Camden Financial Management, Inc.

Firm Brochure (Part 2A & 2B of Form ADV) Camden Financial Management, Inc. 710 Burney Mountain Road Fletcher, NC 28732 Phone (480) 998-7786 Fax (480) 452-1943 This brochure provides information about the qualifications and business practices of Camden Financial Management, Inc. If you have any questions about the contents of this brochure, please contact us at: (480) 998-7786. 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 Camden Financial Management, Inc. is available on the SEC’s website at www.adviserinfo.sec.gov March 11, 2026 Camden Financial Management, Inc.  Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. Material Changes since the Last Update None Full Brochure Available Whenever you would like to receive a complete copy of our Firm Brochure, please contact us by telephone at: (480) 998-7786. i Camden Financial Management, Inc.  Table of Contents Material Changes............................................................................................................ i Annual Update ............................................................................................................ i Material Changes since the Last Update .................................................................... i Full Brochure Available ............................................................................................... i Advisory Business ........................................................................................................ 1 Firm Description ......................................................................................................... 1 Principal Owners ........................................................................................................ 2 Types of Advisory Services ........................................................................................ 2 Tailored Relationships ............................................................................................... 3 Types of Agreements ................................................................................................. 3 Investment Advisory Agreement ................................................................................ 3 Termination of Agreement ......................................................................................... 5 Fees and Compensation ............................................................................................... 5 Description ................................................................................................................. 5 Fee Billing .................................................................................................................. 5 Other Fees ................................................................................................................. 6 Expense Ratios .......................................................................................................... 6 Past Due Accounts and Termination of Agreement ................................................... 7 Performance-Based Fees ............................................................................................. 7 Sharing of Capital Gains ............................................................................................ 7 Types of Clients............................................................................................................. 7 Description ................................................................................................................. 7 Account Minimums ..................................................................................................... 7 Methods of Analysis, Investment Strategies and Risk of Loss ................................. 8 Methods of Analysis ................................................................................................... 8 Investment Strategies ................................................................................................ 8 Risk of Loss ............................................................................................................... 8 Disciplinary Information ............................................................................................... 9 Legal and Disciplinary ................................................................................................ 9 Other Financial Industry Activities and Affiliations ................................................... 9 Financial Industry Activities ........................................................................................ 9 TOC 1 Camden Financial Management, Inc.  Affiliations ................................................................................................................ 10 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................................................................................................................... 10 Code of Ethics.......................................................................................................... 10 Participation or Interest in Client Transactions ......................................................... 10 Personal Trading...................................................................................................... 10 Brokerage Practices .................................................................................................... 10 Selecting Brokerage Firms ....................................................................................... 10 Best Execution ......................................................................................................... 10 Soft Dollars .............................................................................................................. 11 Order Aggregation ................................................................................................... 12 Cross Trades ........................................................................................................... 12 Review of Accounts .................................................................................................... 12 Periodic Reviews ..................................................................................................... 12 Review Triggers ....................................................................................................... 12 Regular Reports ....................................................................................................... 13 Client Referrals ............................................................................................................ 