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ADV PART 2A

Bouchey Financial Group Ltd. (CRD 111824), brochure dated September 4, 2026. Text extracted from the firm's SEC Form ADV Part 2 brochure.

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Item 1 Cover Page Bouchey Financial Group, Ltd. SEC File Number: 801 – 51979 ADV Part 2A, Firm Brochure Dated: September 4, 2026 Contact: David W. Clarke, Chief Compliance Officer 1819 Fifth Avenue Troy, New York 12180-3302 www.bouchey.com This Brochure provides information about the qualifications and business practices Bouchey Financial Group, Ltd. (“Bouchey Financial”). If you have any questions about the contents of this Brochure, please contact us at (518) 720-3333 or dclarke@bouchey.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Bouchey Financial Group, Ltd. also is available on the SEC’s website at www.adviserinfo.sec.gov. References herein to Bouchey Financial Group, Ltd. as a “registered investment adviser” or any reference to being “registered” does not imply a certain level of skill or training. Material Changes Item 2 The following material changes have been made to this disclosure brochure since the last annual amendment filing on 3/27/2026. • The Advisor has amended its minimum relationship size to $1,000,000. Please see Item 7 for additional information. Item 3 Table of Contents Item 1 Cover Page .................................................................................................................................... 1 Item 2 Material Changes .......................................................................................................................... 2 Item 3 Table of Contents .......................................................................................................................... 2 Item 4 Advisory Business ........................................................................................................................ 3 Fees and Compensation ................................................................................................................ 6 Item 5 Performance-Based Fees and Side-by-Side Management ............................................................ 8 Item 6 Item 7 Types of Clients ............................................................................................................................ 8 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 8 Item 9 Disciplinary Information ............................................................................................................. 14 Item 10 Other Financial Industry Activities and Affiliations .................................................................. 14 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............. 14 Item 12 Brokerage Practices .................................................................................................................... 15 Item 13 Review of Accounts .................................................................................................................... 16 Item 14 Client Referrals and Other Compensation .................................................................................. 17 Item 15 Custody ....................................................................................................................................... 18 Investment Discretion ................................................................................................................. 18 Item 16 Item 17 Voting Client Securities .............................................................................................................. 18 Item 18 Financial Information .................................................................................................................. 19 2 Item 4 Advisory Business A. Bouchey Financial Group, LTD. (“Bouchey Financial” or the “Advisor”) is a Delaware corporation formed on August 30, 1995 and located in the State of New York. Bouchey Financial became a registered investment advisor in May 1996. Bouchey Financial is majority owned by Steven B. Bouchey (President). Bouchey Financial’s Chief Compliance Officer, David W. Clarke, remains available to address any questions that a client or prospective client may have regarding any aspect of this ADV Part 2A, Firm Brochure. B. As discussed below, Bouchey Financial offers to its clients (individuals, high net worth individuals, pension and profit-sharing plans, business entities, trusts, estates and charitable organizations) investment advisory services, and, to the extent specifically requested by a client, financial planning and related consulting services. Bouchey Financial serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate conflicts of interest. Bouchey Financial’s fiduciary commitment is further described in the Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. WEALTH MANAGEMENT SERVICES Bouchey Financial may provide Clients with wealth management services, which generally includes a broad range of comprehensive financial planning and consulting services as well as discretionary management of investment portfolios. Financial planning and consulting may also be offered as a stand-alone service. Investment Management Services – Bouchey Financial provides customized investment advisory solutions for its Clients either as a component of wealth management or on a stand-alone basis. This is achieved through continuous personal Client contact and interaction while providing discretionary and/or non-discretionary investment management and related advisory services. Bouchey Financial works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation. Bouchey Financial primarily allocates Client assets among various mutual funds, individual equity securities, fixed income securities and exchange traded funds, and unaffiliated investment managers or investment platforms (collectively “Independent Managers”) in accordance with their stated investment objectives. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Bouchey Financial’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Bouchey Financial will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place 3 reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Bouchey Financial evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Bouchey Financial may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Bouchey Financial may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Bouchey Financial accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the terms of the advisory agreement, please see Item 12 – Brokerage Practices. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor 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. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee- based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Use of Independent Managers – In certain instances, Bouchey Financial will recommend that Clients utilize one or more Independent Managers for all or a portfolio of a Client’s investment portfolio. Bouchey Financial may also assist in the development of the initial policy recommendations and managing the ongoing Client relationship. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Client investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client will be provided with the Independent Manager's Form ADV 2A (or a brochure that makes the appropriate disclosures). Financial Planning and Consulting – Bouchey Financial will typically provide a variety of financial planning services to individuals and families as a component of wealth management services. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not 4 limited to business planning, investment planning, retirement planning, insurance planning, personal savings, education savings, cash flow forecasting, large purchase planning, charitable giving, tax planning, trust/estate planning and other areas of a Client’s financial situation. A financial plan developed for the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Bouchey Financial may also refer Clients to an accountant, attorney or other specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. RETIREMENT PLAN ADVISORY SERVICES Bouchey Financial provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: • Vendor Analysis Investment Management (ERISA 3(21) and ERISA 3(38)) • • Performance Reporting • Benchmarking Services These services are provided by Bouchey Financial serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Bouchey Financial’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. to providing investment advisory services, an C. Bouchey Financial shall provide investment advisory services specific to the needs of each investment adviser client. Prior representative will ascertain each client’s investment objective(s). Thereafter, Bouchey Financial shall allocate and/or recommend that the client allocate investment assets 5 consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on Bouchey Financial’s services. D. Bouchey Financial does not participate in a wrap fee program. E. As of December 31, 2025, Bouchey Financial manages $1,606,520,371 in client assets, $1,573,838,174 of which are managed on a discretionary basis and $32,682,197 on a non- discretionary basis. Item 5 Fees and Compensation A. WEALTH MANAGEMENT AND INVESTMENT MANAGEMENT SERVICES Wealth management or investment management fees (herein “investment advisory fees”) are paid quarterly, at the end of each quarter, pursuant to the terms of the agreement. Investment advisory fees are based on the market value of assets under management at the end of the prior calendar quarter. Investment advisory fees range up to 1.00% annually based on several factors, including: the complexity of the services to be provided, the level of assets to be managed, and the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions and other complexities may be charged a higher fee. The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Bouchey Financial will be independently valued by the Custodian. Bouchey Financial will conduct periodic reviews of the Custodian’s valuations to ensure accurate billing. The Advisor’s fee is exclusive of, and in addition to, brokerage fees, transaction fees, and other related costs and expenses, which may be incurred by the client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Use of Independent Managers - As noted in Item 4, the Advisor will implement all or a portion of a client’s investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager. The Advisor will only earn its investment advisory fee as described above. Independent Managers typically do not offer any fee discounts but may have a breakpoint schedule which will reduce the fee with an increased level of assets placed under management with an Independent Manager. The terms of such fee arrangements are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the Independent Manager. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will not exceed 2.00% annually. RETIREMENT PLAN ADVISORY SERVICES Fees for retirement plan advisory services are charged an annual asset-based fee ranging from 0.25% to 1.00% and are billed on a quarterly basis, at the end of each quarter, pursuant to the terms of the retirement plan advisory agreement. Retirement plan advisor fees are based on the market value of assets under management at the end of the prior calendar 6 quarter. Fees may be negotiable depending on the size and complexity of the services to be provided to the Plan. B. WEALTH MANAGEMENT AND INVESTMENT MANAGEMENT SERVICES Investment advisory fees are calculated by the Advisor or its delegate and deducted from the client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the client’s account[s] at the respective quarter end date. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with Bouchey Financial at the end of each quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. It is the responsibility of the client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide written authorization permitting advisory fees to be deducted by Bouchey Financial to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. In limited instances, Bouchey Financial will bill client directly, to which payment is due upon receipt of the invoice. Use of Independent Managers - For client accounts implemented through an Independent Manager, the Advisor and the Independent Manager will each assume the responsibility for calculating and deducting their respective fees from the client’s account[s]. RETIREMENT PLAN ADVISORY SERVICES Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. C. Clients may incur certain fees or charges imposed by third parties, other than Bouchey Financial, in connection with investments made on behalf of the client’s account[s]. The client is responsible for all securities execution and custody fees charged by the Custodian, if applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in a client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The fees charged by Bouchey Financial are separate and distinct from these custody and execution fees. In addition, all fees paid to Bouchey Financial for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A client may be able to invest in these products directly, without the services of Bouchey Financial, but would not receive the services provided by Bouchey Financial which are designed, among other things, to assist the client in determining which products or services are most appropriate for each client’s financial situation and objectives. Accordingly, the client should review both the fees charged by the fund[s] and 7 the fees charged by Bouchey Financial to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. WEALTH MANAGEMENT AND INVESTMENT MANAGEMENT SERVICES Bouchey Financial is compensated for its services at the end of the quarter after investment advisory services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the client. After the five-day period, the client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the client. The client’s investment advisory agreement with the Advisor is non-transferable without the client’s prior consent. Use of Independent Managers - In the event that a client should wish to terminate their relationship with the Independent Manager, the terms for the termination will be set forth in the respective agreements between the client and that Independent Manager. Bouchey Financial will assist the client with the termination and transition as appropriate. RETIREMENT PLAN ADVISORY SERVICES Bouchey Financial is compensated for its services at the end of the quarter after retirement plan advisory services are rendered. Either party may terminate the retirement plan advisory agreement, at any time, by providing advance written notice to the other party. Upon termination, the Plan shall be responsible for retirement plan advisory fees up to and including the effective date of termination. The Plan’s retirement plan advisory agreement with the Advisor is non-transferable without the client’s prior consent. E. Neither Bouchey Financial, nor its representatives, accepts compensation from the sale of securities or other investment products. Item 6 Performance-Based Fees and Side-by-Side Management Neither Bouchey Financial, nor any supervised person of Bouchey Financial, accepts performance-based fees. Item 7 Types of Clients Bouchey Financial’s clients shall generally include individuals, high net worth individuals, pension and profit-sharing plans, business entities, trusts, estates and charitable organizations. The amount of each type of client is available on Bouchey Financial’s Form ADV Part 1A. These amounts may change over time and are updated at least annually by Bouchey Financial. Bouchey Financial generally requires a minimum relationship size of $1,000,000 which may be waived at the sole discretion of the Advisor. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss A. Bouchey Financial may utilize the following methods of security analysis: 8 • Fundamental - (analysis performed on historical and present data, with the goal of making financial forecasts) • Technical – (analysis performed on historical and present data, focusing on price and trade volume, to forecast the direction of prices) Bouchey Financial may utilize, or otherwise assist clients in implementing, the following investment strategies: • Long Term Purchases (securities held at least a year) • Short Term Purchases (securities sold within a year) • Trading (securities sold within thirty (30) days) • Short Sales (contracted sale of borrowed securities with an obligation to make the lender whole) • Margin Transactions (use of borrowed assets to purchase financial instruments) • Private Equity Subscriptions (legal commitment by an investor to contribute capital to a private equity fund) Please Note: Investment Risk. Investing in securities involves risk of loss that clients should be prepared to bear. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Bouchey Financial) will be profitable or equal any specific performance level(s). ETF Characteristics Investors buying or selling Exchange-Traded Fund (ETF) shares on the secondary market may incur customary brokerage commissions. Market prices may differ to some degree from the net asset value of the shares. Investors who sell fund shares may receive less than the share's net asset value. Shares may be sold throughout the day on the exchange through any brokerage account. However, unlike mutual funds, shares may only be redeemed directly from the fund by authorized participants, in very large creation/redemption units. If the fund's authorized participants are unable to proceed with creation/redemption orders and no other authorized participant is able to step forward to create or redeem, fund shares may trade at a discount to the fund's net asset value and possibly face delisting. Risk Considerations The ETF’s shares will change in value, and you could lose money by investing in the fund. One of the principal risks of investing in the fund is market risk. Market risk is the risk that a particular stock owned by the fund, fund shares or stocks in general may fall in value. There can be no assurance that the fund's investment objective will be achieved. ETF’s may invest in securities issued by companies concentrated in a particular industry. ETF’s may invest in small capitalization and mid-capitalization companies. Such companies may experience greater price volatility than larger, more established companies. An investment in a fund containing securities of non-U.S. issuers is subject to additional risks, including currency fluctuations, political risks, withholding, the lack of adequate financial information, and exchange control restrictions impacting non-U.S. issuers. The fund may invest in depositary receipts which may be less liquid than the underlying shares in their primary trading market. 9 Certain ETFs may be classified as “non-diversified” and may invest a relatively high percentage of its assets in a limited number of issuers. As a result, the fund may be more susceptible to a single adverse economic or regulatory occurrence affecting one or more of these issuers, experience increased volatility and be highly concentrated in certain issuers. B. Bouchey Financial’s methods of analysis and investment strategies do not present any significant or unusual risks. However, every method of analysis has its own inherent risks. To perform an accurate market analysis Bouchey Financial must have access to current/new market information. Bouchey Financial has no control over the dissemination rate of market information; therefore, unbeknownst to Bouchey Financial, certain analyses may be compiled with outdated market information, severely limiting the value of Bouchey Financial’s analysis. Furthermore, an accurate market analysis can only produce a forecast of the direction of market values. There can be no assurances that a forecasted change in market value will materialize into actionable and/or profitable investment opportunities. Bouchey Financial’s primary investment strategies - Long Term Purchases, Short Term Purchases, and Trading - are fundamental investment strategies. However, every investment strategy has its own inherent risks and limitations. For example, longer term investment strategies require a longer investment time period to allow for the strategy to potentially develop. Shorter term investment strategies require a shorter investment time period to potentially develop but, as a result of more frequent trading, may incur higher transactional costs when compared to a longer-term investment strategy. Trading, an investment strategy that requires the purchase and sale of securities within a thirty (30) day investment time period, involves a very short investment time period but will incur higher transaction costs when compared to a short-term investment strategy and substantially higher transaction costs than a longer-term investment strategy. In addition to the fundamental investment strategies discussed above, Bouchey Financial may also, at the direction of the client, implement short selling, use of margin, and/or options transactions. Each of these strategies has a high level of inherent risk. (See discussion below) and, as a result, Bouchey Financial will open implement these strategies at the direction of the client. Short Selling. Bouchey Financial does not recommend the use of short selling. Short selling, involves the selling of assets that the investor does not own. The investor borrows the assets from a third-party lender (i.e., Broker-Dealer) with the obligation of buying identical assets at a later date to return to the third party lender. Individuals who engage in this activity shall only profit from a decline in the price of the assets between the original date of sale and the date of repurchase. Conversely, the short seller will incur a loss if the price of the assets rises. Other costs of shorting may include a fee for borrowing the assets and payment of any dividends paid on the borrowed assets. Access to Margin. Bouchey Financial does not recommend the use of margin. A margin transaction occurs when an investor uses borrowed assets to purchase financial instruments and/or to access liquidity. The investor generally obtains the borrowed