DDD Partners, LLC

DDD Partners, LLC dba Tschetter Group (“we,” “us,” “our,” “Tschetter Group”) was established in December 2017 and is wholly owned by Richard Tschetter, David Tschetter and Dustin Brumbaugh. Our firm provides asset management and investment consulting services for many different types of clients to help meet their financial goals while remaining sensitive to risk tolerance and time horizons. As a fiduciary it is our duty to always act in the client’s best interest. This is accomplished in part by knowing the client. Our firm has established a service-oriented advisory practice with open lines of communication. Working with clients to understand their investment objectives while educating them about our process facilitates the kind of working relationship we value.

Types of Advisory Services Offered Comprehensive Portfolio Management: As part of our Comprehensive Portfolio Management service clients are provided asset management and financial planning or consulting services. This comprehensive service is designed to assist clients in meeting their financial goals with use of a financial plan or consultation. We conduct client meetings to understand each client’s current financial situation, existing resources, financial goals, and tolerance for risk. Based on what we learn, we present an investment approach to the client consisting of individual stocks, bonds, exchange traded funds (“ETFs”), including cryptocurrency focused ETFs, mutual funds and/or other securities or investments. Once we have determined the appropriate portfolio, we continuously and regularly monitor it, and rebalance the account as needed based upon the client’s individual needs, stated goals and objectives. Upon client request, we provide a summary of observations and recommendations for the planning or consulting aspects of this service.

Financial Planning & Consulting: Our firm provides a variety of standalone financial planning and consulting services to clients for the management of financial resources based upon an analysis of current situation, goals, and objectives. Financial planning services will typically involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass Investment Planning, Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, or Business and Personal Financial Planning. Written financial plans or financial consultations rendered to clients usually include general recommendations for a course of activity or specific actions to be taken by the clients. Implementation of the recommendations will be at the discretion of the client. Our firm provides clients with a summary of their financial situation, and observations for financial planning engagements. Financial consultations are not typically accompanied by a written summary of observations and recommendations, as the process is less formal than the planning service. If all the information and documents requested from the client are provided promptly, plans or consultations are typically completed within six months of the client signing a contract with our firm.

Third-Party Money Managers (Sub-Advisors): We sometimes utilize the services of a third-party money manager, an unaffiliated investment adviser, to manage a portion of your assets. We typically engage an outside money manager in a sub-advisory relationship, which means the agreement is between Tschetter Group and the other money manager, rather than between you and the other manager.

In situations where we select an outside manager to manage a portion of a client’s overall portfolio, that outside manager is chosen with the goal of meeting a particular investment goal for the client’s specific circumstances. The other manager will manage that portion of your portfolio allocated to them and will usually have discretionary authority over those specific assets. We retain the discretionary authority to engage new managers or move away from an existing manager. We deduct your advisory fee as described in Item 5 of this brochure and we pay a portion of that fee to the sub-advisor managing a portion of your overall assets. We will continue to monitor your portfolio to ensure the other adviser’s management and investment style remain aligned with your overall investment goals and objectives. We will make changes to a strategy or select another manager as appropriate for you.

Private Funds Tschetter Group provides investment management services on a discretionary basis to privately offered pooled investment vehicles exempt from registration under the Investment Company Act of 1940, as amended. Tschetter Group currently serves as the investment manager to the TG Private Market Opportunities Fund LP, a Delaware limited partnership (the “Fund”). The Fund will be invested via limited partnership interests of 3rd party unaffiliated managers offering private equity, real estate, and venture capital funds. This structure is commonly referred to as a fund of funds. The Fund offers interest through a limited partnership structure (“LP”). Investment advice is provided directly to the Fund. Tschetter Group may, in the future, organize additional investment vehicles that follow an investment program similar to or different from the investment program of the Fund. The Fund is governed by a limited partnership agreement that sets forth the specific investment guidelines and restrictions applicable to the Fund. Advisory services are tailored to achieve the Fund’s investment objectives. However, Tschetter Group has the authority to select the underlying fund managers without consultation with the Fund or the investors in the Fund. Neither the Fund nor the investors in the Fund may impose restrictions on investing in certain types of securities. The detailed terms, strategy, risks, and other information applicable to investors in our Fund are described in the Fund’s organizational and offering documents (collectively “Offering Documents.”) The Fund offers both Class A and Class B Interests. Class A and B interests are identical in all respects except that Class B interests will not be subject to a management fee and will only be offered and sold to qualified employees and affiliates of the Tschetter Group. If such employees cease to be affiliated with Tschetter Group, their Class B interest will be converted to a Class A interest and subject to the stated Class A interest management fee. We may issue additional classes of LP interests in the future, which may differ in terms of fees, allocations charged, and minimum investments.

