ATLANTA CONSULTING GROUP ADVISORS, LLC

Atlanta Consulting Group Advisors, LLC (ACG or the Firm), a Georgia limited liability company, is a boutique investment advisory firm headquartered in Atlanta, Georgia with an office in Lexington, Kentucky. ACG was originally founded in 1985, as a separate business unit within Morgan Keegan & Co. In November of 2017, ACG became an independent employee/founder-owned investment adviser registered with the SEC. From its Lexington office, ACG provides advisory services under the name Brewer Private Wealth. The contents of this Brochure apply to the activities of both ACG and Brewer Private Wealth.

ACG provides non-discretionary investment advisory services as well as discretionary/OCIO portfolio management to retirement plans, including defined benefit plans, defined contribution plans, 401(k) plans, 403(b) plans and 457 plans, trusts, charitable organizations, endowments, foundations, corporations, family offices, individuals, and high net worth individuals.

Investment Goals & Objectives

At the outset of each client relationship, ACG reviews the clients investment objectives and identifies the major investment goals of the client. Based on the information provided by the client, the Firm will tailor its services and make recommendations regarding the portfolio structures, allocation models, and investment strategies to be utilized with respect to each client. For institutional clients, ACG typically considers the clients assets, its capital structure, its operating expectations, and its mission, among other factors.

The Firm may consider the tax implications of the investment strategies recommended to clients. In addition, ACG may consult with the clients outside professionals (e.g., legal and tax) to help ensure the clients strategy is consistent with the clients larger wealth plan and/or investment objectives and goals. With respect to certain matters, the Firm may advise clients to seek the assistance of, and coordinate with, outside professionals.

A clients strategy generally will be updated from time to time when requested by the client, or when determined to be necessary or advisable by ACG based on updates to the clients financial or other circumstances.

Implementing the Strategy

To implement a clients investment strategy, ACG will make recommendations for the clients investment portfolio on a non-discretionary basis or manage the clients investment portfolio on a discretionary basis, in each case pursuant to an Advisory Agreement with the client. When acting as a non-discretionary investment adviser, the Firm receives authorization from the client before executing trades. In such instances, the client retains responsibility for making the final decision with respect to all actions taken in the portfolio.

Outsourced Chief Investment Officer (“OCIO”) Services

In addition to traditional investment advisory services, ACG offers discretionary and Outsourced Chief Investment Officer (OCIO) advisory services. Discretionary/OCIO services help expedite the implementation process by giving ACG the authority and discretion to determine client asset class targets, select, hire, and terminate Managers, execute transactions within the clients predetermined investment guidelines, and rebalance the clients portfolio. Together with the client, ACG establishes target investment allocation ranges for individual asset classes during the investment policy statement development and review stages. These ranges are established to help guide the allocation of investments while maintaining the risk profile designated by the client. When acting as a discretionary/OCIO investment adviser, ACG has the authority to supervise and direct the trading within the portfolio without prior consultation with the client.

Notwithstanding the foregoing, clients may impose certain reasonable written restrictions in the management of their investment portfolio, such as prohibiting the purchase of certain types of investments or prohibiting the sale of certain investments held in the account at the commencement of the relationship. However, any reasonable restrictions imposed by a client, and agreed upon by ACG, can adversely affect the composition and performance of the clients investment portfolio. For these and other reasons, performance of client investment portfolios with the same or similar investment objectives, goals, and/or risk tolerances will differ from each other, and clients should not expect that the composition or performance of their investment portfolio will be consistent with similar clients of the Firm.

Separate Account Managers

Where appropriate, ACG recommends or selects one or more Separate Account Managers (each, a Manager) for a particular client through either the managed accounts program offered by Raymond James & Associates, Inc. (Raymond James) or through the Managed Account Select Program offered by Charles Schwab & Co., Inc. (Schwab). ACGs access to various Managers allows the Firm to offer clients access to a wide variety of manager styles and provides the opportunity to utilize more than one Manager. Factors that ACG considers in recommending/selecting Managers generally include the clients stated investment objectives, and the Managers management style, performance, risk level, reputation, financial strength, reporting, pricing, and research.