assets by using other securities as collateral for the borrowed sum. The effect of purchasing a security using margin is to magnify any gains or losses sustained by the purchase of the financial instruments on margin. Although clients may retain the ability to use margin, Bouchey 10 Financial does not use margin for investment purposes and does not recommend its use by clients. The use of margin by a client will not impact a client’s fees. Risks Specific to the Program. ETFs in which the Program may invest involve certain inherent risks generally associated with investments in a portfolio of securities, including the risk that the general level of security prices may decline, thereby adversely affecting the value of each unit of the ETF. Moreover, an ETF may not fully replicate the performance of its benchmark index because of the temporary unavailability of certain index securities in the secondary market or discrepancies between the ETF and the index with respect to the weighting of securities or the number of securities held. ETFs in which the strategies invest have their own fees and expenses as set forth in the ETF prospectuses. ETFs may have exposure to derivative instruments, such as futures contracts, forward contracts, options, and swaps. There is a risk that a derivative may not perform as expected. The main risk with derivatives is that some types can amplify a gain or loss, potentially earning or losing substantially more money than the actual cost of the derivative, or that the counterparty may fail to honor its contract terms, causing a loss for the ETF. Use of these instruments may also involve certain costs and risks such as liquidity risk, interest rate risk, market risk, credit risk, management risk, and the risk that an ETF could not close out a position when it would be most advantageous to do so. Some ETFs available, including Schwab ETFs™, are less than 10 years old. Accordingly, there is limited data available to use when assessing the investment risk of some of these ETFs. As a result, one or more of the following may occur: (i) poor liquidity in or limited availability of the ETFs, or (ii) lack of market depth causing the ETFs to trade at excessive premiums or discounts C. Currently, Bouchey Financial primarily allocates client investment assets among mutual funds, individual equity securities, fixed income securities, ETFs, and Independent Manager(s) on a discretionary and/or non-discretionary basis in accordance with the client’s designated investment objective(s). (See Independent Managers disclosure at Item 4.B. above). Risks associated with these asset types include: 1. Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. 2. Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk may be caused by external factors independent of the fund’s specific investments as well as due to the fund’s specific investments. Additionally, each security’s price will fluctuate based on market movement and emotion, which may, or may not be due to the security’s operations or changes in its true value. For example, political, economic and social conditions may trigger market events which are temporarily negative, or temporarily positive. 3. Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. 4. Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. 11 5. Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. 6. Market Risk (Systematic Risk): Even a long-term investment approach cannot guarantee a profit. Economic, political, and issuer-specific events will cause the value of securities to rise or fall. Because the value of your portfolio will fluctuate, there is a risk that you will lose money. 7. Unsystematic Risk: Unsystematic risk is the company-specific or industry-specific risk in a portfolio. The combination of systematic (market risk) and unsystematic risk is defined as the portfolio risk that the investor bears. While the investor can do little to reduce systematic risk, he or she can affect unsystematic risk. Unsystematic risk may be significantly reduced through diversification. However, even a portfolio of well- diversified assets cannot escape all risk. 8. Credit Risk: Credit risk is the risk that the issuer of a security may be unable to make interest payments and/or repay principal when due. A downgrade to an issuer’s credit rating or a perceived change in an issuer’s financial strength may affect a security’s value, and thus, impact performance. Credit risk is greater for fixed income securities with ratings below investment grade (BB or below by Standard & Poor’s Rating Group or Ba or below by Moody’s Investors Service, Inc.). Fixed income securities that are below investment grade involve higher credit risk and are considered speculative. 9. Call Risk: Call risk is the risk that during periods of falling interest rates, a bond issuer will call or repay a higher-yielding bond before its maturity date, forcing the investment to reinvest in bonds with lower interest rates than the original obligations. 10. Income Risk: Income risk is the risk that falling interest rates will cause the investment’s income to decline. 11. Purchasing Power Risk: Purchasing power risk is the risk that your investment’s value will decline as the price of goods rises (inflation). The investment’s value itself does not decline, but its relative value does, which is the same thing. Inflation can happen for a variety of complex reasons, including a growing economy and a rising money supply. Rising inflation means that if you have $1,000 and inflation rises 5 percent in a year, your $1,000 has lost 5 percent of its value, as it cannot buy what it could buy a year previous. 