13 Incoming Referrals ................................................................................................... 13 Referrals Out ........................................................................................................... 13 Custody ........................................................................................................................ 13 Account Statements ................................................................................................. 13 Performance Reports ............................................................................................... 13 Investment Discretion ................................................................................................. 14 Discretionary Authority for Trading ........................................................................... 14 Limited Power of Attorney ........................................................................................ 14 Voting Client Securities .............................................................................................. 14 Proxy Votes ............................................................................................................. 14 Financial Information .................................................................................................. 14 Financial Condition .................................................................................................. 14 Business Continuity Plan ........................................................................................... 15 General .................................................................................................................... 15 Alternate Offices ...................................................................................................... 15 Loss of Key Personnel ............................................................................................. 15 TOC 2 Camden Financial Management, Inc.  Privacy Notice .......................................................................................................... 15 Brochure Supplement (Part 2B of Form ADV) .......................................................... 17 Education and Business Standards ......................................................................... 17 Professional Certifications ....................................................................................... 17 Employee Education and Business Background ..................................................... 17 Richard Randall (“Randy”) Oldenburg ...................................................................... 17 TOC 3 Camden Financial Management, Inc.  Advisory Business Firm Description Camden Financial Management, Inc. (“Camden”) was founded in 1996. Camden provides customized Investment Advisory and Financial Planning Services. These services are provided to individuals, families, retirement plans, trusts and estates. Investment advice is personalized through conversations with Clients and may include the evaluation of the Client’s: financial objectives, risk parameters, financial structure, cash management and life experiences. Camden strongly believes that building customized portfolios is not an exact science since a Client’s tolerance for stock market risk is not always a static measurement. It has been Camden’s experience that Clients are willing to take on greater risk/uncertainty during up markets and exhibit less of a willingness to take on risk/uncertainty during down markets. Thus, Camden knows it may take a few market cycles to “fine tune” and arrive at a portfolio structure that ultimately meets the Client’s desires. Within our Investment Advisory Service, Camden spends about 50% of our time helping clients with non-investment-oriented issues. Camden refers to these non- investment services as Financial Planning Services. Financial Planning Services are very broad in nature and are Client specific, but may include tax planning, risk management/insurance planning, education funding, retirement planning, and estate planning. These non-investment-oriented services are different for every client and are typically instigated by some situation in the client’s financial life. Camden is strictly a fee-only investment management and financial planning firm. The firm does not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products. The firm is not affiliated with entities that sell financial products or securities. No commissions or finder’s fees are accepted in any format. Camden does not act as a custodian of Client assets. Assets always remain in the name of the Client and Camden does not accept title or vesting of any assets within the firm’s name. All assets are held at large, “well known” custodians. Camden implements the recommended investment strategy via a limited power of attorney provided to the firm by the Client. The nature of this limited power of attorney is discussed in greater detail in the following pages. After Camden has spent time understanding the Client’s financial situation and desires, a “Recommendation Letter” is drafted to propose the specific investment allocation to be utilized. The Client has the full authority to accept or reject the recommendations in this Recommendation Letter. Once the investment allocation is approved by the Client, Camden will proceed in implementing the allocation over the time period noted in the Recommendation Letter. Periodic updates are provided to Clients as to the recommended current course of action. Camden believes that two-way communication is imperative to achieve a successful outcome. Camden utilizes emails, phone conversations and face to face meetings as modes of communication. Camden fully relies on Clients to update - 1 - Camden Financial Management, Inc.  them immediately of any changes in their financial or personal lives. It is also crucial that the Client maintain contact with Camden via one of the above modes of communication. The Recommendation Letter is utilized for the noted implementation period. Beyond the implementation of the Recommendation Letter, Camden will make rebalancing and investment changes without notice to the Client. It is imperative that the Client has other professional relationships (e.g., lawyer, accountant, insurance agents, etc.) that are engaged directly by the Client on an as- needed basis. It is the Client’s responsibility to make sure these other professionals are being proactive and contacting the Client if any changes need to be