTFA® examination, which tests the individual’s knowledge on fi duciary and trust activities, fi nancial planning, tax law and planning, investment management, and ethics. Experience: To satisfy the prerequisites, an individual must satisfy one of the following experience tiers: 1.) ten or more years experience in wealth management 2.) fi ve years minimum experience in wealth management and a bachelor’s degree or 3.) three years minimum experience in wealth management and the completion of one specifi ed wealth management training program. Ethics: An individual must sign the ABA Professional Certifi cations’ Code of Ethics statement. Education: CTFA® designees are required to complete forty‑fi ve hours of continuing education every three years to continue their professional development in the fi duciary and trust arena. ƒ Accredited Estate Planner; National Association of Estate Jennifer D. Muckley has earned the following designations and is in good standing with the granting authorities: ƒ Certifi ed Financial Planner; Certifi ed Financial Planner Planners and Councils; 2020 Board of Standards; 2009 In order to be licensed to use the CFP® mark, an individual must meet the following qualifi cations, as specifi ed by the Certifi ed Financial Planner Board of Standards, Inc. (CFP® Board): Examination: An individual must successfully complete the CFP® Board’s comprehensive certifi cation examination, which tests the individual’s knowledge on a multitude of key fi nancial planning topics. Experience: Depending on the level of degree work completed in a collegiate setting, an individual must acquire three to fi ve years of fi nancial planning‑related experience prior to receiving the right to use the CFP® mark. Ethics: An individual must voluntarily ascribe to the CFP® Board’s code of ethics and additional requirements as mandated. This voluntary decision empowers the CFP® Board to take action if a CFP® licensee should violate the code of ethics. Such violations could lead to disciplinary action, including the permanent revocation of the right to use the CFP® mark. In order to be licensed to use the AEP® mark, an individual must meet the following qualifi cations, as specifi ed by the National Association of Estate Planners & Councils: in estate planning Professional discipline engaged requirement—The applicant must be presently and signifi cantly engaged in “estate planning activities” as an attorney, an accountant, an insurance professional and fi nancial planner, or a trust offi cer. Experience requirement: A minimum of fi ve (5) years of experience engaged in estate planning and estate planning activities is required in one or more of the professional disciplines described above to apply for the designation. Membership requirement: AEP® applicants are required to be members of, and continuously maintain membership in, an affi liated local or regional estate planning council where such membership is available. Professional reputation and character requirement: An applicant must continuously be in good standing with the applicant’s respective professional organization and/or license authority. — 37 —  Jennifer D. Muckley Form ADV Part 2B \\ March 5, 2024 Item 4: Other Business Activities A. Investment‑Related Activities None B. Non Investment‑Related Activities None Commitment to NAEPC Code of Ethics requirement: The applicant must sign a declaration statement to continuously abide by the NAEPC Code of Ethics. Dedicated to team concept requirement: The applicant must acknowledge a commitment to the team concept of estate planning by signing a declaration statement. Continuing education requirement: The applicant must satisfy a minimum of thirty (30) hours of continuing education during the previous twenty‑four (24) months. Item 5: Additional Compensation Jennifer D. Muckley does not receive any economic benefi t from a non‑advisory client for the provision of advisory services. Item 3: Disciplinary Information Jennifer D. Muckley has no reportable disciplinary history. Item 6: Supervision Jennifer D. Muckley reports directly to Dawn M. Cannon, Chief Compliance Offi cer. Dawn can be reached at 704‑714‑7713 and at dawn@braggfi nancial.com. — 38 —  Lauren Klaiber Part 2B of Form ADV \\ August 22, 2024 This brochure supplement provides information about Lauren Klaiber that supplements the Bragg Financial Advisors brochure. You should have received a copy of that brochure. Please contact Dawn Cannon if you did not receive BFA’s brochure or if you have any questions about the contents of this supplement. Additional information about Lauren Klaiber is