12. Political Risks: Most investments have a global component, even domestic stocks. Political events anywhere in the world may have unforeseen consequences to markets around the world. 13. Regulatory Risk: Changes in laws and regulations from any government can change the market value of companies subject to such regulations. Certain industries are more susceptible to government regulation. Changes in zoning, tax structure or laws impact the return on these investments. 12 14. Risks Related to Investment Term: Securities do not follow a straight line up in value. All securities will have periods of time when the current price of the security is not what we believe it is truly worth. If you require us to liquidate your portfolio during one of these periods, you will not realize as much value as you would have had the investment had the opportunity to regain its value. An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as ETFs and mutual funds are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. As such, a mutual fund or ETF client or investor may incur substantial tax liabilities even when the fund underperforms. Shares of mutual funds are distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per-share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes in the market value of the fund’s holdings. The trading prices of a mutual fund’s shares can differ significantly from the NAV during periods of market volatility, which may, among other factors, lead to the mutual fund’s shares trading at a premium or discount to NAV. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for indexed-based ETFs and more frequently for actively managed ETFs. However, certain inefficiencies can cause the shares to trade at a premium or discount to their pro-rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. While clients and investors may be able to sell their ETF shares on an exchange, ETFs generally only redeems shares directly from shareholders when aggregated as creation units (usually 50,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. Alternative Investment Vehicles. The Advisor may periodically allocate a portion of a Client’s portfolio to alternative investments at its discretion, considering the Client’s objectives and risk tolerance. These investments are influenced by the performance of their respective Managers, whose strategies and decisions impact returns. If a Manager’s approach falls out of favor or investment decisions are poor, losses may occur. If several Managers underperform simultaneously, a Client’s account may experience significant declines. Cryptocurrency ETF Risks. Cryptocurrency ETFs are investment vehicles designed to provide exposure to the price movements of cryptocurrencies or cryptocurrency-related assets through exchange-listed securities. Cryptocurrencies and cryptocurrency-related markets are highly volatile. Prices may fluctuate dramatically over short periods of time due to factors including, but not limited to, market sentiment, technological developments, macroeconomic events, regulatory actions, and changes in liquidity. As a result, Cryptocurrency ETFs may experience rapid and substantial losses. A Cryptocurrency ETF’s performance may differ materially from the crypto market exposure it seeks to 13 provide due to fees and expenses, portfolio construction and rebalancing, and the use of derivatives, and during periods of market stress liquidity may decline, bid-ask spreads may widen, shares may trade above or below the value of underlying holdings, and trading may be halted or limited, which may prevent buying or selling at desired times or prices. Item 9 Disciplinary Information Bouchey Financial has not been the subject of any disciplinary actions. Item 10 Other Financial Industry Activities and Affiliations Licensed Insurance Agency. Bouchey Financial is affiliated through common control and ownership with Bouchey, Millet, and Schafer, LLC, a corporation licensed with the New York State Department of Insurance. Bouchey Financial’s representatives will not recommend that clients of Bouchey Financial purchase insurance products through Bouchey, Millet, and Schafer, LLC. Tax Services Bouchey Financial is also affiliated through common control and ownership with B, M & Co. Tax Service, LLC. Bouchey Financial’s representatives recommend that certain Clients of Bouchey Financial engage in tax preparation and accounting services through B, M & Co. Tax Service, LLC. The recommendation that a client utilize the services of one the Affiliated Entities presents a conflict of interest, as the additional compensation may provide an incentive to recommend certain investment products, rather than on a particular client’s need. No client is under any obligation to purchase any investment products from the Affiliated Entities. Clients are reminded that they may engage in tax preparation and accounting services recommended by Bouchey Financial through other, non-affiliated tax agencies. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Bouchey Financial maintains an investment policy relative to personal securities transactions. This investment policy is part of Bouchey Financial’s overall Code of Ethics, which serves to establish a standard of business conduct for all of Bouchey Financial’s representatives that is based upon fundamental principles of openness, integrity, honesty and trust, a copy of which is available upon request. In accordance with Section 204A of the Investment Advisers Act of 1940, Bouchey Financial also maintains and enforces written policies reasonably designed to prevent the misuse of material non-public information by Bouchey Financial or any person associated with Bouchey Financial. B. Neither Bouchey Financial nor any related person of Bouchey Financial recommends, buys, or sells for client accounts, securities in which Bouchey Financial or any related person of Bouchey Financial has a material financial interest. 