Managers will generally be granted discretionary trading authority to provide investment supervisory services for the portfolio. Under certain circumstances, ACG retains the authority to terminate Manager relationships or to hire new Managers without the need to obtain client consent. In other cases, the client will ultimately select one or more Managers recommended by the Firm. The Firm monitors the investment approach and performance of such Managers.

Wrap Fee Programs

ACG also utilizes the Managers available in Wrap Fee Programs sponsored by Raymond James (the Raymond James Wrap Program). A wrap fee program is one that charges a single bundled fee (the wrap fee) which typically includes the Firms Advisory Fee, the fees of any Managers, and all applicable brokerage expenses (e.g., for trading, custodial, and administrative services) incurred by the account. The Raymond James Wrap Program offers a wide variety of Manager styles which gives clients the opportunity to utilize more than one Manager, if necessary, to meet the needs and investment objectives of the client.

Retirement Plan Advisory Services

ACG provides retirement plan advisory services to employee benefit plans, which include defined benefit plans, defined contribution plans, pooled and participant-directed 401(k) plans, 403(b) plans and 457 plans, as well as to their fiduciaries based upon an analysis of the needs of each plan. In general, these services include existing plan review, asset allocation advice, money management services, communication and education services, investment performance monitoring, and/or ongoing consulting.

ACG also assists Employee Retirement Income Security Act (ERISA) plan sponsors who might not have the time or resources to devote to the role of plan fiduciary, or who wish to avoid the personal liability that accompanies the role. As a plans designated fiduciary, ACG can serve as the plans 3(38) investment manager, offering a comprehensive investment strategy designed for ERISA retirement plans and taking on the responsibility for meeting a plans many fiduciary obligations. ACG also has access to other third-party service providers who can act in this capacity, if desired by the plan sponsor.

Financial Planning

ACG offers financial planning services, in conjunction with portfolio management, to those in need of additional guidance in shaping and reaching their financial goals. The Firm will use Goal Planning and Monitoring (GPM) software to create and monitor a financial plan tailored to each individual to whom such services are provided.

Model Portfolios

For certain private wealth clients, where appropriate, ACG offers several model portfolios which can act as the foundation of a clients investment strategy. ACG recommends the model portfolio it believes best aligns with the clients stated investment objectives, risk tolerance, and time horizon. The model portfolio can be tailored further depending upon the unique circumstances and needs of each client.

Donor-Advised Funds

ACG supports its philanthropically minded clients by helping to simplify and streamline the charitable giving process. ACG provides access to various Donor-Advised Fund (DAF) platforms that can assume the responsibility for making grants to charitable organizations on behalf of clients so that they can enjoy the power of giving without the hassle of timing, tax concerns, expenses, and record-keeping. Donor-Advised Funds that are tax-qualified public charities can provide clients with an immediate and full tax deduction for the contribution and, at the same time, seek to increase the value of the original gift through prudent investing.

Since ACG does not provide tax or legal advice, clients considering charitable giving are urged to consult their attorney, accountant, and/or tax advisor with questions related to the deductibility of contributions made to a Donor-Advised Fund for federal and state tax purposes. Additional details about these programs, including associated fees and costs, are included in the Donor-Advised Fund platforms disclosure brochure and other documentation.

Trustee Services

ACG assists clients seeking to appoint a third-party Trustee to accept the responsibility of navigating the daily complexities of Trust oversight. Trustees are obligated to act in the best interests of both current and future trust beneficiaries an often complex and time-consuming responsibility. They must comply with specific trust document provisions as well as state and federal laws that govern trusts. If desired, ACG can facilitate introductions to qualified Trustee service providers who can act as a Trusts sole trustee or as co-trustee alongside a family member, friend, or other trusted advisor.

Non-Advisory Services

From time to time, ACG offers non-advisory services to its clients such as Execution-Only trade or Reporting-Only services.

Referral Services

For clients with needs beyond traditional investment advisory services, such as mortgage lending, securities-based lines of credit, and investment banking, ACG can facilitate introductions to unaffiliated third-party providers who offer such services. In some cases, ACG receives a referral fee for making such introductions.

Regulatory Assets Under Management

As of December 31, 2025, the Firms total Regulatory Assets Under Management (RAUM) was approximately $14,698,439,022, of which approximately $2,189,349,778 was managed on a discretionary/OCIO basis and $12,509,089,244 on a non-discretionary basis.