GENEVA FINANCIAL GROUP LLC

Form ADV Part 2A: Firm Brochure Item 1 – Cover Page Geneva Financial Group, LLC 2060 W. County Line Rd Jackson, NJ 08532 732-719-4101 Date of Disclosure Brochure: March 2025 ____________________________________________________________________________________ This Form ADV Part 2A Brochure (“Brochure”) provides information about the qualifications and business practices of Geneva Financial Group, LLC. If you have any questions about the contents of this Brochure, please contact us at 732-719-4101 or jf@genevafingroup.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Registration with the SEC does not imply that Geneva Financial Group, LLC or any individual providing investment advisory services on behalf of Geneva Financial Group, LLC possess a certain level of skill or training. Additional information about Geneva Financial Group, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. Geneva Financial Group, LLC Page 1 Form ADV Part 2A Firm Brochure  Item 2 – Material Changes Since our initial disclosure brochure was filed in June of 2024 and amended in December 2024, the following material changes have been made: • • • Item 4: Types of Investments Item 4 Assets Under Management Item 4 Advisory Business – Geneva Financial Group LLC is owned by Geneva Enterprises INC which is 100% owned by Jacques Frenkel Geneva Financial Group, LLC Page 2 Form ADV Part 2A Firm Brochure  Item 3 – Table of Contents Item 1 – Cover Page ................................................................................................................................ 1 Item 2 – Material Changes ....................................................................................................................... 2 Item 3 – Table of Contents ....................................................................................................................... 3 Item 4 – Advisory Business ...................................................................................................................... 4 Introduction .......................................................................................................................................... 4 Description of Advisory Services .......................................................................................................... 4 Types of Investments ........................................................................................................................... 6 Client Assets Managed by Geneva Financial Group ............................................................................. 6 Item 5 – Fees and Compensation ............................................................................................................ 6 Asset Management Services ................................................................................................................ 7 Item 6 –Performance-Based Fees ............................................................................................................ 7 Item 7 – Types of Clients ......................................................................................................................... 8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 8 Methods of Analysis ............................................................................................................................. 8 Investment Strategies .......................................................................................................................... 9 Item 9 – Disciplinary Information ............................................................................................................ 12 Item 10 – Other Financial Industry Activities and Affiliations ................................................................... 12 Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading .............................. 12 Code of Ethics Summary ................................................................................................................... 12 Affiliate and Employee Personal Securities Transactions Disclosure .................................................. 13 Item 12 – Brokerage Practices ............................................................................................................... 13 Asset ................................................................................................................................................. 13 Custodian Services and Brokerage Services ...................................................................................... 13 Soft Dollar Benefits ............................................................................................................................ 13 Block Trading Policy .......................................................................................................................... 13 Item 13 – Review of Accounts ................................................................................................................ 14 Account Reviews ............................................................................................................................... 14 Statements and Reports .................................................................................................................... 14 Item 14 – Client Referrals ...................................................................................................................... 14 Item 15 – Custody.................................................................................................................................. 14 Item 16 – Investment Discretion ............................................................................................................. 15 Item 17 – Voting Client Securities .......................................................................................................... 