14 C. Bouchey Financial and/or representatives of Bouchey Financial may buy or sell securities that are also recommended to clients. This practice may create a situation where Bouchey Financial and/or representatives of Bouchey Financial are in a position to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a potential conflict of interest. Practices such as “scalping” (i.e., a practice whereby the owner of shares of a security recommends that security for investment and then immediately sells it at a profit upon the rise in the market price which follows the recommendation) could take place if Bouchey Financial did not have adequate policies in place to detect such activities. In addition, this requirement can help detect insider trading, “front-running” (i.e., personal trades executed prior to those of Bouchey Financial’s clients) and other potentially abusive practices. Bouchey Financial has a personal securities transaction policy in place to monitor the personal securities transactions and securities holdings of each of Bouchey Financial’s “Access Persons”. Bouchey Financial’s securities transaction policy requires that an Access Person of Bouchey Financial must provide the Chief Compliance Officer or his/her designee with a written report of their current securities holdings within ten (10) days after becoming an Access Person. Additionally, each Access Person must provide the Chief Compliance Officer or his/her designee with a written report of the Access Person’s current securities holdings at least once each twelve (12) month period thereafter on a date Bouchey Financial selects. D. Bouchey Financial and/or representatives of Bouchey Financial may buy or sell securities, at or around the same time as those securities are recommended to clients. This practice creates a situation where Bouchey Financial and/or representatives of Bouchey Financial are in a position to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a potential conflict of interest. As indicated above in Item 11.C, Bouchey Financial has a personal securities transaction policy in place to monitor the personal securities transaction and securities holdings of each of Bouchey Financial’s Access Persons. Item 12 Brokerage Practices A. Bouchey Financial does not have discretionary authority to select the broker- dealer/custodian for custody and execution services. The client will engage the broker- dealer/custodian (herein the "Custodian") to safeguard client assets and authorize Bouchey Financial to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, Bouchey Financial does not have the discretionary authority to negotiate commissions on behalf of clients on a trade-by-trade basis. Where Bouchey Financial does not exercise discretion over the selection of the Custodian, it may recommend the Custodian[s] to clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by Bouchey Financial. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Bouchey Financial may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the client, services made available to the client, its reputation and/or the location of the Custodian’s offices. 15 Bouchey Financial will generally recommend that clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC. Schwab and Fidelity will serve as the client’s “qualified custodian”. Bouchey Financial maintains an institutional relationship with Schwab, whereby the Advisor receives economic benefits from Schwab. Please see Item 14 below. The following are additional details regarding the brokerage practices of the Advisor: Soft Dollars – Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker- dealer/custodian in exchange for research and other services. Bouchey Financial does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, the Advisor does receive certain economic benefits from Schwab. Please see Item 14. Brokerage Referrals – Bouchey Financial does not receive any compensation from any third party in connection with the recommendation for establishing an account. Directed Brokerage – All clients are serviced on a “directed brokerage basis”, where Bouchey Financial will place trades within the established account[s] at the Custodian designated by the client. Further, all client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other client accounts (i.e., purchase of a security into one client account from another client’s account[s]). Bouchey Financial will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. A. To the extent that Bouchey Financial provides investment management services to its clients, the transactions for each client account may be affected independently, unless Bouchey Financial decides to purchase or sell the same securities for several clients at approximately the same time. Bouchey Financial may combine or “bunch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among Bouchey Financial’s clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among clients in proportion to the purchase and sale orders placed for each client account on any given day. Bouchey Financial shall not receive any additional compensation or remuneration as a result of such aggregation. Item 13 Review of Accounts A. For those clients to whom Bouchey Financial provides investment supervisory services, account reviews are conducted on an ongoing basis by Bouchey Financial's Principals and/or representatives. All investment supervisory clients are advised that it remains their responsibility to advise Bouchey Financial of any changes in their investment objectives and/or financial situation. All clients (in person or via telephone) are encouraged to review financial planning issues (to the extent applicable), investment objectives and account performance with Bouchey Financial on an annual basis. 