Tailoring of Advisory Services We offer individualized investment advice to our portfolio management clients. Excluding an investment in our Fund, clients have the opportunity to place reasonable restrictions on the types of investments to be held in their portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account.

Participation in Wrap Fee Programs We do not offer or participate in a wrap fee program.

Important Information for Retirement Investors When we recommend that you rollover retirement assets or transfer existing retirement assets (such as a 401(k) or an IRA) to our management, we have a conflict of interest. This is because we will generally earn additional revenue when we manage more assets. In making the recommendation, however, we do so only after determining that the recommendation is in your best interest. Further, in making any recommendation to transfer or rollover retirement assets, we do so as a “fiduciary,” as that term is defined in ERISA or the Internal Revenue Code, or both. We also acknowledge we are a fiduciary under ERISA or the Internal Revenue Code with respect to our ongoing investment advisory recommendations and discretionary asset management services, as described in the advisory agreement we execute with you. To the extent we provide non-fiduciary services to you, those will be described in the advisory agreement.

Regulatory Assets Under Management As of March 16, 2026, we managed assets of approximately $2.2350 billion on a discretionary basis and $45.4 million on a non-discretionary basis.

Compensation for Our Advisory Services Comprehensive Portfolio Management: The maximum annual fee charged for this service will not exceed 1.50%. Fees to be assessed will be outlined in the advisory agreement to be signed by the client. Annualized fees are billed on a pro-rata basis monthly in advance based on the value of the account(s) on the last day of the previous month. Fees are negotiable and will be deducted from client account(s). In rare cases, we will agree to directly invoice. As part of the fee deduction process, Clients understand the following: a) The client’s independent custodian sends statements at least quarterly showing the market values for each security included in the Assets and all account disbursements, including the amount of the advisory fees paid to our firm. b) Clients will provide authorization permitting Tschetter Group to be directly paid from the custodian. c) We will send an invoice directly to the custodian for the amount of the advisory fee. d) If we send an internally produced statement to the client, we strongly urge the client to compare the information we provide in that statement with the information from the qualified custodian.

Private Funds: For TG Private Market Opportunities Fund LP Class A interests (“Fund”), Tschetter Group receives management fees as compensation for performing advisory services to the Fund. The management fee, with respect to each Class A Limited Partner, is payable quarterly in advance and is equal to .75% annually of the Class A Limited Partner’s capital account balance as of the last business day of the immediately preceding fiscal quarter (or if the Class A Limited Partner was not a Partner on such date, the first business day of the current fiscal quarter. Additionally, the Fund will pay an administrative fee to PPB TG PMO MGT LLC, the Fund’s co-general partner, of .0625% quarterly (.25% annually). This fee is charged quarterly in advance and allocated proportionally to each limited partner's capital account. This fee is subject to a quarterly minimum of $9,000. If the minimum fee is applied, it will be allocated to each limited partner on a pro-rata basis. At the sole discretion of the Fund’s general partner(s), and without the consent of the other Fund investors, fees may be waived or reduced for certain Limited Partners, including for Limited Partners that are principals, employees or affiliates (as described above) and/or for certain large or other investors the general partner(s) deems to be strategic.