15 Item 18 – Financial Information .............................................................................................................. 15 Geneva Financial Group, LLC Page 3 Form ADV Part 2A Firm Brochure  Item 4 – Advisory Business Geneva Financial Group (GFG) is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”) and is a limited liability company (LLC) formed under the laws of the State of New Jersey. • The owner of Geneva Financial Group LLC is Geneva Enterprises INC • Jacques Frenkel is the Managing Director of Geneva Financial Group and owner of Geneva Enterprises INC • Geneva Financial Group has registered with the SEC in June 2024 Introduction The investment advisory services of GFG are provided to you through an appropriately licensed individual who is an investment adviser representative of GFG (referred to as your investment adviser representative throughout this brochure). Description of Advisory Services The following are descriptions of the primary advisory services of GFG. Please understand that a written agreement, which details the exact terms of the service to our Clients (or “investors”, “you” or “your” or similar references), must be signed by you and GFG before our Firm can provide you the services described below. Asset Management Services – GFG offers asset management services, which involves GFG providing you with continuous and ongoing supervision over your specified accounts. You must appoint GFG as your investment adviser of record on specified accounts (collectively, the “Account”). The Account consists only of separately managed account(s) held by qualified independent custodian(s) under your name. The qualified independent custodians maintain physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account. The Account is managed based on your financial situation, investment objectives, financial information, and risk tolerance. GFG actively monitors Account and provides advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Account. GFG will obtain certain information from you to determine your financial situation and investment objectives. You will be responsible for notifying us of any updates regarding your financial situation, risk tolerance or investment objective and whether you wish to impose or modify existing investment restrictions; however, we will contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance or investment objectives. We are always reasonably available to consult with you relative to the status of your Account. You have the ability to impose reasonable restrictions on the management of your accounts, including the ability to instruct us not to purchase certain securities. It is important that you understand that we manage investments for other clients and may give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you, or actions taken for you. GFG is not obligated to buy, sell or recommend to you any security or other investment that we may buy, sell or recommend for any other clients or for our own accounts. Geneva Financial Group, LLC Page 4 Form ADV Part 2A Firm Brochure  Conflicts may arise in the allocation of investment opportunities among accounts that we manage. GFG strives to allocate investment opportunities believed to be appropriate for your account(s) and other accounts advised by our firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If GFG or its personnel obtains material, non-public information about a security or its issuer that we may not lawfully use or disclose, the Firm has absolutely no obligation to disclose the information to any client or use it for any client’s benefit. Retirement Plan Rollover Recommendations - When GFG provides investment advice about your retirement plan account or individual retirement account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan account, roll over such investment/proceeds from the retirement plan account to a IRA or make a distribution from the retirement plan account, you acknowledge that GFG is a “fiduciary” within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”) as applicable, which are laws governing retirement accounts. GFG operates under a special rule that requires GFG to act in your best interest and not put its interests ahead of you. Under this special rule’s provisions, GFG must as a fiduciary to a retirement plan account or IRA under ERISA/IRC: • • • • • • Meet a professional standard of care when making investment recommendations (give prudent advice); Never put the financial interests of GFG ahead of you when making recommendations (give loyal advice); Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that GFG gives advice that is in your best interest; Charge no more than is reasonable for the services of GFG; and Give Client basic information about conflicts of interest. To the extent we recommend you roll over your account from a current retirement plan account to an individual retirement account managed by GFG, please know that GFG has a conflict of interest. GFG earns increased investment advisory fees by recommending that you roll over your account at the retirement plan to an IRA managed by our Firm. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by GFG. Thus, our investment adviser representative(s) have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA which is a conflict of interest because our recommendation that you open an IRA account to be managed by GFG is not based exclusively on whether moving the IRA to our management program is in your overall best interest. GFG has taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representative(s) will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in GFG receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by GFG and our supervised persons and any material conflicts of interest related Geneva Financial Group, LLC Page 5 Form ADV Part 2A Firm Brochure  to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to a retirement plan account or IRA, GFG representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of our Firm or our affiliated personnel. Types of Investments GFG provides investment advice on the following types of investments • Structured Notes • Mutual Funds • Exchange Traded Funds (ETFs) • Exchange-listed Securities • Securities Traded Over-the-Counter • Foreign Issues (including ADRs/GDRs) • Corporate Debt Securities • Commercial Paper • Certificates of Deposit • Municipal Securities • US Government Securities • US Government Agency Securities • Options Contracts on Securities • Securities Properly Exempted from Registration We reserve the right to offer advice on any investment product that we deem appropriate for each client’s specific circumstances, needs, goals and objectives. You have the ability to impose reasonable restrictions on the accounts we manage for you, including specific investment selections and sectors. It is not GFG’s typical investment strategy to attempt to time the market, but we may increase cash holdings as deemed appropriate based on your risk tolerance and our expectations of market behavior. GFG may modify the established investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.) Client Assets Managed by Geneva Financial Group As of December 31, 2024, the Firm managed $188,109,100 of client assets, $7,573,140 of client assets are managed on a discretionary basis and $180,535,960 of client assets are managed on a non- discretionary basis. Item 5 – Fees and Compensation Geneva Financial Group, LLC Page 6 Form ADV Part 2A Firm Brochure  This section describes how GFG is compensated for its services. The exact fees and other terms will be outlined in the agreement between you and GFG. Lower fees for comparable service may be available from other advisors. Asset Management Services Fees charged for our asset management services are charged based on a percentage of assets under management, billed in arrears (at the end of the billing period) on a monthly basis and calculated based on the fair market value of your account as of the last day of the current billing period, cash balances are also considered billable assets in this assessment. Fees are prorated (based on the number of days service is provided during the initial billing period) for your account opened at any time other than the beginning of the billing period. If asset management services are commenced in the middle of the billing period, then the prorated fee for that billing period will be billed in arrears at the end of that billing period. The asset management services continue in effect until terminated by either party (i.e., GFG Group or you) by providing written notice of termination to the other party. When fees are billed in arrears, Geneva Financial Group will prorate the final fee payment based on the number of days services are provided during the final period. The amount of client assets on the termination date will be used to determine the final fee payment. Fees charged for our asset management services are negotiable and depend on various factors, including, but not limited to, the type of client, the complexity of the client's situation, the composition of the client's account , the potential for additional account deposits, the relationship of the client with the investment adviser representative, and the total amount of assets under management for the client or client household. The annual fee for asset management services will be between 0.75% and 1.50% There is a minimum account size of $250,000. GFG believes that its annual fee is reasonable in relation to: (1) services provided and (2) the fees charged by other investment advisers offering similar services/programs. However, our annual investment advisory fee may be higher than that charged by other investment advisers offering similar services/programs. In addition to our compensation, you may also incur charges imposed at the mutual fund level (e.g., advisory fees and other fund expenses). The investment advisory fees will be deducted from your account and paid directly to our firm by the qualified custodian(s) of your account. You will authorize the qualified custodian(s) of your account to deduct fees from your account and pay such fees directly to our firm. You should review your account statements received from the qualified custodian(s) and verify that appropriate investment advisory fees are being deducted. The qualified custodian(s) will not verify the accuracy of the investment advisory fees deducted. Brokerage expenses and/or transaction fees charged are billed directly to you. GFG does not receive any portion of such commissions or fees from you or any other party. In addition, you will incur certain charges imposed by third parties other than GFG in connection with investments made through your account including, but not limited to, mutual fund sales loads, 12(b)-1 fees applicable to registered investment companies and contingent deferred sales charges, s, IRA and qualified retirement plan fees, and charges imposed by the qualified custodian(s) of your account. Management fees charged by GFG are separate and distinct from the fees and expenses charged by investment company securities that may be recommended to you. A description of these fees and expenses are available in each investment company security’s prospectus or applicable product’s offering memorandum. Item 6 –Performance-Based Fees Geneva Financial Group, LLC Page 7 Form ADV Part 2A Firm Brochure  GFG’s fee is not based whether there are any gains and is not contingent on a share of capital gains or capital appreciation of the assets held in a client’s account Item 7 – Types of Clients GFG generally provides investment advice to the following types of clients: Individuals • • High net worth individuals • Corporations or business entities other than those listed above • Single Family Offices You are required to execute a written agreement with GFG specifying the particular advisory services in order to establish a client arrangement with our Firm. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis GFG uses the following methods of analysis in formulating investment advice: Charting - This is a set of techniques used in technical analysis in which charts are used to plot price movements, volume, settlement prices, open interest, and other indicators, in order to anticipate future price movements. Users of these techniques, called chartists, believe that past trends in these indicators can be used to extrapolate future trends. Charting is likely the most subjective analysis of all investment methods since it relies on proper interpretation of chart patterns. The risk of reliance upon chart patterns is that the next day's data can always negate the conclusions reached from prior days' patterns. Also, reliance upon chart patterns bears the risk of a certain pattern being negated by a larger, more encompassing pattern that has not shown itself yet. Fundamental – This is a method of evaluating a security by attempting to measure its intrinsic value by examining related economic, financial and other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect the security's value, including macroeconomic factors (like the overall economy and industry conditions) and individually specific factors (like the financial condition and management of a company). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security's current price in hopes of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short). Fundamental analysis is considered to be the opposite of technical analysis. Fundamental analysis is about using real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be used for just about any type of security. The risk associated with fundamental analysis is that it is somewhat subjective. While a quantitative approach is possible, fundamental analysis usually entails a qualitative assessment of how market forces interact with one another in their impact on the investment in question. It is possible for those market forces to point in different directions, thus necessitating an interpretation of which forces will be dominant. This interpretation may be wrong and could therefore lead to an unfavorable investment decision. Technical – This is a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a Geneva Financial Group, LLC Page 8 Form ADV Part 2A Firm Brochure  security's intrinsic value, but instead use charts and other tools to identify patterns that can suggest future activity. Technical analysts believe that the historical performance of stocks and markets are indications of future performance. Technical analysis is even more subjective than fundamental analysis in that it relies on proper interpretation of a given security's price and trading volume data. A decision might be made based on a historical move in a certain direction that was accompanied by heavy volume; however, that heavy volume may only be heavy relative to past volume for the security in question, but not compared to the future trading volume. Therefore, there is the risk of a trading decision being made incorrectly since future trading volume is an unknown. Technical analysis is also done through observation of various market sentiment readings, many of which are quantitative. Market sentiment gauges the relative degree of bullishness and bearishness in a given security, and a contrarian investor utilizes such sentiment advantageously. When most traders are bullish, then there are very few traders left in a position to buy the security in question, so it becomes advantageous to sell it ahead of the crowd. When most traders are bearish, then there are very few traders left in a position to sell the security in question, so it becomes advantageous to buy it ahead of the crowd. The risk in utilization of such sentiment technical measures is that a very bullish reading can always become more bullish, resulting in lost opportunity if the money manager chooses to act upon the bullish signal by selling out of a position. The reverse is also true in that a bearish reading of sentiment can always become more bearish, which may result in a premature purchase of a security. There are risks involved in using any analysis method. Investment Strategies GFG uses a variety of investment strategies when managing client assets and providing investment advice, including, but not limited to: Long term purchases. Investments held at least a year. Short term purchases. Investments sold within a year. Short sales. A short sale is generally the sale of a stock not owned by the investor. Investors sell short when they believe the price of the stock will fall. If the price drops, the investor can buy the stock at the lower price and make a profit. If the price of the stock rises and the investor buys it back later at the higher price, the investor will incur a loss. Short sales require a margin account. Margin transactions. When an investor buys a stock on margin, the investor pays for part of the purchase and borrows the rest of the purchase price from a brokerage firm. For example, an investor may buy $5,000 worth of stock in a margin account by paying for $2,500 and borrowing $2,500 from a brokerage firm. Clients cannot borrow stock from Geneva Financial Group. Option Buying and Option Selling including selling covered options, uncovered options. Trading of Structured Products: This includes structured notes, which are products that attempt to meet specific investment objectives such as growth, income, or risk management. Structured notes combine a traditional security, like a bond, with a derivative component in which the issuer promises to pay a return based on the performance of one or more reference assets, such