available on the SEC’s website at www.adviserinfo.sec.gov 1031 S. Caldwell Street, Suite 200 \\ Charlotte, North Carolina 28203 \\ www.braggfi nancial.com \\ (704) 377‑0261 — 39 —  Lauren Klaiber Form ADV Part 2B \\ August 22, 2024 Item 2: Educational, Background and Business Experience Full Legal Name: Lauren M. Klaiber Born: 1986 Education ƒ The University of Tulsa; BS, Finance, 2008 Business Experience ƒ Bragg Financial Advisors, Inc.; Portfolio Manager, Member of the Investment Committee; from 08/2024 to Present ƒ Wells Fargo Investment Institute; Senior Wealth Portfolio Manager; from 04/2010 to 06/2024 ƒ Wells Fargo Retirement Group; Retirement Service curriculum provides a Associate; from 07/2008 to 04/2010 Designations Lauren Klaiber has earned the following designation and is in good standing with the granting authority: ƒ Chartered Financial Analyst; CFA Institute; 2013 learn more about the CFA charter, visit Global Recognition: Passing the three CFA exams is a diffi cult feat that requires extensive study (successful candidates report spending an average of 300 hours of study per level). Earning the CFA charter demonstrates mastery of many of the advanced skills needed for investment analysis and decision making in today’s quickly evolving global fi nancial industry. As a result, employers and clients are increasingly seeking CFA charter holders—often making the charter a prerequisite for employment. Additionally, regulatory bodies in 22 countries and territories recognize the CFA charter as a proxy for meeting certain licensing requirements, and more than 125 colleges and universities around the world have incorporated a majority of the CFA Program curriculum into their own fi nance courses. Comprehensive and Current Knowledge: The CFA Program comprehensive framework of knowledge for investment decision making and is fi rmly grounded in the knowledge and skills used every day in the investment profession. The three levels of the CFA Program test a profi ciency with a wide range of fundamental and advanced investment topics, including ethical and professional standards, fi xed‑income and equity analysis, alternative and derivative investments, economics, fi nancial reporting standards, portfolio management, and wealth planning. The CFA Program curriculum is updated every year by experts from around the world to ensure that candidates learn the most relevant and practical new tools, ideas, and investment and wealth management skills to refl ect the dynamic and complex nature of the profession. To www.cfainstitute.org. Item 3: Disciplinary Information Lauren Klaiber has no reportable disciplinary history. Item 4: Other Business Activities A. Investment‑Related Activities None B. Non Investment‑Related Activities None The Chartered Financial Analyst (CFA) charter is a globally respected, graduate‑level investment credential established in 1962 and awarded by CFA Institute — the largest global association of investment professionals. There are currently more than 90,000 CFA charter holders working in 134 countries. To earn the CFA charter, candidates must: 1) pass three sequential, six‑ hour examinations; 2) have at least four years of qualifi ed professional investment experience; 3) join CFA Institute as members; and 4) commit to abide by, and annually reaffi rm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. High Ethical Standards: The CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an active professional conduct program, require CFA charter holders to: ƒ Place their clients’ interests ahead of their own ƒ Maintain independence and objectivity ƒ Act with integrity ƒ Maintain and improve their professional competence ƒ Disclose confl icts of interest and legal matters — 40 —  Lauren Klaiber Form ADV Part 2B \\ August 22, 2024 Item 5: Additional Compensation Lauren Klaiber does not receive any economic benefi t from a non‑advisory client for the provision of advisory services. Item 6: Supervision Lauren Klaiber reports directly to Dawn M. Cannon, Chief Compliance Offi cer. Dawn can be reached at 704‑714‑7713 and at dawn@braggfi nancial.com. — 41 —  Lynn Araujo Part 2B of Form ADV \\ March 7, 2022 This brochure supplement provides information about Lynn Araujo that supplements the Bragg Financial Advisors brochure. You should have received a copy of that brochure. Please contact Dawn Cannon if you did not receive BFA’s brochure or if you have any questions about the contents of this supplement. Additional information about Lynn Araujo is available on the SEC’s website at www.adviserinfo.sec.gov 1031 S. Caldwell Street, Suite 200 \\ Charlotte, North Carolina 28203 \\ www.braggfi nancial.com \\ (704) 377‑0261 — 42 —  Lynn Araujo Form ADV Part 2B \\ March 7, 2022 Item 2: Educational, Background and Business Experience Full Legal Name: Lynn Lins de Araujo Born: 1972 Education ƒ University of North Carolina at Chapel Hill; BS, Mathematics; 1994 Business Experience ƒ Bragg Financial Advisors, Inc.; Client Advisor; from 12/2016 to Present ƒ BB&T; Wealth Planning Analyst; from 2/2013 to 12/2016 ƒ Wells Fargo (and predecessor banks, Wachovia and acquire three to fi ve years of fi nancial planning‑related experience prior to receiving the right to use the CFP® mark. Ethics: An individual must voluntarily ascribe to the CFP® Board’s code of ethics and additional requirements as mandated. This voluntary decision empowers the CFP® Board to take action if a CFP® licensee should violate the code of ethics. Such violations could lead to disciplinary action, including the permanent revocation of the right to use the CFP® mark. Education: A CFP® licensee must obtain 30 hours of continuing education every two years in the body of knowledge pertaining to fi nancial planning areas such as estate planning, retirement planning, investment management, tax planning, employee benefi ts and insurance. Item 3: Disciplinary Information First Union); Financial Planner 9/2001 to 9/2011 ƒ First Union; Sales Leader; from 5/1997 to 8/2001 ƒ First Union; Assistant Branch Manager; from 8/1994 to 4/1997 Lynn Araujo has no reportable disciplinary history. Designations Item 4: Other Business Activities A. Investment‑Related Activities None Lynn Araujo has earned the following designation and is in good standing with the granting authority: ƒ Certifi ed Financial Planner; Certifi ed Financial Planner B. Non Investment‑Related Activities Board of Standards; 2001 None Item 5: Additional Compensation Lynn Araujo does not receive any economic benefi t from a non‑advisory client for the provision of advisory services. Item 6: Supervision Lynn Araujo reports directly to Dawn M. Cannon, Chief Compliance Offi cer. Dawn can be reached at 704‑714‑7713 and at dawn@braggfi nancial.com. In order to be licensed to use the CFP® mark, an individual must meet the following qualifi cations, as specifi ed by the Certifi ed Financial Planner Board of Standards, Inc. (CFP® Board): Examination: An individual must successfully complete the CFP® Board’s comprehensive certifi cation examination, which tests the individual’s knowledge on a multitude of key fi nancial planning topics. Experience: Depending on the level of degree work completed in a collegiate setting, an individual must — 43 —  Marc N. Scavo Part 2B of Form ADV \\ March 7, 2022 This brochure supplement provides information about Marc N. Scavo that supplements the Bragg Financial Advisors brochure. You should have received a copy of that brochure. Please contact Dawn Cannon if you did not receive BFA’s brochure or if you have any questions about the contents of this supplement. Additional information about Marc N. Scavo is available on the SEC’s website at www.adviserinfo.sec.gov 1031 S. Caldwell Street, Suite 200 \\ Charlotte, North Carolina 28203 \\ www.braggfi nancial.com \\ (704) 377‑0261 — 44 —  Marc N. Scavo Form ADV Part 2B \\ March 7, 2022 Item 2: Educational, Background and Business Experience Full Legal Name: Marc N. Scavo Born: 1980 Education: A CFP® licensee must obtain 30 hours of continuing education every two years in the body of knowledge pertaining to fi nancial planning areas such as estate planning, retirement planning, investment management, tax planning, employee benefi ts and insurance. Education ƒ Chartered Retirement Planning Counselor; College for ƒ University of Iowa; BS; Bachelor of Business Financial Planning; 2011. Administration in Finance; 2002 Business Experience ƒ Bragg Financial Advisors, Inc.; Client Advisor; from 03/2020 to Present ƒ The Vanguard Group; Senior Financial Advisor; from 11/2017 to 03/2020 ƒ TIAA; Wealth Management Client Relationship Consultant; from 07/2013 to 11/2017 ƒ UBS AG; Investment Associate; from 06/2002 to 06/2013 Designations In order to be licensed to use the CRPC® mark, an individual must meet the following qualifi cations, as specifi ed by the College for Financial Planning: Examination ‑‑ an individual must successfully complete the College for Financial Planning’s comprehensive certifi cation examination, which tests the individual’s knowledge of pre‑ and post‑ retirement needs, asset management, estate planning and the entire retirement planning process. Ethics ‑‑ an individual must voluntarily ascribe