The minimum subscription amount for Fund interests is $250,000. Initial capital contributions may be made on the last day of the calendar quarter, or at such other time with the consent of the general partner(s), at their discretion. Limited Partners may make additional contributions to the Fund on the last day of each calendar quarter, or at other times with the consent of the general partner(s), in minimum amounts of $100,000, which may be waived at the discretion of the general partner(s). Redemptions by Limited Partners. No voluntary partial redemptions or withdrawals are permitted without the prior written consent of the general partner(s), which may or may not be granted. Whether any redemptions/withdrawals are permitted, or distributions are made are dependent on each underlying fund permitting the Fund to withdraw interest in their fund. Withdrawal of Limited Partnership interests will be subject to any restrictions imposed by each underlying fund manager. In addition, no redemption/withdrawal will be made if it would violate any contract or agreement to which the Fund is then a party or any law then applicable to the Fund or if the general partner(s) at their discretion, determines that it In the case of termination of Tschetter Group’s investment management agreement with the Fund prior to the end of a calendar quarter, the management fees for such period would be pro-rated to the date of termination with any excess payment refunded to the Fund and credited to the Limited Partners capital account. Other Fees In addition to the management fee, the Fund will be responsible for reasonable costs and expenses of the Fund, including (i) accounting, bookkeeping, tax and auditing fees and expenses, and administrator fees; (ii) legal fees and expenses, including, but not limited to, fees and expenses incurred in connection with any offering of the Fund’s interests, Fund contracts and investments; (iii) all fees and disbursements of the Fund’s, the general partner’s and its attorneys, consultants and other third parties performing work benefiting the Fund or otherwise in connection with the Fund’s investment activities; (iv) organizational and start-up expenses; (v) expenses related to the acquisition, holding, monitoring or sale of portfolio investment that are consummated, costs and fees of evaluating existing or potential investments to be made by the Fund, due diligence costs (including travel expenses) incurred in researching potential investment opportunities), brokerage commissions payable to third parties, fees of consultants, brokers or other professionals or advisors who provide research, advice or due diligence services with regard to actual or potential investments and any other expenses reasonably related to the purchase, sale, monitoring or transmittal of Fund assets; (vi) valuation related expenses; salaries and benefits of personnel hired by the Fund on a full or part time basis; (vii) all federal, state and local taxes and foreign taxes assessed against the Fund or its investments or for which the Fund is required to withhold, and the costs of determination, challenge and compliance, if applicable, and any interest and penalties thereon (collectively, “Taxes”) (it being understood that taxes withheld due to state of residence and or tax status of a Limited Partner shall be specifically allocated and charged to the Capital Account of the Limited Partner); (viii) costs associated with pricing services; and (ix) costs related to the Fund’s indemnification of the general partners, Tschetter Group and their respective affiliates and/or the purchaser of a portfolio investment and all extraordinary expenses including, without limitation, litigation fees, judgments, penalties and expenses in connection with any legal action for or against the Fund (and the general partners, Tschetter Group and any affiliates, to the extent arising out of the affairs of the Fund), director and officer liability or other insurance and indemnification relating to the affairs of the Fund, each as the general partner(s) determine in their sole discretion. The above list of expenses is not exhaustive. Potential investors should review the offering documents of the Fund for a complete disclosure of fees and expenses. Layering of Fees and Expenses The allocation of the Fund’s assets to underlying funds will increase the fees and expenses payable by the Fund because the underlying portfolio managers charge their own fees and expenses, which are in addition to the general partner Fee, the management Fee, and expenses charged by the Fund. Each portfolio manager may charge its

investors a management fee, which will be in addition to the management fee charged by Tschetter Group the Fund will have to pay such fees, directly or indirectly.

The following methods of analysis and investment strategies may be utilized in formulating our investment advice and/or managing client assets, provided that such methods and/or strategies are appropriate to the needs of the client and consistent with the client’s investment objectives, risk tolerance, and time horizons, among other considerations. General Risks of Owning Securities The prices of securities held in client accounts and the income they generate may decline in response to certain events taking place around the world. These include events directly involving the issuers of securities held as underlying assets of mutual funds in a client’s account, conditions affecting the general economy, and overall market changes. Other contributing factors include local, regional, or global political, social, or economic instability and governmental or governmental agency responses to economic conditions. Finally, currency, interest rate, and commodity price fluctuations may also affect security prices and income. The prices of, and the income generated by, most debt securities held by a client’s account may be affected by changing interest rates and by changes in the effective maturities and credit ratings of these securities. For example, the prices of debt securities in the client’s account generally will decline when interest rates rise and increase when interest rates fall. In addition, falling interest rates may cause an issuer to redeem, “call” or refinance a security before its stated maturity, which may result in our firm having to reinvest the proceeds in lower yielding securities. Longer maturity debt securities generally have higher rates of interest and may be subject to greater price fluctuations than shorter maturity debt securities. Debt securities are also subject to credit risk, which is the possibility that the credit strength of an issuer will weaken and/or an issuer of a debt security will fail to make timely payments of principal or interest and the security will go into default.

The guarantee of a security backed by the U.S. Treasury, or the full faith and credit of the U.S. government, only covers the timely payment of interest and principal when held to maturity. This means that the current market values for these securities will fluctuate with changes in interest rates. Investments in securities issued by entities based outside the United States may be subject to increased levels of the risks described above. Currency fluctuations and controls, different accounting, auditing, financial reporting, disclosure, regulatory and legal standards and practices could also affect investments in securities of foreign issuers. Additional factors may include expropriation, changes in tax policy, greater market volatility, different securities market structures, and higher transaction costs. Various administrative difficulties, such as delays in clearing and settling portfolio transactions, or in receiving payment of dividends can increase risk. Finally, investments in securities issued by entities domiciled in the United States may also be subject to many of these risks.