as an index or any other asset. Unlike mutual funds or exchange-traded funds (ETFs), structured notes do not hold an underlying portfolio of investments. Strategic asset allocation. Calls for setting target allocations and then periodically rebalancing the portfolio back to those targets as investment returns skew the original asset allocation Geneva Financial Group, LLC Page 9 Form ADV Part 2A Firm Brochure  percentages. The concept is akin to a “buy and hold” strategy, rather than an active trading approach. Of course, the strategic asset allocation targets may change over time as the client’s goals and needs change and as the time horizon for major events such as retirement and college funding grow shorter. Risk of Loss Past performance is not indicative of future results. Therefore, you should never assume that future performance of any specific investment or investment strategy will be profitable. Investing in securities (including stocks, mutual funds, Structured Notes , Money Market and bonds, etc.) involves risk of loss. Further, depending on the different types of investments there may be varying degrees of risk. You should be prepared to bear investment loss including loss of original principal. Because of the inherent risk of loss associated with investing, my firm is unable to represent, guarantee, or even imply that my services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. There are certain additional risks associated with investing in securities through my investment management program, as described below: Structured notes: Structured Notes can come with or without principal protection. Structured notes with principal protection offer a full or partial return of principal at maturity, regardless of the performance of the underlying assets. However, any guarantee of principal protection depends on the financial strength of the issuer of the security. Structured notes can offer higher potential returns compared to their reference assets but also involve unique risks and complexities in their terms and features. Investors should recognize that other factors may also affect their investment outcomes. Therefore, it is crucial to carefully review the offering documents associated with these investments. Issuers of Structured Products are not under an obligation to provide liquidity in all circumstances. Even when a market is provided you might not be able to obtain an appropriate price for the product when you sell it. It might also be difficult or impossible to determine a fair price or even compare prices at all, as there is often only one market maker. Always read the investment prospectus to be sure you know whether a specific note offers full or less than full protection or has protection that is conditional or contingent on other factors. Market Risk – Either the stock market as a whole, or the value of an individual company, Equity (stock) market risk – Common stocks are susceptible to general stock market Company Risk. When investing in stock positions, there is always a certain level of • goes down resulting in a decrease in the value of client investments. This is also referred to as systemic risk. • fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change. If you held common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater risk than if you held preferred stocks and debt obligations of the issuer. • company or industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk and can be reduced through appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. • Fixed Income Risk. When investing in bonds, there is the risk that the issuer will default on the bond and be unable to make payments. Further, individuals who depend on set amounts Geneva Financial Group, LLC Page 10 Form ADV Part 2A Firm Brochure  of periodically paid income face the risk that inflation will erode their spending power. Fixed- income investors receive set, regular payments that face the same inflation risk. • ETF and Mutual Fund Risk – When investing in an ETF or mutual fund, you will bear additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds. You will also incur brokerage costs when purchasing ETFs. • Margin Risk - When you purchase securities, you may pay for the securities in full or borrow part of the purchase price from your account custodian or clearing firm. If you intended to borrow funds in connection with your Account, you will be required to open a margin account, which will be carried by the clearing firm. The securities purchased in such an account are the clearing firm’s collateral for its loan to you. If those securities in a margin account decline in value, the value of the collateral supporting this loan also declines, and as a result, the brokerage firm is required to take action in order to maintain the necessary level of equity in your account. The brokerage firm may issue a margin call and/or sell other assets in your account. It is important that you fully understand the risks involved in trading securities on margin, which are applicable to any margin account that you may maintain, including any margin account that may be established as part of the Asset Management Agreement established between you and Geneva Financial Group and held by the account custodian or clearing firm. These risks include the following: You can lose more funds than you deposit in your margin account. • • The account custodian or clearing firm can force the sale of securities or other assets in your account. • The account custodian or clearing firm can sell your securities or other assets without contacting you. • You are not entitled to choose which securities or other assets in your margin account may be liquidated or sold to meet a margin call. • The account custodian or clearing firm may move securities held in your cash account to your margin account and pledge the transferred securities. The account