16 B. Bouchey Financial may conduct account reviews on an other-than-periodic basis upon the occurrence of a triggering event, such as a change in client investment objectives and/or financial situation, market corrections and client request. C. Clients are provided, at least quarterly, with written transaction confirmation notices and regular written summary account statements directly from the broker-dealer/custodian and/or program sponsor for the client accounts. Bouchey Financial may also provide a written periodic report summarizing account activity and performance. Item 14 Client Referrals and Other Compensation A. Bouchey Financial may refer clients to various third parties to provide certain financial services necessary to meet the goals of its clients. Likewise, Bouchey Financial may receive non-compensated referrals of new clients from a third party. Participation in Institutional Advisor Platform Bouchey Financial has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Bouchey Financial. As a registered investment advisor participating on the Schwab Advisor Services platform, Bouchey Financial receives access to software and related support without cost because the Advisor renders investment management services to clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit clients. In fulfilling its duties to its clients, the Advisor endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for client accounts, the ability to deduct advisory fees, trading tools, and back-office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its clients, but may not directly benefit all clients. Services that May Only Benefit the Advisor – Schwab also offers other services to Bouchey Financial that may not benefit the client, including: educational conferences and events, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a conflict of interest. Bouchey Financial believes, however, that the selection of Schwab as Custodian is in the best interests of its clients. 17 B. Bouchey Financial does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 Custody Bouchey Financial shall have the ability to have its advisory fee for each client debited by the custodian on a quarterly basis. Clients are provided, at least quarterly, with written transaction confirmation notices and regular written summary account statements directly from the broker-dealer/custodian and/or program sponsor for the client accounts. Bouchey Financial may also provide a written periodic report summarizing account activity and performance. Please Note: To the extent that Bouchey Financial provides clients with periodic account statements or reports, the client is urged to compare any statement or report provided by Bouchey Financial with the account statements received from the account custodian. Please Also Note: The account custodian does not verify the accuracy of Bouchey Financial’s advisory fee calculation. In addition, certain clients have established asset transfer authorizations which permit the qualified custodian to rely upon instructions from Bouchey Financial to transfer client funds or securities to third parties. These arrangements are also disclosed at ADV Part 1, Item 9, but in accordance with the guidance provided in the SEC’s February 21, 2017 Investment Adviser Association No-Action Letter, the affected accounts are not subject to an annual surprise CPA examination. Item 16 Investment Discretion The client can determine to engage Bouchey Financial to provide investment advisory services on a discretionary basis. Prior to Bouchey Financial assuming discretionary authority over a client’s account, the client shall be required to execute an Investment Advisory Agreement, naming Bouchey Financial as the client’s attorney and agent in fact, granting Bouchey Financial full authority to buy, sell, or otherwise effect investment transactions involving the assets in the client’s name found in the discretionary account. Clients who engage Bouchey Financial on a discretionary basis may, at any time, impose restrictions, in writing, on Bouchey Financial’s discretionary authority (i.e. limit the types/amounts of particular securities purchased for their account, exclude the ability to purchase securities with an inverse relationship to the market, limit or proscribe Bouchey Financial’s use of margin, etc.). Item 17 Voting Client Securities A. Bouchey Financial does not vote client proxies. Clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. 18 B. Clients will receive their proxies or other solicitations directly from their custodian. Clients may contact Bouchey Financial to discuss any questions they may have with a particular solicitation. Item 18 Financial Information A. Bouchey Financial does not solicit fees of more than $1,200, per client, six months or more in advance. B. Bouchey Financial is unaware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments relating to its discretionary authority over certain client accounts. C. Bouchey Financial has not been the subject of a bankruptcy petition. 19