Investment Strategies Proprietary Models: Tschetter Group develops proprietary asset allocation models and investment strategies as part of our investment process. The purpose of these models and strategies is to create a foundation for clients’ investment portfolios based on their individual risk tolerance, investment timeframe, and specific investment goals. Our proprietary models provide recommended percentage allocation ranges to specific asset classes based on risk tolerance. Our risk tolerance models typically range from aggressive to conservative, with several levels in between. We then tailor our investment model to fit clients’ individual investment needs and goals. The risks associated with our proprietary models reflect risks similar to that of asset allocation strategies. This includes that a client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that a client’s actual holdings may deviate from the model over time and if not corrected, may no longer be appropriate for the client’s goals. We determine asset allocation for each client to ensure the appropriate mix in light of investment objective and risk tolerance. Our firm periodically reviews and rebalanced portfolios to maintain target allocation. Standard portfolio classifications are as follows, although we customize allocation when/as necessary:

Aggressive Growth (100/0) Moderate Growth (80/20) Moderate Balanced (60/40) Balanced (50/50) Income and Growth (40/60) Income (20/80)

Performance for portfolios may be benchmarked against an appropriate blend of market indices depending on asset and strategy allocation. Strategy benchmarks are specified below. Equity Portfolio Management: We primarily build out domestic equity allocations using individual stocks through two strategies, Dividend Growth and Capital Appreciation. The amount invested in each strategy may be adjusted to suit an individual’s specific objectives or risk tolerance; a neutral mix utilized in the majority of domestic equity allocations is 50/50. These strategies are supplemented with an allocation to TG International for non-U.S. equity exposure. Buy/sell decisions for individual equities is driven by third party research recommendations and our team’s own due diligence. Equity allocations, sector weights vs. benchmark, and individual position sizes are regularly monitored using proprietary tools developed by the team as well as tools provided by 3rd party vendors. A typical stock portfolio will contain 30-40 individual stocks with an average position size of ~3%. We monitor company fundamentals and valuation metrics on a weekly basis using analytical tools developed internally. We may also utilize equity mutual funds or ETFs in certain situations including, but not limited to, achieving appropriate diversification for smaller accounts.

TG Core | Dividend Growth Strategy: This strategy seeks to generate above average dividend income and attractive long-term appreciation potential. Using both fundamental and quantitative research, the investment team identifies companies that have a proven track record of dividend and earnings growth as well as a positive outlook for future growth. The goal of the strategy is to emphasize consistent and growing dividends while minimizing risk and volatility compared to the S&P 500 Index. Generally, companies considered for inclusion in the Strategy have a minimum 10-year history of consecutive dividend increases, and preferably longer. The companies that are identified and selected for this strategy tend to be large cap, national or multi-national firms that are generally leaders in their industries with strong, consistent management teams. Broad sector diversification of companies committed to a stable and growing dividend serve as the strategy’s primary risk management tools. The strategy has low portfolio turnover, though we rebalance the positions at least semiannually, or more frequently depending on circumstances, for additional risk management. Reasons a stock may be removed from the portfolio may include, but are not limited to, a cut or potential cut to the dividend, no increase to the dividend within the required time frame (typically one year), or deterioration in the fundamentals of the company. We also apply valuation considerations to the portfolio decision process and may remove a stock if we believe the valuation is extended or there are more attractive alternatives. The Dividend Growth strategy targets 15-20 individual stocks for inclusion. Our benchmark for the Dividend Growth Strategy is the Russell 1000 Value Index and the secondary benchmark is the S&P 500 Index. TG Core | Capital Appreciation Strategy: This strategy seeks to provide capital appreciation with a concentrated portfolio of equity holdings. Using both fundamental and quantitative research, the investment team identifies companies it believes are priced below intrinsic value. The goal of the strategy is to maximize risk-adjusted returns with an emphasis on stock price growth. The companies that are identified and selected for the Capital Appreciation strategy may be Small, Mid, or Large-Cap companies. We look for attractive valuation opportunities using a variety of fundamental measures and also emphasize companies with a solid financial position. We monitor company fundamentals and valuation metrics for companies we own on an ongoing basis utilizing financial database (Bloomberg) and spreadsheet tools developed by the team. The Capital Appreciation strategy targets 15-25 stocks for inclusion. The benchmark for our Capital Appreciation strategy is the S&P 500 Index, and the secondary benchmark is the Russell 3000 TR Index. TG Core | International Equity: The strategy seeks to invest in actively managed international equity funds that provide broad, diversified exposure as a core component of a balanced investment portfolio. We believe investors should maintain a strategic allocation to both developed and emerging international equities, which offer exposure to different economic cycles, policy regimes, and currency dynamics than the U.S. market — factors that can enhance long-term returns and improve overall portfolio diversification. International markets offer access to a wide range of strong companies with compelling growth opportunities, many of which are underrepresented in most U.S.-focused portfolios. While international equities can experience periods of higher volatility and currency fluctuations, we believe that, over a long-term investment horizon (5+ years), these exposures can strengthen portfolio resilience and improve risk-adjusted returns. If the account is of sufficient size to implement a sound portfolio of individual bonds, we identify corporate, municipal, or treasury bonds for portfolio construction. We analyze portfolio characteristics (maturities, call features, duration, credit quality, etc.) using 3rd party software. We may shift the duration, bond type, or quality profile of the fixed income portfolio based on our view of relative value/risk offered in the market. Generally, investment grade rated bonds comprise the large majority of a fixed income portfolio, although we may utilize high yield bonds as appropriate. We may also utilize bond mutual funds, ETFs, or sub-advisors if deemed to be in the clients’ best interest. TG Innovation Strategy: This strategy looks to identify early and mid-stage public companies that are innovators and disruptors in promising growth industries. Owning a basket of these companies can complement a traditional stock portfolio. The Strategy aims to deliver compelling appreciation potential for long-term investors who are willing to accept higher levels of risk.