to the Standards of Professional Conduct, by signing a code of professional ethics and complete a disclosure form attesting to their professional conduct. Education ‑‑ a CRPC® licensee must obtain 16 hours of continuing education every two years in the body of knowledge pertaining to retirement planning. Marc N. Scavo has earned the following designation and is in good standing with the granting authority: ƒ Certifi ed Financial Planner; Certifi ed Financial Planner Board of Standards; 2013 Item 3: Disciplinary Information Marc N. Scavo has no reportable disciplinary history. Item 4: Other Business Activities A. Investment‑Related Activities None B. Non Investment‑Related Activities None Item 5: Additional Compensation Marc N. Scavo does not receive any economic benefi t from a non‑advisory client for the provision of advisory services. Item 6: Supervision Marc N. Scavo reports directly to Dawn M. Cannon, Chief Compliance Offi cer. Dawn can be reached at (704) 714‑7713 and at dawn@braggfi nancial.com. In order to be licensed to use the CFP® mark, an individual must meet the following qualifi cations, as specifi ed by the Certifi ed Financial Planner Board of Standards, Inc. (CFP® Board): Examination: An individual must successfully complete the CFP® Board’s comprehensive certifi cation examination, which tests the individual’s knowledge on a multitude of key fi nancial planning topics. Experience: Depending on the level of degree work completed in a collegiate setting, an individual must acquire three to fi ve years of fi nancial planning‑related experience prior to receiving the right to use the CFP® mark. Ethics: An individual must voluntarily ascribe to the CFP® Board’s code of ethics and additional requirements as mandated. This voluntary decision empowers the CFP® Board to take action if a CFP® licensee should violate the code of ethics. Such violations could lead to disciplinary action, including the permanent revocation of the right to use the CFP® mark. — 45 —  Matthew S. DeVries Part 2B of Form ADV \\ February 27, 2025 This brochure supplement provides information about Matthew S. DeVries that supplements the Bragg Financial Advisors brochure. You should have received a copy of that brochure. Please contact Dawn Cannon if you did not receive BFA’s brochure or if you have any questions about the contents of this supplement. Additional information about Matthew S. DeVries is available on the SEC’s website at www.adviserinfo.sec.gov 1031 S. Caldwell Street, Suite 200 \\ Charlotte, North Carolina 28203 \\ www.braggfi nancial.com \\ (704) 377‑0261 — 46 —  Matthew S. DeVries Form ADV Part 2B \\ February 27, 2025 ƒ Act with integrity ƒ Maintain and improve their professional competence ƒ Disclose confl icts of interest and legal matters Item 2: Educational, Background and Business Experience Full Legal Name: Matthew S. DeVries Born: 1980 Education ƒ University of North Carolina at Chapel Hill; BS; Business Administration and BA; Political Science; 2003 Business Experience ƒ Bragg Financial Advisors, Inc.; Portfolio Manager, Member of the Investment Committee; from 09/2015 to Present ƒ Linden Thomas & Co.; Portfolio Analyst; from 12/2012 to 08/2015 ƒ T3 Trading Group, LLC; Proprietary Trader; from 08/2012 to 12/2012 ƒ Trade King, LLC; Trade Desk, MVP Support; from 03/2011 to 07/2012 curriculum provides a ƒ Synergy Investment Group; VP Trading Operations/ Securities and Municipal Principal; from 03/2010 to 03/2011 ƒ Fountain Rock Capital; Proprietary Trader; from 01/2004 to 11/2009 Designations Matthew S. DeVries has earned the following designation and is in good standing with the granting authority: ƒ Chartered Financial Analyst; CFA Institute; 2010 learn more about the CFA charter, visit Global Recognition: Passing the three CFA exams is a diffi cult feat that requires extensive study (successful candidates report spending an average of 300 hours of study per level). Earning the CFA charter demonstrates mastery of many of the advanced skills needed for investment analysis and decision making in today’s quickly evolving global fi nancial industry. As a result, employers and clients are increasingly seeking CFA charter holders—often making the charter a prerequisite for employment. Additionally, regulatory bodies in 22 countries and territories recognize the CFA charter as a proxy for meeting certain licensing requirements, and more than 125 colleges and universities around the world have incorporated a majority of the CFA Program curriculum into their own fi nance courses. Comprehensive and Current Knowledge: The CFA Program comprehensive