made within their area of specialty. All of these professionals provide unique and distinct services beyond the services that are provided by Camden, thus the importance of these other relationships. Camden will discuss legal, tax and insurance topics with the client, but it is the Client’s responsibility to take the next step in contacting their particular professional to implement any desired changes within these specific areas. We are pleased to discuss options before the Client contacts their other professionals, but the Client needs to take the initiative and assume responsibility in making contact. One of the main reasons that Camden prepares an annual Net Worth Statement for Clients is for this document to be utilized to better inform these “other professionals” as to the Client’s current financial position. It is the policy of Camden to eliminate conflicts of interest wherever possible. It may not be possible to eliminate conflicts of interest in every situation. Camden will disclose any known conflicts of interest in writing. The initial meeting(s), which may be by telephone and/or in person, is/are free of charge and is/are considered an exploratory interview to determine the needed scope of services and to determine if there will likely be a mutual benefit to both the Client and Camden. Principal Owners Randy Oldenburg is the 100% stockholder. Types of Advisory Services The only advisory service Camden provides is the above-mentioned Investment Advisory Service. On a regular basis, Camden furnishes advice to Clients on matters not involving securities. We refer to these other services as Financial Planning Services. These other services are very broad in scope and are typically driven by specific Client requests or needs, but they may include retirement planning, tax planning, risk management/insurance planning and estate planning. It is Camden’s belief that one of the differentiating elements of our firm is the time we spend with Clients on these non-investment advisory issues. As of December 31, 2025, Camden manages approximately $157,004,577 in assets for approximately 41 clients. Approximately $157,004,577 is managed on a discretionary basis, and $0 is managed on a non-discretionary basis. - 2 - Camden Financial Management, Inc.  Tailored Relationships Through our initial conversations with Clients, Camden tailors a customized investment allocation that is communicated to the Client in what we refer to as the “Recommendation Letter.” The presentation and conversation about this letter give the Client the forum to accept or decline the initial recommendations. Camden provides periodic updates to Clients on our beliefs in the macro economy. These updates allow for the Client to contact Camden and discuss any possible disagreements regarding our investment recommendations or broad global beliefs. Camden will fully rely on the Client to contact us with any significant “big picture” disagreements with our recommended investment theories. Agreements may not be assigned without Client consent. Types of Agreement Investment Advisory Agreement Clients elect to hire Camden under an Investment Advisory Agreement to provide Asset Management. Due to Camden’s high minimums, the firm naturally gravitates to Clients that are well on their way to being financially independent or have reached the point of not needing to continue to work. Most Clients hire Camden for the management of their assets, but over numerous years Clients come to understand the significant value in ongoing, broad non-investment-oriented services that are provided by Camden. Camden believes that the pursuit of these Financial Planning topics is crucial to obtaining financial success. Financial Planning has become synonymous with a formalized, 60-page document. We believe Financial Planning is the ongoing pursuit of issues that will more fully maximize clients’ Net Worth and improve one’s quality of life. The Investment Advisory Service provides the ongoing management of the Client’s investment portfolio and the continuous pursuit of financial planning issues that need to be integrated into the Client’s financial structure. If the Client wants an upfront comprehensive analysis of all financial planning issues, the Client must initially hire Camden under a Financial Planning Document Preparation Agreement. The Financial Planning Services under the Investment Advisory Agreement should in no way be construed as a comprehensive Financial Plan. We understand how Clients initially minimize these non-investment services addressed under our Investment Advisory Agreement, thus the following list of recent topics where we have helped Clients: Estate Planning Medicare and Supplemental Policies Asset Protection College Planning – 529 Plans Charitable Gifting Identity Theft Property Casualty/Umbrella Policies Reverse Mortgages Beneficiary Designations Credit Reports – FICO Scores Roth Conversions Client’s Health Long-Term Care Insurance Tax Update - 3 - Camden Financial Management, Inc.  As directly pertaining to Asset Management, the following services will be provided: • Risk Tolerance Determination • Portfolio design to pursue financial independence • Tailored Asset Allocation Plan with Specific Investment Recommendations • Implementation and Ongoing support o Account establishment and/or account transfer assistance o Quarterly appraisal and performance reports o Ongoing portfolio monitoring and management – we spend a significant amount of time researching how to best position your portfolio relative to the current economic environment o Constant access to the Advisor via phone, email or in person to evaluate life changes and family financial issues The following is a list of services that we provide annually that only partially relate to management of Client’s investments: 1) Tax Reporting including Realized Gain and Loss reports and detailed notes to the Client’s accountant to assist in completion of the Client’s tax return. Upon Client direction, Camden communicates directly with the Client’s accountant as to any tax reporting revisions by the custodian. 2) Required Minimum Distribution calculation and distribution plan. 3) Annual Net Worth Calculation to determine progress of the Client’s overall financial situation. Camden prepares Net Worth Statements during the second quarter of the year. Camden sends the Clients out a query for asset values at the beginning of the second quarter. The Client is encouraged to provide the Net Worth Statement to their estate planning attorney and insurance agent to ensure that these other professionals understand the Client’s current structure and current asset values to determine if changes need to be made to estate planning documents or insurance coverage. 