custodian or clearing firm can increase its “house” maintenance margin requirements at any time and they are not required to provide you advance written notice. • • You are not entitled to an extension of time on a margin call. • Management Risk – Your investment with our firm varies with the success and failure of my investment strategies, research, analysis and determination of portfolio securities. If my investment strategies do not produce the expected returns, the value of the investment will decrease. • Foreign (NonU.S.) Risk. A portfolio’s investments in securities of non-U.S. (or foreign) issuers may involve more risk than those of U.S. issuers. These securities may fluctuate Geneva Financial Group, LLC Page 11 Form ADV Part 2A Firm Brochure  more widely in price and may be less liquid due to adverse market, economic, political, regulatory or other factors. • Emerging Markets Risk. Securities of companies in emerging markets may be more volatile than those of companies in developed markets. By definition, markets, economies and government institutions are generally less developed in emerging market countries. Investment in securities of companies in emerging markets may entail special risks relating to the potential for social instability and the risks of expropriation, nationalization or confiscation. Investors may also face the imposition of restrictions on foreign investment or the repatriation of capital and a lack of hedging instruments. • Currency Risk. Fluctuations in currency exchange rates may negatively affect the value of a portfolio’s investments or reduce its returns • Interest Rate Risk. Changes in interest rates will affect the value of a portfolio’s investments in fixed income securities. When interest rates rise, the value of investments in fixed income securities tend to fall and this decrease in value may not be offset by higher income from new investments. Interest rate risk is generally greater for fixed income securities with longer maturities or durations. Credit Risk. An issuer, obligor or guarantor of a fixed income security or a structured note, may be unable to make timely payments of interest or principal. Item 9 – Disciplinary Information GFG has no legal or disciplinary events to disclose. Item 10 – Other Financial Industry Activities and Affiliations Jacques Frenkel is the owner of Geneva Enterprises, which holds ownership of this firm. He also owns GFG Realty LLC and Geneva Realty LLC, both of which are real estate companies. Additionally, he serves as the President of GFG Group LLC, a logistics and freight transportation company. GFG does not advise its clients to invest in these entities, nor will any of these entities accept investments from GFG clients. Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading Code of Ethics Summary In accordance with Rule 204A-1 of the Investment Advisers Act of 1940, GFG has established a Code of Ethics (“Code”) to comply with this rules requirements, that reflects its fiduciary obligations and those of its supervised persons. The Code also requires compliance with federal securities laws. The Code covers all individuals that are classified as “supervised persons” . GFG requires its supervised persons to Geneva Financial Group, LLC Page 12 Form ADV Part 2A Firm Brochure  consistently act in your best interest in all advisory activities. GFG imposes certain requirements on its supervised persons to ensure that they meet the firm’s professional obligations to you. This section is intended to provide a summary description of GFG’s Code . If you wish to receive a copy the Code in its entirety , please contact our Firm at the 732-719-4101. Affiliate and Employee Personal Securities Transactions Disclosure GFG’s supervised persons buy and sell for their personal accounts investment products identical to those recommended to clients. This creates a conflict of interest. To mitigate conflicts of interest that can occur when access persons manage their personal accounts at the same time GFG manages client accounts, GFG has developed written procedures that include personal investment and trading policies for its representatives, employees and their immediate family members (collectively, supervised persons). Further, it is the express policy of GFG that all persons associated in any manner with the Firm must place clients’ interests ahead of their own when implementing personal investments. GFG and its supervised persons will not buy or sell securities for their personal account(s) where their decision is derived, in whole or in part, by information obtained as a result of employment or association with my firm unless the information is also available to the investing public upon reasonable inquiry. Item 12 – Brokerage Practices Where GFG maintains a duty to assist our Clients in the implementation of any investment recommendations, the Firm is responsible to ensure that the client receives the best execution possible. Best execution does not necessarily mean that clients receive the lowest possible commission costs but that the qualitative execution is best. In other words, all conditions considered, the transaction execution is in your best interest. When considering best execution, the Firm considers a number of factors besides prices and rates including, but not limited to: • Execution capabilities (e.g., market expertise, ease/reliability/timeliness of execution, responsiveness, integration with my existing systems, ease of monitoring investments) • Products and services offered (e.g., investment programs, back office services, technology, regulatory compliance assistance, research and analytic services) • Financial strength, stability and responsibility • Reputation and integrity • Ability to maintain confidentiality Asset Custodian Services and Brokerage Services GFG currently uses BNY Mellon, Interactive Brokers, and Charles Schwab as