framework of knowledge for investment decision making and is fi rmly grounded in the knowledge and skills used every day in the investment profession. The three levels of the CFA Program test a profi ciency with a wide range of fundamental and advanced investment topics, including ethical and professional standards, fi xed‑income and equity analysis, alternative and derivative investments, economics, fi nancial reporting standards, portfolio management, and wealth planning. The CFA Program curriculum is updated every year by experts from around the world to ensure that candidates learn the most relevant and practical new tools, ideas, and investment and wealth management skills to refl ect the dynamic and complex nature of the profession. To www.cfainstitute.org. Item 3: Disciplinary Information Matthew S. DeVries has no reportable disciplinary history. Item 4: Other Business Activities A. Investment‑Related Activities Member of the Investment Committee of Camp LUCK, a non‑profi t organization. Matt does not receive any form of compensation from this activity. B. Non Investment‑Related Activities None The Chartered Financial Analyst (CFA) charter is a globally respected, graduate‑level investment credential established in 1962 and awarded by CFA Institute — the largest global association of investment professionals. There are currently more than 90,000 CFA charter holders working in 134 countries. To earn the CFA charter, candidates must: 1) pass three sequential, six‑ hour examinations; 2) have at least four years of qualifi ed professional investment experience; 3) join CFA Institute as members; and 4) commit to abide by, and annually reaffi rm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. High Ethical Standards: The CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an active professional conduct program, require CFA charter holders to: ƒ Place their clients’ interests ahead of their own ƒ Maintain independence and objectivity — 47 —  Matthew S. DeVries Form ADV Part 2B \\ February 27, 2025 Item 5: Additional Compensation Matthew S. DeVries does not receive any economic benefi t from a non‑advisory client for the provision of advisory services. Item 6: Supervision Matthew S. DeVries reports directly to Dawn M. Cannon, Chief Compliance Offi cer. Dawn can be reached at 704‑714‑7713 and at dawn@braggfi nancial.com. — 48 —  Meghan Oldis Part 2B of Form ADV \\ July 27, 2023 This brochure supplement provides information about Meghan Oldis that supplements the Bragg Financial Advisors brochure. You should have received a copy of that brochure. Please contact Dawn Cannon if you did not receive BFA’s brochure or if you have any questions about the contents of this supplement. Additional information about Meghan Oldis is available on the SEC’s website at www.adviserinfo.sec.gov 1031 S. Caldwell Street, Suite 200 \\ Charlotte, North Carolina 28203 \\ www.braggfi nancial.com \\ (704) 377‑0261 — 49 —  Meghan Oldis Form ADV Part 2B \\ July 27, 2023 Item 2: Educational, Background and Business Experience Full Legal Name: Meghan M. Oldis knowledge pertaining to fi nancial planning areas such as estate planning, retirement planning, investment management, tax planning, employee benefi ts and insurance. Born: 1979 ƒ Certifi ed Public Accountant; North Carolina State Board of CPA Examiners; 2008 Education ƒ The College of William & Mary; BBA, Accounting; 2001 the Business Experience ƒ Bragg Financial Advisors, Inc.; Client Advisor, from 07/2023 to Present ƒ Bank of America Private Bank, N.A.; Wealth Strategies Advisor, from 03/2019 to 06/2023 ƒ Wells Fargo Private Bank, N.A.; Senior Wealth Planner, from 01/2005 to 03/2019 ƒ PriceWaterhouse Coopers, LLP; Senior Associate, from 08/2001 to 12/2004 Designations Meghan Oldis has earned the following designations and is in good standing with the granting authorities: ƒ Certifi ed Financial Planner; Certifi ed Financial Planner Board of Standards; 2006 In order to be licensed as a CPA in the state of North Carolina, an following individual must meet qualifi cations as specifi ed by the North Carolina State Board of CPA Examiners: Examination: An individual must successfully pass all parts of the CPA exam. Experience: Individuals must have completed one of the following for licensure: one year in public accounting or the fi eld of accounting under the direct supervision of a properly licensed CPA, four years in the fi eld of accounting, four years teaching accounting at an accredited college or university, four years of experience as a self employed individual in accounting. Ethics: Within one year prior to