4) Tax Loss Harvesting opportunities are pursued throughout the year. At times, there can be significant value to the Client in this service. 5) Year-end tax evaluation to determine if tax deferral or tax acceleration is beneficial for the Client. In an example of this analysis, Camden might determine if a Roth Conversion or additional income will benefit the Client in normalizing tax liabilities over numerous years. The scope of work and fee for an Investment Advisory Service relationship is provided to the Client in writing prior to the start of the relationship via a formalized contract. - 4 - Camden Financial Management, Inc.  The annual Investment Advisory Service Agreement fee is based on a percentage of the investable assets according to the following schedule: Portfolio Value Quarterly Rate Equivalent Annual Rate < or = $2,000,000 0.1875% 0.75%, plus >$2,000,000 0.125% 0.50% Current Clients under previous contracts may have a lower fee than the fee schedule above. Camden has a minimum annual fee of $20,000. Camden, in its sole discretion, may reduce the minimum fee and/or charge a lesser investment advisory fee based upon certain extenuating factors. Although the Investment Advisory Service Agreement is an ongoing agreement, the length of service to the Client is at the Client’s discretion. The Client or the Advisor may terminate an Agreement by written notice to the other party. At termination, fees will be billed on a pro rata basis for the portion of the quarter completed. The portfolio value at the completion of the prior full billing quarter is used as the basis for the fee computation. Termination of Agreement A Client may terminate any of the aforementioned agreements at any time by notifying Camden in writing and paying the pro-rata portion of the investment advisory expense for the given quarter. Camden may terminate any of the aforementioned agreements at any time by notifying the Client in writing. If the Client made an advance payment, Camden will refund any unearned portion of the advance payment. Fees and Compensation Description Camden bases its fees on a percentage of assets under management, the applicable minimum annual fee, or a negotiated flat fee with periodic adjustments for inflation. Financial Plans are priced according to the degree of complexity associated with the Client’s situation. Fees are not negotiable. Fee Billing Investment management fees are billed quarterly, in arrears, meaning that we invoice the Client after the three-month billing period has ended. Camden provides a copy of the Client’s invoice along with their quarterly investment statements. Camden utilizes the quarter end balance to determine the Client’s fee. It is clearly noted on the invoice that the Client must verify the fee calculation in that the custodian will not verify these figures. The Client authorizes Camden to directly debit this fee from the Client’s investment accounts, via the custodian account application. Fees are pulled from - 5 - Camden Financial Management, Inc.  multiple Client accounts each quarter. The fee deduction is rotated between the Client’s accounts if the Client has multiple accounts. Other Fees Custodians charge transaction fees on purchases or sales of certain mutual funds, exchange-traded funds or separate issue securities. These transaction charges are usually small and incidental to the underlying annual expense of the fund. The selection of the security is more important than the nominal fee the custodian charges to buy or sell the security. The current fees at Charles Schwab are $10 to $45 for a mutual fund and zero for stocks and ETFs (Exchange Traded Funds). Camden also utilizes third party bond brokers that transact bond and CD purchases and sales under the direction of the Advisor. These bond brokers are compensated by commissions and it is Camden’s responsibility to reduce these commissions wherever possible. These commissions for the purchase or sale of municipal bonds are significantly higher than the transactions to buy separate issue stocks or mutual funds. There is no ongoing mutual fund expense on these separate issue bonds or CDs, thus the benefit in paying a higher commission to purchase these securities. It is imperative to understand that Camden does not receive any of the above commissions nor does Camden receive any enticement to direct trades to these third- party brokers. Investments may also include: equities (stocks), preferred stock, corporate debt securities, certificates of deposit, municipal bonds, investment company securities (mutual funds and exchange traded funds) and U. S. government securities. Initial Public Offerings (IPOs) are not available through Camden. There are instances where extraordinary financial planning or non-investment-oriented services could arise under the Investment Advisory Agreement. It should be noted that these instances are rare, but have been becoming more frequent with the estate settlement work that we have been doing for heirs. Camden will discuss any additional fees with client before any fees accrue. The most common reason for these fees has been death or divorce of a Client. An hourly fee of $350 will be billed for these services. Expense Ratios Mutual funds and ETFs charge a management fee for their services as investment managers. These fees vary on the complexity of the management of the specific funds. As an example, a fund that has an expense of .2% would have an annual expense of $200 on a $100,000 investment. These fees are in addition to the fees paid by the Client to Camden. Performance figures quoted by mutual fund companies in various publications are after their fees have been deducted. Camden’s performance reports are net of all fees (Camden’s Fee, Mutual Fund Expenses and Custodian Transaction Fee). Equity Assets are invested primarily in no-load mutual funds and exchange-traded funds (ETFs) and Fixed Income Assets are mostly invested within separate issue bonds and CDs. Most of the mutual funds are deemed to be “Institutional Class” - 6 - Camden Financial Management, Inc.  funds due to their reduced annual expenses provided to Investment Advisors that have substantial holdings with the fund company. The underlying expense in a recommended fund is very important and a determining factor for the advisor in recommending the funds to the Client. Camden favors these lower expense investments where applicable for its Clients. These expenses are disclosed in the