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We have the following types of clients:

Individuals and High Net Worth Individuals Trusts, Estates or Charitable Organizations Corporations, Limited Liability Companies and/or Other Business Types

We do not impose minimum requirements for opening and maintaining accounts or otherwise engaging us. However, we charge a separate financial planning fee when we manage less than $500,000 of a client’s household assets. The minimum investment in our Fund is $250,000 which may be waived at the discretion of Tschetter Group.

We do not charge performance-based fees for any separately managed accounts. While our Fund does not charge a performance fee, the underlying managers in the Fund will each receive an incentive or performance-based fee. This fee will vary by manager and is paid by the Fund and allocated as an expense against the Limited Partners’ capital account. Please refer to the Fund’s complete offering documents for more information about the specific fees charged to the Fund.

Tschetter Group is a licensed insurance agency in Washington state and some of our employees are licensed as insurance agents. While providing advisory services to clients, these individuals may recommend an insurance product to an advisory client. Being insurance licensed means both Tschetter Group and the licensed insurance agent can receive revenue resulting from implementing insurance transactions on behalf of advisory clients. Clients are not under any obligation to engage Tschetter Group or its representatives when considering implementation of insurance recommendations. The implementation of any or all insurance recommendations is solely at the discretion of the client. Tschetter Group and its licensed insurance agents receive separate, yet customary commission compensation when a client chooses to implement our insurance recommendations through us, or through a partner insurance agency helping to facilitate our recommendations. This potential for additional revenue creates a conflict of interest in that we have an incentive to recommend an insurance product because of the additional potential revenue. As part of our fiduciary duty to our clients, we always endeavor to put the interests of our clients first, above our own and we take the following steps to address this conflict:

We only recommend an insurance product to an advisory client when we believe the product coverage, terms, and cost are in the best interests of that client. We disclose to clients the existence of all material conflicts of interest, including the potential for our firm and our employees to earn additional compensation beyond our advisory fees. We disclose to clients that they are not obligated to purchase recommended insurance products from Tschetter Group or our representatives. We educate our employees regarding the responsibilities of a fiduciary, including the need to have a reasonable and independent basis for the investment advice provided to clients.

We have an advisory representative who is also a registered representative of an unaffiliated broker-dealer, PKS. He maintains his registration with a broker-dealer for the purpose of providing clients with access to certain investment products and solutions not currently offered on our investment advisory platform. These investment products typically generate a commission payable to the representative. The potential for additional revenue creates a conflict of interest, which is discussed in more detail in the individual’s ADV Part 2B Brochure Supplement. General Partner Affiliation TG Partners LLC, our affiliate, is the general partner to our Fund. We share resources with the general partner, including offices and staff. Neither Tschetter Group nor its affiliate is registered and do not plan to register as a broker-dealer, futures commission merchant, or commodity pool operator/trading advisor.

As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to always act solely in the best interest of each of our clients. Our fiduciary duty is the underlying principle for our firm’s Code of Ethics, which includes procedures for personal securities transaction and insider trading. Our firm requires all employees to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws. Upon employment with our firm, and at least annually thereafter, all employees will acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and its employees must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively

affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. If a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. We recognize that the personal investment transactions of our employees must be carried out in a way that does not endanger the interest of any client. At the same time, we also believe that if investment goals are similar for clients and for our employees, it is logical, and even desirable, that there be common ownership of some securities. In order to prevent conflicts of interest, we have established procedures for transactions effected by our employees for their personal accounts. In order to monitor compliance with our personal trading policy, we generally request employees trade alongside clients in a block transaction, if possible, to minimize potential conflicts. If not trading in a block with clients, we require pre-clearance on individual stock transactions. We also obtain and review a quarterly securities transaction report for all associated person accounts for which they have direct or beneficial ownership. In order to minimize this conflict of interest, our employees will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Further, our employees will refrain from buying or selling the same securities prior to buying or selling for our clients in the same day unless included in a block trade. If we recommend a security in which any employee has a material financial interest, we will provide disclosure to the client at or prior to the time of that recommendation. Employees of our firm buy and sell securities and other investments that are also recommended to clients. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics.

