SOWA Financial Group Inc

Item 5. Fees and Compensation

  I.      INVESTMENT ADVISORY SERVICES COMPENSATION

       1. Percentage of Assets Based Compensation

           a) Clients choosing Investment Advisory Services (described in Item 4.A above) will compensate
              SFG based on a percentage of the total value of their investment advisory account portfolio
              (including annuities consisting of no-load funds for which SFG Adviser did not receive any
              commission upon purchase, but there may be additional costs - See Items 13, 14 and 15 below)
              as of the last business day of each prior calendar quarter. Generally, such compensation is
              calculated by dividing the number of days that the account was active for the prior calendar
              quarter by 365, multiplying the quotient by the annual percentage rate set forth below, and
              multiplying the product by the portfolio value at the end of the prior calendar quarter, as
              adjusted (see immediately below).

           b) SFG also draws a distinction between new clients (those who do not hold existing accounts with
              SFG where SFG has not received transaction-based compensation) and those who are existing
              SFG clients (those with existing accounts where SFG has already received transaction-based
              compensation). As illustrated below, existing SFG clients who convert their account(s) to managed
              account(s) may be offered a discounted rate. SFG’s managed account program generally has a
              $250,000 minimum investment requirement. Account balances may be combined at the household
              level to satisfy the account minimum. SFG reserves the right to waive the minimum investment
              requirement for any reason in our sole discretion. See also Item 7 below.

                   i.      New Clients The annual fee percentage is based on a tiered fee schedule generally
                           applicable to new clients on amounts comprising such client’s portfolio as follows:

                        Tier             Applies to Assets Under Management              Percentage of Assets

                          1    The first $250,000                                              1.50%
                          2    Additions and/or Amount from $250,000.01 to $500,000.00         1.00%

                          3    Additions and/or Amounts from $500,000.01 to $750,000           0.80%

                          4    Additions and/or Amounts from $750,000.01 to $1,000,000         0.70%

                          5    Additions and/or Amounts from $1,000,000.01 to                  0.65%
                               $1,500,000
                          6    Additions and/or Amounts from $1,500,000.01 to                  0.60%
                               $2,000,000
                          7    Additions and/or Amounts over $2,000,000                       As agreed

        The annual percentage applicable to new clients shall be a blended rate, charged based on the
        above tiered fee schedule.

ADV Part 2A                                            IRS Empl. Ident.    SEC File      Date:
Sowa Financial Group, Inc.                             No.                 Number:       1/27/2026
                                                       05-0509395          801-43008

       For instance, new client fees shall be assessed in the following manner:

                             • 1.50% of the first $250,000.00 in the client’s account;
                             • 1.00% on amounts in client’s portfolio between $250,000.01 to
                                 $500,000.00;
                             •   0.80% on amounts in client’s portfolio between $500,000.01 to
                                 $750,000.00; and
                             •   following the fee tiers for each addition or increase to the account raising
                                 the value of the account to each tier benchmark.

                  ii.   Existing Clients

                    a) Wishing to Convert The annual percentage applicable to existing clients who
                    have already paid transaction-based compensation and wish to convert assets to
                    Investment Advisory Services may be discounted as deemed appropriate by SFG, and
                    different clients engaged in identical transactions may pay more or less than other clients
                    for the same services. Client may be able to obtain comparable services provided by
                    and/or through others for lower fees.

                    b) Wishing to Remain Financial Planning Only Clients Existing clients not wishing
                    to convert to the Investment Advisory Service program may continue to use solely the
                    Financial Planning Services or services as described above.

                    c) Flat Fee Clients may also engage SFG for Financial Planning Services and will be
                    charged a flat fee for such services, as further described in Section 5.II below.

                    d) Variations From time to time, SFG may, by agreement with clients, based on the
                    relative complexity of the services, charge fees different from (but in no event higher than
                    those stated) those outlined hereinabove. All such fees shall be fully disclosed, assented
                    to, and evidenced in writing signed by client and SFG. The aggregate amount paid by
                    clients may vary, and clients (given the differences between and among clients, their
                    needs and their distinct objectives, and the possible varying complexities) may pay
                    different rates and/or fees, which means different clients may receive the same services,
                    but pay different rates and/or fees.
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Types of Clients:

            • Individuals
            • High Net Worth Individuals
            • Trusts, Estates and Charitable Organizations

For clients seeking Investment Advisory Services, SFG has minimums on the initial total portfolio value.
Clients of SFG seeking Investment Advisory Services are generally required to have an initial total
portfolio value of $250,000 or more. All of the foregoing may be negotiated from time to time at the
discretion of SFG.