fund prospectus or can be viewed on the mutual fund’s website. Camden can also provide details on these fund fees on the initial “Recommendation Letter.” Past Due Accounts and Termination of Agreement Camden deducts fees from Investment Advisory accounts approximately three weeks following the end of the quarter. The Client authorizes the Advisor to deduct these fees at the onset of the relationship. The Client has approximately two weeks to review their bill before the deduction is implemented. With the above arrangement, Past Due Accounts are not applicable. Also, as previously noted, the Client or Advisor can terminate any agreement and a prorated portion of the fee will be charged to the Client. Performance-Based Fees Sharing of Capital Gains Fees are not based on a share of the capital gains or capital appreciation of managed securities. Camden does not utilize a performance-based fee structure because of the potential conflict of interest. Performance-based compensation may create an incentive for the Advisor to recommend an investment strategy that may carry a higher degree risk than desired by the Client. Types of Clients Description Camden generally provides investment advice to individuals, families, pension and profit-sharing plans, trusts and estates. Client relationships vary in length of service. Account Minimums Camden believes Clients need to have a minimum portfolio of approximately $3,000,000 to justify Camden’s $20,000 minimum annual fee. Camden has the discretion to temporarily reduce the account minimum. - 7 - Camden Financial Management, Inc.  Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Camden’s security analysis method predominately centers on fundamental analysis. Camden spends much of their investment analysis energy on understanding the macroeconomic environment. While many firms center their efforts on the micro economic environment (specific stocks), Camden believes that our time is much better utilized in understanding the “Big Picture.” The main source of information comes from analysts throughout the world. Much of this information is obtained via the internet. Secondarily, information is obtained from mutual fund company literature, financial newspapers and magazines, mutual fund rating services, research materials prepared by others and discussions with fellow financial advisors. Investment Strategies The primary investment strategy used on Client accounts is strategic asset allocation. Camden spends the majority of its research efforts attempting to understand the macroeconomic forces and implementing broad and diversified investments that will benefit from these long-term these forces. These possible benefits may be either in the form of upside performance or downside preservation of capital. As an example, in the year 2000 while many investors were attempting to figure out what internet stock (micro approach) to own, many macro-oriented advisors scoured the world landscape and came to the conclusion that broad emerging market exposure would benefit clients over the next ten years. Many investors were trying to decipher what stock to hold for the next ten days, while macro investors knew they could not time the market over days or months, but looked for value over an extended number of years. These macroeconomic beliefs are clearly communicated to Clients via our investment articles and it is clearly communicated which types of investments need to be pursued to capture these opportunities. Camden asks for input from the Client and it is up to the Client to provide any changes to their risk parameters or financial situation. Risk of Loss All investment programs have certain risks that are borne by the investor. Camden is humble enough to know that we cannot foresee all possible risks. We do understand though that there are known unknowns. Our investment process emphasizes asset preservation and the preservation of purchasing power in that most of our clients cannot replace their funds if they are permanently lost. Some of the risks that investors could weather are: • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to lose value. For example, when interest rates rise the value of the underlying bond can lose value. • Market Risk: The price of a security, bond, or mutual fund may drop in reaction to real and/or emotional events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying - 8 - Camden Financial Management, Inc.  circumstances. For example, political, economic and social conditions may trigger market events. • Inflation Risk/Loss of Purchasing Power: When inflation is present, a dollar next year will not buy as much as a dollar today because the purchasing power has been eroded. This devaluation can also occur in other world currencies as well. • U.S. Dollar Risk: Our home currency could become impaired due to excessive current and further additional Federal deficits. • Counterparty Risk: Financial institutions may not be able to honor their obligations in an extreme financial crisis, similar to what was experienced in 2008 and early 2009. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash at a reasonable price and with limited transaction costs. The vast majority of Camden’s assets are liquid, assuming that the markets stay open and do not seize. The issue on liquidity has been more of an issue of liquidity at a much lower price. During the downturn in 2008 and 2009, there was limited liquidity within the municipal bond market and if Client was forced to sell during a one- month window, Client would have received a significant discount in price. It is Camden’s goal to ensure that assets that could have compromised liquidity in a financial panic are in fact long-term holdings and would not need to be sold in these somewhat inopportune periods. We attempt to not be sellers in a compromised market. Some fixed income holdings that we purchase for clients are designed to be held to maturity in that the market for these bonds is not very deep. • Default Risk: Camden has increased the quality of bonds over the years and currently buys a lot of bonds with a U.S. government guarantee. The U.S. default would be the greater concern in today’s market, but it appears that the government would print themselves out of a default and the risk would appear in the form of inflation risk as the bonds were devalued from a purchasing power standpoint. Disciplinary Information Legal and Disciplinary The firm and its owner have not been involved in any legal or disciplinary events related to past or present investment clients in our 30 years in the business. Other Financial Industry Activities and Affiliations Financial Industry Activities Camden does not have any other commercial activities within the Securities, Investment Management or Financial Planning industry. - 9 - Camden Financial Management, Inc.  