applying for certifi cation with North Carolina, a certifi cate applicant must complete an eight hour course on the North Carolina Accountancy Statutes and Rules. Upon receiving a CPA certifi cate, all individuals must complete an ethics course each year. Education: All North Carolina CPAs must complete 40 hours of continuing education each year. Item 3: Disciplinary Information Meghan Oldis has no reportable disciplinary history. Item 4: Other Business Activities A. Investment‑Related Activities None B. Non‑Investment‑Related Activities None Item 5: Additional Compensation Meghan Oldis does not receive any economic benefi t from a non‑advisory client for the provision of advisory services. Item 6: Supervision Meghan Oldis reports directly to Dawn M. Cannon, Chief Compliance Offi cer. Dawn can be reached at 704‑714‑7713 and at dawn@braggfi nancial.com. In order to be licensed to use the CFP® mark, an individual must meet the following qualifi cations, as specifi ed by the Certifi ed Financial Planner Board of Standards, Inc. (CFP® Board): Examination: An individual must successfully complete the CFP® Board’s comprehensive certifi cation examination, which tests the individual’s knowledge on a multitude of key fi nancial planning topics. Experience: Depending on the level of degree work completed in a collegiate setting, an individual must acquire three to fi ve years of fi nancial planning‑related experience prior to receiving the right to use the CFP® mark. Ethics: An individual must voluntarily ascribe to the CFP® Board’s code of ethics and additional requirements as mandated. This voluntary decision empowers the CFP® Board to take action if a CFP® licensee should violate the code of ethics. Such violations could lead to disciplinary action, including the permanent revocation of the right to use the CFP® mark. Education: A CFP® licensee must obtain 30 hours of continuing education every two years in the body of — 50 —  Thomas Benjamin Rose Part 2B of Form ADV \\ March 7, 2022 This brochure supplement provides information about Thomas Benjamin Rose that supplements the Bragg Financial Advisors brochure. You should have received a copy of that brochure. Please contact Dawn Cannon if you did not receive BFA’s brochure or if you have any questions about the contents of this supplement. Additional information about Thomas Benjamin Rose is available on the SEC’s website at www.adviserinfo.sec.gov 1031 S. Caldwell Street, Suite 200 \\ Charlotte, North Carolina 28203 \\ www.braggfi nancial.com \\ (704) 377‑0261 — 51 —  Thomas Benjamin Rose Form ADV Part 2B \\ March 7, 2022 ƒ Act with integrity ƒ Maintain and improve their professional competence ƒ Disclose confl icts of interest and legal matters Item 2: Educational, Background and Business Experience Full Legal Name: Thomas Benjamin Rose Born: 1970 Education ƒ Wake Forest University; BS; Business Administration; 1992 Business Experience ƒ Bragg Financial Advisors, Inc.; Director of Portfolio Management, Member of the Investment Committee; from 06/2012 to Present ƒ Wells Fargo Advisors Financial Network, LLC; Partner; from 09/2009 to 6/2012 ƒ Morgan Keegan & Company, Inc.; First Vice President; from 08/2001 to 09/2009 ƒ Wachovia Securities, Inc.; Research Analyst; from 01/1998 to 08/2001 curriculum provides a ƒ Nationsbanc Advisors, Inc., Nationsbanc Investments Inc.; Investment Specialist II; from 07/1996 to 01/1998 ƒ Smith Barney Inc.; Marketing Associate; from 01/1995 to 06/1996 ƒ Southwestern; Organizational Leader; from 05/1991 to 01/1995 Designations the Thomas Benjamin Rose has earned following designations and is in good standing with the granting authorities: ƒ Chartered Financial Analyst; CFA Institute; 2018 learn more about the CFA charter, visit Global Recognition: Passing the three CFA exams is a diffi cult feat that requires extensive study (successful candidates report spending an average of 300 hours of study per level). Earning the CFA charter demonstrates mastery of many of the advanced skills needed for investment analysis and decision making in today’s quickly evolving global fi nancial industry. As a result, employers and clients are increasingly seeking CFA charter holders—often making the charter a prerequisite for employment. Additionally, regulatory bodies in 22 countries and territories recognize the CFA charter as a proxy for meeting certain licensing requirements, and more than 125 colleges and universities around the world have incorporated a majority of the CFA Program curriculum into their own fi nance courses. Comprehensive and Current Knowledge: The CFA Program