custodians, and may choose to engage additional custodians in the future. We maintain professional relationships with a range of qualified brokerage firms, allowing us to select the broker we believe is best suited for each individual transaction. This approach ensures optimal service for our clients. Soft Dollar Benefits GFG does not have a formal commission sharing arrangement with any financial institution nor participate in transactions involving soft dollar commissions with a broker-dealer or a third-party. Block Trading Policy Geneva Financial Group, LLC Page 13 Form ADV Part 2A Firm Brochure  GFG may elect to purchase or sell the same securities for several clients at approximately the same time. This process is referred to as aggregating orders, batch trading or block trading and is used by GFG when it believes such action may prove advantageous to clients. Typically, the process of aggregating client orders is done in order to achieve better execution, to negotiate more favorable commission rates or to allocate orders among clients on a more equitable basis in order to avoid differences in prices and transaction fees or other transaction costs that might be obtained when orders are placed independently. If GFG aggregates client orders, allocating securities among client accounts is done on a fair and equitable basis. GFG does not receive additional compensation for aggregating trades. GFG uses the average price allocation method for transaction allocation. Under this procedure GFG will calculate the average price and transaction charges for each transaction included in a block order and assign the average price and transaction charge to each allocated transaction executed for the client’s account. If GFG includes proprietary accounts of the firm or personal accounts of its supervised persons in an aggregated client order (i.e., block trade), then each client/proprietary account/personal account participating in the order will participate at an average share price of all GFG’s transactions in that security on the day of execution and transaction costs will be shared on a pro rata base for each client’s participation in the transaction. Item 13 – Review of Accounts Account Reviews Managed accounts are reviewed at least quarterly and/or conducted at your request. Account reviews will include investment strategy and objectives review and making a change if strategy and objectives have changed. Reviews are conducted by Jacques Frenkel. Statements and Reports For our asset management services, you will receive account statements in writing directly from the qualified custodian, which also provides online access to your account. You are encouraged to compare any correspondence, reports, or statements provided by me against the account statements delivered by the qualified custodian. If you have questions about your account statement or anything you see online, you should contact both our firm and the qualified custodian responsible for preparing the statement. Item 14 – Client Referrals GFG does not directly or indirectly compensate any person for client referrals. . Item 15 – Custody GFG is deemed to have custody of client funds and securities if it is given the authority to have fees deducted directly from client accounts. For accounts in which GFG is deemed to have custody, it has established procedures to ensure all client funds and securities are held at a qualified custodian in a Geneva Financial Group, LLC Page 14 Form ADV Part 2A Firm Brochure  separate account for each client under that client’s name. Clients or an independent representative of the client will direct, in writing, the establishment of all accounts and therefore are aware of the qualified custodian’s name, address and the manner in which the funds or securities are maintained. Finally, account statements are delivered directly from the qualified custodian to each client, or the client’s independent representative, at least quarterly. Clients should carefully review those statements and are urged to compare the statements against reports received from GFG. When clients have questions about their account statements,they should contact GFG or the qualified custodian preparing the statement. Item 16 – Investment Discretion GFG maintains trading authorization over your account and offers both , discretionary and non- discretionary account options. When discretionary authority is granted, GFG will have the authority to determine the type of securities and the amount of securities that can be bought or sold for your portfolio without obtaining your consent for each transaction. If you decide to grant trading authorization on a non-discretionary basis, GFG will be required to contact you prior to implementing changes in your account. This can have an adverse impact on the timing of trade implementations and the price you receive for your transactions. You will have the ability to place reasonable restrictions on the types of investments that may be purchased in your Account. You may also place reasonable limitations on the discretionary power granted to Geneva Financial Group so long as the limitations are specifically set forth or included as an attachment to the client agreement. Item 17 – Voting Client Securities GFG does not vote proxies on behalf of Clients. Therefore, it is your responsibility to vote all proxies for securities held in Account. You will receive proxies directly from the qualified custodian or transfer agent. You are encouraged to read through the information provided with the proxy-voting documents and make a determination based on the information provided. Item 18 – Financial Information GFG does not require or solicit prepayment of more than $1200 in fees per client, six months or more in advance. GFG has not been the subject of a bankruptcy petition at any time. Geneva Financial Group, LLC Page 15 Form ADV Part 2A Firm Brochure