Affiliations Camden has affiliations Continuum Wealth Management (detailed later in “Privacy Notice”). Craig Ritter of Continuum Wealth Management provides services to Camden Financial Management. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The employees of Camden have committed to a Code of Ethics that is available for review by Clients and prospective Clients upon request. Participation or Interest in Client Transactions Camden and its employees may buy or sell securities that are also held by Clients. Employees may not trade their own securities ahead of Client trades. Employees must comply with the provisions of the Camden Compliance Manual. Personal Trading The Chief Compliance Officer of Camden is Randy Oldenburg. He places and reviews all personal trades each quarter. This personal trading review ensures that Clients of the firm receive preferential treatment over the personal trades of Randy Oldenburg. Brokerage Practices Selecting Brokerage Firms Camden does not have any affiliation with product sales firms. Specific custodian recommendations are made to Clients based on their need for such services. Camden recommends custodians based on the cost benefit proposition that is offered to the client. The stability and “safe keeping” of client’s assets is the utmost importance in our determination of custodians. Camden recommends discount brokerage firms (qualified custodians), such as Charles Schwab. Transamerica/Vanguard Annuity is also recommended for their low- cost variable annuities for Clients with existing variable annuities. Camden does not receive fees or commissions from any of these arrangements. Best Execution In the past, Camden reviewed a compilation of execution data (transactions) at TD Ameritrade and Charles Schwab. In that the government allowed this merger, there really is not any realistic competition in the institutional brokerage industry. Additionally, Camden does talk with Fidelity occasionally we and ask for any data they may have that shows superior execution. The response has always indicated that no data exists supporting any one of the two large Institutional/Independent custodians having any better execution than the other. In that Camden utilizes mutual funds for almost half of our equity allocation, the transaction fee to buy or sell a fund is of equal - 10 - Camden Financial Management, Inc.  importance as the bid/ask spread. The fees charged to transact mutual funds at Charles Schwab are some of the most competitive in the industry. As mentioned previously, Camden does utilize a third-party institutional bond broker to execute most bond purchases and sales due to the reduced commissions and much broader offering of inventory. Charles Schwab has predominately had the best execution on Treasuries sales, while Piper Sandler has been remarkably more competitive on Municipal Bonds. Piper Sandler effectively finds bonds in the marketplace that Camden desires. The best execution analysis of separate issue, lowly traded municipal bonds is difficult to quantify in a review process. When Camden is purchasing bonds, it is likely that only one bond house has the bond in their inventory. It is not uncommon that Camden buys bonds that are only traded once in a given quarter. The purchasing of Municipal Bonds is not a transaction business. There is no central exchange for Municipal Bonds. Many of these bond purchases are obtained directly from Piper Sandler’s own inventory. Camden determines the merits of the bond by comparing the yield to the MMD Curve. Camden is very picky as to the types of bonds, the municipality location and creditworthiness of the municipality. During periods where Camden believes it is advantageous for clients to add separate issue bonds to their portfolios, Camden will also look to offerings at Charles Schwab. Camden will typically review five different offerings for each bond that is purchased for clients. It is typical that Camden will spend weeks to find just one bond for a client. Camden makes the ultimate decision whether to purchase the bond, pass on the purchase or make a bid for the bond at a lower price, thus enhancing the ultimate yield for the client. Sometimes the bond trader will accept the lower bid, but many times they elect to pursue another investor. Camden also utilizes many other strategies such as responding to bid-wanted requests. The process of buying bonds at the most advantageous price for clients is very detailed and laborious. Each bond is unique in price, municipality creditworthiness, type, call date and final maturity. Camden does not receive any portion of these trading fees or commissions that are associated with our acquisition or sale of separate issue bonds, thus we have no financial incentive as to where bonds are purchased. Camden’s strategy and analysis of best execution on municipal bonds needs to be assessed as we acquire each bond. Soft Dollars Camden does not have any soft dollar arrangements in the literal definition. The issue that could potentially be deemed to be a soft dollar arrangement would be our utilizing of CHARLES SCHWAB as the custodian for our Client funds. SCHWAB offers services to independent investment advisors and their clients which include custody of securities, trade execution, clearance, and settlement of transactions (“Institutional Program”). The Advisor receives no cash benefit, or commissions, from any third party in connections with Clients’ accounts. All investment advisors that participate in the Institutional Program are eligible to receive certain benefits from - 11 - Camden Financial Management, Inc.  