comprehensive framework of knowledge for investment decision making and is fi rmly grounded in the knowledge and skills used every day in the investment profession. The three levels of the CFA Program test a profi ciency with a wide range of fundamental and advanced investment topics, including ethical and professional standards, fi xed‑income and equity analysis, alternative and derivative investments, economics, fi nancial reporting standards, portfolio management, and wealth planning. The CFA Program curriculum is updated every year by experts from around the world to ensure that candidates learn the most relevant and practical new tools, ideas, and investment and wealth management skills to refl ect the dynamic and complex nature of the profession. To www.cfainstitute.org. ƒ Certifi ed Financial Planner; Certifi ed Financial Planner Board of Standards; 2012 In order to be licensed to use the CFP® mark, an individual must meet the following qualifi cations, as specifi ed by the Certifi ed Financial Planner Board of Standards, Inc. (CFP® Board): Examination: An individual must successfully complete the CFP® Board’s comprehensive certifi cation examination, which tests the individual’s knowledge on a multitude of key fi nancial planning topics. Experience: Depending on the level of degree work completed in a collegiate setting, an individual must acquire three to fi ve years of fi nancial planning‑related experience prior to receiving the right to use the CFP® mark. The Chartered Financial Analyst (CFA) charter is a globally respected, graduate‑level investment credential established in 1962 and awarded by CFA Institute — the largest global association of investment professionals. There are currently more than 90,000 CFA charter holders working in 134 countries. To earn the CFA charter, candidates must: 1) pass three sequential, six‑ hour examinations; 2) have at least four years of qualifi ed professional investment experience; 3) join CFA Institute as members; and 4) commit to abide by, and annually reaffi rm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. High Ethical Standards: The CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an active professional conduct program, require CFA charter holders to: ƒ Place their clients’ interests ahead of their own ƒ Maintain independence and objectivity — 52 —  Thomas Benjamin Rose Form ADV Part 2B \\ March 7, 2022 addition to those set forth by any other code that governs professional and ethical conduct. Education: AIF designees are required to complete six hours of continuing education per year to continue their professional development in the fi duciary arena. Item 3: Disciplinary Information Thomas Benjamin Rose has no reportable disciplinary history. Ethics: An individual must voluntarily ascribe to the CFP® Board’s code of ethics and additional requirements as mandated. This voluntary decision empowers the CFP® Board to take action if a CFP® licensee should violate the code of ethics. Such violations could lead to disciplinary action, including the permanent revocation of the right to use the CFP® mark. Education: A CFP® licensee must obtain 30 hours of continuing education every two years in the body of knowledge pertaining to fi nancial planning areas such as estate planning, retirement planning, investment management, tax planning, employee benefi ts and insurance. Item 4: Other Business Activities A. Investment‑Related Activities None ƒ Accredited Investment Fiduciary; Fiduciary 360; 2008 B. Non Investment‑Related Activities None Item 5: Additional Compensation Thomas Benjamin Rose does not receive any economic benefi t from a non‑advisory client for the provision of advisory services. Item 6: Supervision Thomas Benjamin Rose reports directly to Dawn M. Cannon, Chief Compliance Offi cer. Dawn can be reached at 704‑714‑7713 and at dawn@braggfi nancial.com. In order to be licensed to use the AIF® mark, an individual must meet the following qualifi cations, as specifi ed by the Fiduciary 360, Inc.; Examination: An individual must successfully complete the AIF training curriculum and pass the proctored AIF examination, which tests the individual’s knowledge on a multitude of investment fi duciary topics. Experience: To satisfy prerequisites, an individual must acquire points in a valuation framework considering three factors: 1.) education (minimum bachelor’s degree), 2.) relevant industry experience (minimum two years) and 3.) professional development (industry credentials). Ethics: An individual must attest to the AIF® Designee Code of Ethics, and its principles and obligations, in — 53 —