The Custodian and Brokers We Use Our firm does not maintain custody of (hold) client assets; however, we are deemed to have custody of client assets when clients give us written authority to withdraw assets from accounts, described in Item 15 Custody, below. Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. We recommend our clients use Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer, member SIPC, as the qualified custodian. We are independently owned and operated and not affiliated with Schwab. Schwab will hold client assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend that you use Schwab as custodian/broker, you will decide whether to do so and open an account with Schwab by entering into an account agreement directly with them. We do not open the account for you, although we assist in doing so. Even though the account is maintained at Schwab, we can still use other brokers to execute trades for your account as described below (see “Your brokerage and custody costs”). How We Select Brokers/Custodians We seek to use a custodian/broker who will hold your assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, but not limited to:

combination of transaction execution services along with asset custody services (generally without a separate fee for custody) capability to execute, clear and settle trades (buy and sell securities for client accounts) capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.)

breadth of investment products made available (stocks, bonds, mutual funds, exchange traded funds (ETFs), etc.) availability of investment research and tools that assist in making investment decisions quality of services competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate them reputation, financial strength and stability of the provider prior service to our firm and our other clients availability of other products and services that benefit us, as discussed below (see “Products and services available to us from Schwab”).

Your Brokerage and Custody Costs For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades, for example many individual stocks and ETFs, do not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. In addition to commissions, Schwab charges you a flat dollar amount as a “prime broker” or “trade away” fee for each that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Schwab account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize costs, we have Schwab execute most trades for your account. We have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above under “How We Select Brokers/Custodians.” Products & Services Available to Us from Schwab Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like Tschetter Group. They provide our clients and us with access to their institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help manage or administer our client accounts while others help manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (we do not have to request them) and at no charge to us. Following is a more detailed description of Schwab’s support services: Services that Benefit Clients Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph Services that May Not Directly Benefit Clients Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist in managing and administering our clients’ accounts. They include investment research, both Schwab’s and that of third parties. We may use this research to service all or some substantial number of client accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that:

provide access to client account data (such as duplicate trade confirmations and account statements). facilitate trade execution and allocate aggregated trade orders for multiple client accounts. provide pricing and other market data.

facilitate payment of our fees from our clients’ accounts. assist with back-office functions, recordkeeping and client reporting.

Services that Generally Benefit Only Us Schwab also offers other services intended to help manage and further develop our business enterprise. These services include:

educational conferences and events consulting on technology, compliance, legal, and business needs publications and conferences on practice management and business succession access to employee benefits providers, human capital consultants and insurance providers marketing consulting and support

Schwab may provide some of these services itself. In other cases, Schwab will arrange for third-party vendors to provide the services to our firm. Schwab may also discount or waive fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits, such as occasional business entertainment for our personnel. Our Interest in Schwab’s Services The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services, and they are not contingent upon committing any specific amount of business to Schwab in trading commissions or assets in custody. In light of our arrangements with Schwab, a conflict of interest exists as we have incentive to require that clients maintain their accounts with Schwab, based on our interest in receiving Schwab’s services that benefit our business and Schwab’s payment for services for which we would otherwise have to pay rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. We believe, however, that or selection of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How We Select Brokers/Custodians” above) and not Schwab’s services that benefit only us. Soft Dollars We have discretion over the selection of the broker-dealer to be used and the commission rates to be paid. In selecting a broker-dealer for any transaction or series of transactions, we consider a number of factors including net price, clearance, settlement, reputation, financial strength and stability, efficiency of execution and error resolution, block trading and block positioning capabilities, willingness to execute related or unrelated difficult transactions in the future, order of call, offering us on-line access to computerized data regarding clients’ accounts, computer trading systems, and other matters involved in the receipt of brokerage services generally. We also purchase from a broker-dealer, or allow a broker to pay for, certain research products and services (a “soft dollar” relationship). These research products and services include online access to financial news and research, securities price quotes, security characteristics. Section 28(e) of the Securities Exchange Act of 1934 provides a “safe harbor” to investment advisers who use soft dollars of their advised accounts to obtain investment research and brokerage services that provide lawful and appropriate assistance to the adviser in performing investment decision-making responsibilities. Conduct outside of the safe harbor of section 28(e) is subject to the traditional standards of fiduciary duty under state and federal law. If Tschetter Group uses commission dollars to pay for products or services that provide administrative or other non-research assistance to itself or its affiliates, such payments may not fall within the section 28(e) safe harbor. Subject to best execution considerations, when Tschetter Group directs client transactions to certain broker-dealers from which we receive research products and services, the receipt of such research services and products using “soft dollars” can be seen as benefiting Tschetter Group in the sense that we would otherwise have to directly pay