SCHWAB (“Program Benefits”). These benefits include various technological tools, education and compliance materials that assist investment advisors in managing and servicing their Clients’ accounts. These Program Benefits do not depend on the amount of brokerage transactions an investment advisor directs to SCHWAB. An investment advisor’s receipt of Program Benefits could create potential conflicts of interest between the investment advisor and its Clients. For example, the receipt of Program Benefits by an advisor may indirectly influence that advisor’s recommendation of SCHWAB for custody and brokerage services. Camden does not deem the benefits mentioned in the prior paragraph as having any significant value. If Camden utilized another custodian, they would receive similar “institutional services.” It should be noted that Schwab’s retail division has services and benefits in some areas that are superior to the advisor group. If Camden found a custodian that would provide better service to the Client, lower fees and equal stability – Camden would consider moving our Institutional relationship. Order Aggregation Most trades are mutual funds or exchange-traded funds and Camden does not utilize aggregating software. As previously noted, Camden manages customized portfolios, thus purchases and sales are specifically tailored to each Client’s current financial situation. Cross Trades Cross Trades are transactions where Camden will utilize a brokerage firm to set the pricing of a bond or CD and allow one Camden client to sell a holding while at the same time allowing another Camden client to buy the same holding. Camden does utilize cross trades within Client’s accounts (Taxable to IRA). Camden would consider making cross trades if the transactions benefited both parties and Piper Sandler would act as an arbitrator and price the bonds to protect both the buyer and the seller. Review of Accounts Periodic Reviews Account reviews are performed at least quarterly by the Advisor, Randy Oldenburg. Account reviews are performed more frequently when market conditions dictate. Review Triggers Other conditions that may trigger a review are changes in market conditions, a change in investment assumptions, an unforeseen macro event, or an update from the Client as to changes in the Client’s financial or personal situation. Input and feedback are requested of Clients relative to our macro beliefs and/or general recommendations. In addition, all Clients are requested to keep the Advisor apprised of any changes regarding their financial and personal situation. - 12 - Camden Financial Management, Inc.  Regular Reports Clients receive regular statements and confirmations from various companies serving as custodians for the Clients’ investment(s), e.g. brokerage firms (Charles Schwab) and mutual fund companies (Transamerica/Vanguard). Clients should review these trades and statements within a timely basis and contact Camden if any discrepancies exist or additional information is needed. Schwab provides these reports on a monthly basis and Transamerica/Vanguard provides the reports on a quarterly basis. The Advisor prepares quarterly investment appraisals and performance reports for Clients. Camden spends a significant amount of time maintaining the data to produce these reports. As with custodian statements and confirmations, Clients should review the data and contact Camden if any additional information or explanations are needed. Client Referrals Incoming Referrals Camden has been fortunate to receive many client referrals over the years. The firm does not compensate these particular referring parties for these referrals. Referrals Out Camden does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Custody Account Statements All assets are held at third party custodians, which means the custodians provide account statements directly to Clients at their address of record or email address, at least quarterly. CHARLES SCHWAB provides statements on a monthly basis. Performance Reports Clients are directed to compare the account statements received directly from their custodians to the appraisal report statements provided by Camden. Custody of Money Transfers A nuance has been brought forward by the SEC in 2017 where it is now required that Camden deems any client accounts where we have money transfer instructions in place to be deemed to have custody. The SEC has detailed seven requirements for which CHARLES SCHWAB and Camden will comply to not have Camden have to be burdened with the normal Custody requirements like a surprise internal audit from a CPA. Camden continues to maintain that we do not have the ability to obtain client funds, besides our small quarterly fee deduction that is clearly specified to the client before the deduction is effectuated. - 13 - Camden Financial Management, Inc.  Investment Discretion Discretionary Authority for Trading Clients provide Camden the authority to determine, without obtaining specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. This Discretionary Authority does not provide Camden the ability to take possession of any of Client’s assets. During periods of financial distress, a period where Camden has typically been acquiring assets, it is normal that Camden will write a Camden Comments report talking about the current opportunity. The client receives either paper or electronic confirmations on all transactions and Camden is very open to discuss any transaction where a client received a confirmation. It is Camden’s belief that if the Client invests one hour per month reviewing their quarterly reports, Schwab monthly statements, Charles Schwab confirmations and emails/letters, the Client will be reasonably up to speed as to their current investment affairs and current investment and financial strategy. Camden predominately utilizes Charles Schwab as our custodian. It is not feasible for Camden to utilize another custodian for just one Client, thus in the hiring process the Client needs to understand that Charles Schwab will be recommended to the Client. Camden strongly believes in the cost/benefit tradeoff to the Client in utilizing Charles Schwab and will happily discuss these benefits with Clients. Camden does not receive any portion of the small transaction fees or commissions paid by the Client to the custodian. Limited Power of Attorney The Client provides Camden with a Limited Power of Attorney to implement purchase and sale transactions within the Client’s portfolio. This Limited Power of Attorney provides Camden with the discretionary authority to make the necessary alterations in the Client’s portfolio. Voting Client Securities Proxy Votes Camden does not vote for Clients on proxy votes. If there was a specific situation where Camden wanted clients to vote a particular way, we would contact clients via email or U.S. mail. Financial Information Financial Condition Camden does not have any financial impairment that will preclude the firm from meeting contractual commitments to Clients. - 14 - Camden Financial Management, Inc.  