Victory Financial Group LLC

Item 5 – Fees and Compensation

VFG offers services on a fee basis, which includes fees based upon assets under management or advisement.
Additionally, certain of the Firm’s Supervised Persons, in their individual capacities, offer insurance
products under a separate commission-based arrangement.

Investment Management or Wealth Management Fees
VFG offers investment management and wealth management services for an annual fee based on the
amount of assets under the Firm’s management. This fee varies between 25 and 150 basis points (0.25%
– 1.50%), depending upon the size and composition of a client’s portfolio, the type and amount of services
rendered. Separate from, and in addition to his fee, you may pay an additional third-party management
fee if the strategy you have selected involves a third-party manager. This additional fee shall vary based
on the manager selected and shall be stated in your agreement with the third-party manager. However,
in no event shall the combined fee for your asset management services exceed 2.99%. In addition, the
Firm’s investment adviser representatives (“IAR”) determine the fee charged to the client, so clients can

Victory                       ADV Part 2A             March 26                  Page 10 of 38
                                                                                 © 2025 Red Oak Compliance Solutions LLC

pay a higher fee than another IAR would charge under similar circumstances. If a Third-Part Independent
Manager is engaged for the management of your assets, this fee shall be inclusive of any Third-Party
Independent Management Fees described below.

The annual fee is prorated and charged monthly or quarterly, in advance or arrears, or as otherwise
indicated in your advisory agreement, based upon the market value of the assets being managed by VFG
on the last day of the previous billing period as determined by a party independent from the Firm
(including the client’s custodian or another third-party). Fee billing frequency and calculation method
may vary depending on the third-party manager(s) used in servicing your account(s). In no event shall we
charge $1,200 or more 6 months or more in advance of services rendered.

The Firm includes cash in a clients account in determining the valuation for billing purposes. The Firm may,
in its sole discretion, not include cash in determining the fee, especially where a client has a high
percentage of cash for reasons other than the Firm's investment management decision.

If assets are deposited into or withdrawn from an account after the inception of a billing period, the fee
payable with respect to such assets is not adjusted to reflect the interim change in portfolio value. For the
initial period of an engagement, the fee is calculated on a pro rata basis. In the event the advisory
agreement is terminated, the fee for the final billing period is prorated through the effective date of the
termination and the outstanding or unearned portion of the fee is charged or refunded to the client, as
appropriate.

Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g.,
held-away assets, accommodation accounts, alternative investments, etc.), VFG can negotiate a fee rate
that differs from the range set forth above. Clients are advised that a conflict of interest exists for the Firm
to recommend that clients engage VFG for additional services for compensation, including rolling over
retirement accounts or moving other assets to the Firm’s management. Clients retain absolute discretion
over all decisions regarding engaging the Firm and are under no obligation to act upon any of the
recommendations.

Third-Party Management Fees
If we engage a third-party independent manager to manage all or a portion of your assets, they receive
an annual Program Fee that is detailed in the disclosure material of the third-party manager. This fee is
included in our total investment management fee described above, and your combined fee for the third-
party manager and victory shall not exceed 2%. This means the Asset Management Fee received by Victory
Financial may be less than it would otherwise be without Third-Party Management Fees.

This fee structure creates an inherent conflict of interest, as Victory Financial Group is less incentivized to
recommend or place a client within these services if the fee that we receive is reduced by the
compensation received by third-parties for asset Management. However, our Code of Ethics requires our
Investment Adviser Representatives to do what is in the client’s best interests at all times. Kyle Wardlaw
monitors all transactions to ensure that we put the needs of our clients first, not the additional
compensation they may negotiate.

Victory                        ADV Part 2A             March 26                  Page 11 of 38
                                                                                  © 2025 Red Oak Compliance Solutions LLC

Held-Away Participant Management Fees
Clients for whom we manage held-away assets through our third-party platform shall be charged a higher
rate than they may otherwise be able to negotiate due to the platform fee paid to the third-party Platform
provider. This platform fee shall be up to 0.30%, and it shall be separate from, and in addition to, your
investment management or wealth management fee detailed above. This means a client at the maximum
rate specified above who is advised through the third-party platform shall pay a total asset management
fee of 1.80% for asset management.

Financial Planning and Consulting Fees
We provide comprehensive financial planning services for a negotiable fixed fee ranging between $500
and $50,000 per plan, based upon the nature and complexity of the client’s circumstances as well as the
services requested. The Financial Planning Agreement will show the fee you will pay. A deposit of 50% of
...