for such products and services itself. Thus, the use of "soft dollars" generated through client transactions to acquire such products and services creates a conflict of interest. Tschetter Group has a conflict of interest between allocating client brokerage to a broker-dealer through which Tschetter Group generates “soft dollar” credits and allocating brokerage to other broker-dealers. We have established guidelines to monitor such soft dollar arrangements, that the costs continue to be the best option for our clients, and to ensure any products and services received through such arrangements are eligible research or brokerage services under Section 28(e) of the Securities Exchange Act of 1934. As we note above in our Brokerage Practices section, we occasionally receive services provided free of charge from custodians and/or investment providers that are generally used to further our business enterprise. We can also receive modest cost reimbursements related to our company events from custodians and/or investment providers. These types of “soft dollars” do not fall within the safe harbor provisions of 28(e). These services are further outlined under Services That Generally Benefit Only Us (above). Aggregation of Orders We aggregate the securities to be purchased or sold in client accounts if we deem such a block trade is likely to result in more favorable pricing for our clients. This means execution prices for identical securities on behalf of multiple client accounts in any one business day are averaged. In any given situation, we attempt to allocate trade executions in the most equitable manner possible, taking into consideration client objectives, current asset allocation and availability of funds using price averaging, proration and consistently non-arbitrary methods of allocation. However, there may be circumstances preventing us from treating all accounts equally in connection with every trade. Where, because of prevailing market conditions, it is not possible to obtain the same price or time of execution for all securities purchase or sold for client accounts, we will allocate the securities on a pro-rata basis and in accordance with our order allocation procedures to ensure the fair and equitable treatment of all accounts. Clients should be aware that our primary custodian, Charles Schwab & Co., Inc. ("Schwab"), may apply "allocation fees" or "handling fees" to individual accounts within a block trade under certain circumstances. These fees are generally triggered by factors outside our direct control, such as the total 30-day trading volume of a security or when a trade requires manual intervention by the custodian’s trade desk. While we block trades to promote price equality and operational efficiency, these custodian-imposed fees may at times result in higher total transaction costs for an individual account than if the trade had been executed independently. We periodically review our trading practices and custodian fee structures to ensure our aggregation methods remain in the best interest of our clients. We may elect to forgo trade aggregation if we determine that the additional allocation fees would outweigh the benefits of an average execution price.

Charles Schwab & Co., Inc. We receive an economic benefit from Schwab in the form of the support products and services they make available to us and other independent investment advisors whose clients maintain accounts at Schwab. These products and services, how they benefit our firm, and the related conflicts of interest are described above in Item 12 of this brochure. The availability of Schwab’s products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. Referral Fees We do not compensate anyone outside of TG for client referrals. We do not receive fees from anyone for referring clients to third parties.

There are no legal or disciplinary events that are material to the evaluation of our advisory business or the integrity of our management.

Our management personnel or financial advisors review accounts on at least an annual basis for our Portfolio Management clients. The nature of these reviews is to learn whether client accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. Our firm does not provide written reports to clients, unless asked to do so. Verbal reports to clients take place on at least an annual basis when our Portfolio Management clients are contacted. Our firm may review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. Financial Planning clients do not receive reviews of their written plans unless they take action to schedule a financial consultation with us. Our firm does not provide ongoing services to financial planning clients, but are willing to meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. Financial Planning clients do not receive written or verbal updated reports regarding their financial plans unless they separately engage our firm for a post-financial plan meeting or update to their initial written financial plan.

On an annual basis, each investor in our private fund receives a copy of the private fund’s audited financial statements prepared by our independent auditors and includes tax-reporting information. We also provide additional information as requested, provided that such requests are deemed reasonable in content and scope and that we are prepared to supply the same level of information to other investors who may ask for similar information.

Excluding our private fund, all client assets are held by a qualified custodian, and we do not hold (or custody) client funds or securities. We are, however, deemed to have custody in instances where a client signs a standing letter of authorization (SLOA) that allows us to move money to a designated third party without obtaining a signature from the client each time. We are in compliance with the conditions set forth by the SEC relating to SLOAs and, therefore, do not obtain a surprise exam for those assets. We are also deemed to have custody when a client authorizes us in writing to withdraw advisory fees automatically from their account. All of our clients receive account statements directly from their qualified custodians at least quarterly upon opening of an account. We urge clients to compare their account statements received from their qualified custodian with any periodic reports you receive from us. Clients are encouraged to raise any questions with us about the custody, safety or security of their assets and our custodial recommendations. With respect to our private fund, we are not required to comply with certain requirements of the custody rule because we comply with the provisions of the so-called ‘audit exception’ for pooled investment vehicles. Among other things, the exception requires that the private fund be subject to audit at lease annually by an independent public accountant that is registered with, and subject to inspection by, the Public Company Accounting Oversight Board. Because our private fund is a “fund of funds” we are required to distribute its audited financial statements to all investors within 180 days after the end of the fiscal year.