A balance sheet is not required to be provided because Camden does not serve as a custodian for Client funds or securities and does not require prepayment of fees of more than $1,200 per Client, and six months or more in advance. Business Continuity Plan General Camden has a Business Continuity Plan in place that provides redundancies in services to mitigate and recover from the loss of office space and or communications. Camden effectively has office space to utilize in multiple states and multiple locations and has taken extreme precautions and expense if standard communications are interrupted. Camden has gone as far as having internet service by both cable and Satellite. Camden has both Cable phone lines as well as Satellite phone lines. Alternate Offices Camden has access to other locations, thus the loss of use of one office would not greatly affect the ability to service clients. Craig Ritter lives about an hour south of Asheville and during our hurricane, I was able to bring him power via my solar generators and he had internet service. In reality, I am an hour away from being able to regain communication if my cable line is down, my cell phone is down and my satellite/Starlink is down. Loss of Key Personnel Camden has forged a long-standing relationship with Craig Ritter at Continuum Wealth Management. Camden relies on Craig for daily support, but Craig Ritter is also the back-up advisor if something were to happen to Randy Oldenburg. Privacy Notice Camden Financial Management, Inc., an independent financial planning and investment management firm, is committed to safeguarding the confidential information of its Clients. We hold all personal information provided to our firm in the strictest confidence. These records include all personal information that we collect from Client in connection with any of the services provided by the firm. We have never disclosed non-public personal information to nonaffiliated third parties without Client’s prior permission, except as permitted by law, and do not anticipate doing so in the future. If we were to anticipate such a change in firm policy, we would be prohibited under the law from doing so without advising Client first. As Clients know, we use health and financial information that Client provides to us to help meet Client’s personal financial goals while guarding against any real or perceived infringements of Client’s rights of privacy. Our policy with respect to personal information about Client is listed below: • We limit employee and agent access to information only to those who have a business or professional reason for knowing. We limit the information provided to nonaffiliated parties to that to which Client has consented in the Client Agreement, or as permitted by law. (For example, federal regulations permit us to share a limited amount of information about Client with a brokerage firm in order to execute - 15 - Camden Financial Management, Inc.  securities transactions on Client behalf, or so that our firm can discuss Client’s financial situation with Client’s accountant or lawyer.) • We make every effort to maintain a secure office and computer environment to ensure that Client’s information is not placed at unreasonable risk. • The categories of nonpublic personal information that we collect from a Client depend upon the scope of the Client engagement. It will include information about Client’s personal finances, information about Client’s health to the extent that it is needed for the planning process, information about transactions between Client and third parties, and information from consumer reporting agencies. • For nonaffiliated third parties that require access to Client’s personal information, including financial service companies, consultants, insurance agents and auditors, we also require strict confidentiality with them and expect them to keep this information private. Federal and state regulators also may review firm records as permitted under law. • We do not provide Client’s personally identifiable information to mailing list vendors or solicitors for any purpose. • Personally identifiable information about Client will be maintained during the time Client is a Client, and at least for the required time thereafter that such records are required to be maintained by federal and state securities laws, and consistent with the CFP Board Code of Ethics and Professional Responsibility. This information will not be disclosed to third parties except as agreed to in the Client Agreement and this Privacy Notice. • Randy Oldenburg of Camden Financial Management and Craig Ritter of Continuum Wealth Management work on the affairs of Camden’s clients. Randy and Craig have access to each other’s Clients’ information. We take the confidentiality of this information very seriously and jointly take numerous steps to keep this information secure. Opt-Out Provision. You have a right not to permit us to share your nonpublic personal information with anyone else. If you do not want us to share your nonpublic personal information with others, as we deem necessary to perform the service you’ve engaged us for, then it is unlikely that we will be able to fulfill our duties outlined in the Client Agreement. If you intend to exercise this right, please notify the firm immediately by calling us at 480-998- 7786. - 16 - Camden Financial Management, Inc.  Brochure Supplement (Part 2B of Form ADV) Education and Business Standards Camden requires that advisors have a bachelor's degree and a CFP® license. Additionally, advisors must have work experience that demonstrates their aptitude for financial planning and investment management. Professional Certifications Advisors have earned certifications and credentials that are required to be explained in further detail. Certified Financial Planner (CFP): Certified Financial Planners are licensed by the CFP Board to use the CFP mark. CFP certification requirements: • Bachelor’s degree from an accredited college or university. • Completion of the financial planning education requirements set by the CFP Board (www.cfp.net). • Successful completion of the CFP® Certification Exam. • Three-year qualifying full-time work experience. Employee Education and Business Background Richard Randall (“Randy”) Oldenburg Birth Year: 1965 Educational Background: • Bachelor of Business Administration, Finance, Southern Methodist University, 1989 • Bachelor of Arts, Economics, Southern Methodist University, 1989 • College for Financial Planning, Certified Financial Planner Licensee, 1994 Business Experience: • 7/1996–Present - Camden Financial Management, Inc., Asheville, NC • 5/1993–7/1996 -Vice President, Wells Fargo Private Banking, Scottsdale, AZ • 12/1989–5/1993 - Private Banker, First Chicago Private Banking, Chicago, IL Disciplinary Information: None Other Business Activities: None Additional Compensation: None - 17 - Camden Financial Management, Inc.