Our usual practice is to have our clients provide us with investment discretion on their behalf, pursuant to an executed investment advisory client agreement. By granting investment discretion to us, we are authorized to execute securities transactions, determine which securities are bought and sold, and the total amount to be bought and sold without first obtaining your permission. When clients grant our firm non-discretionary authority, we are required to obtain the client’s permission prior to effecting securities transactions. Limitations may be imposed by

the client in the form of specific constraints on any of these areas of discretion with our firm’s written acknowledgement. We have full discretionary authority over all of the assets we manage in the Fund pursuant to a Limited Partnership Agreement and consistent with the investment objectives and strategy as described in the Fund’s offering documents.

SEC Rule 206(4)-6 requires investment advisers who have voting authority with respect to securities held in their clients’ accounts to monitor corporate actions and vote proxies in their clients’ interests. Our firm is required by the SEC to adopt written policies and procedures, make those policies and procedures available to clients, and retain certain records with respect to proxy votes cast. We vote client proxies when authorized to do so in writing by a client. We understand our duty to vote client proxies and to do so in the best interest of our clients. Furthermore, it is understood that any material conflicts between our interests and those of our clients with regard to proxy voting must be resolved before proxies are voted. We subscribe to a proxy monitor and voting agent service, which includes access to proxy analyses with research and vote recommendations. We will generally vote in accordance with the recommendations but may vote in a different fashion if we determine that such actions are in the best interest of our clients. Where applicable, we will consider any specific voting guidelines designated in writing by a client. Clients may request a copy of our written policies and procedures regarding proxy voting and/or information on how particular proxies were voted by contacting our Chief Compliance Officer. Proxy Voting Guidelines Where voting authority exists, we utilize the services of a third-party service provider to vote client proxies. The service provider we have selected is an independent provider of proxy research, voting recommendations and voting services. We believe this independence limits their potential conflicts around decisions relating to publicly traded securities. Our policy is to vote proxies in the best interests of our clients. We have adopted the voting guidelines of our service provider but may choose to vote differently under certain circumstances. We have adopted written policies and procedures regarding the voting of proxies. These policies and procedures are designed to ensure that we fulfill our fiduciary obligation to you in connection with proxy voting and that we vote them in clients’ best interests. This includes ongoing review and assessment of our third-party proxy voting service provider for conflicts of interest, their research and analysis, and that voting continues to be in accordance with their guidelines and in the best interests of shareholders. Egan-Jones publishes their complete proxy voting guidelines each year, which we will provide to clients upon request. Generally, our firm votes FOR or AGAINST proposals or nominees, but may ABSTAIN in certain instances. Some voting is determined on a case-by-case basis to ensure the recommendation is appropriate. We will defer to instruction from clients in all voting matters. Records of all issues and votes are maintained and reported to clients as requested. We recognize that under certain circumstances our firm may have a conflict of interest between us and our clients. Such circumstances may include, but are not limited to, situations where our firm or one or more of our affiliates, including officers, directors and employees, has or is seeking a client relationship with the issuer of the security that is the subject of the proxy vote. As a matter of practice, we do not seek out relationships with issuers and do not expect conflicts to arise. If such a situation arises, we will not vote proxies relating to such issuers on behalf of client accounts until we determine that the conflict of interest is not material or a method of resolving such conflict of interest has been agreed upon by our management team. A conflict of interest will be considered material to the extent that it is determined that such conflict has the potential to influence our decision-making in voting a proxy. Materiality determinations will be based upon an assessment of the particular facts and circumstances. If our firm determines that a conflict of interest is not material, our firm may vote proxies notwithstanding the existence of a

conflict. If the conflict of interest is determined to be material, the conflict shall be disclosed to our management team and our firm shall follow the instructions of the management team. We will maintain files relating to our proxy voting procedures, a record of each voted, and the research documenting the rationale for how your proxies were voted for 5 years. We will also retain a copy of each written client request for information on how our firm voted such client’s proxies, and a copy of any written response to any client request for information on how our firm voted their proxies. Our general policies and procedures regarding proxy voting are disclosed here. Detailed guidelines and information on how particular proxies were voted are available upon request to our Chief Compliance Officer.

We are not required to provide financial information in this section because we do not require prepayment of more than $1,200 in fees when services cannot be rendered within 6 months, and we do not have a financial condition or commitment that impairs our ability to meet contractual and fiduciary obligations to clients. We have never been the subject of a bankruptcy proceeding.