CAMPBELL DEEGAN FINANCIAL

Form ADV Part 2A Brochure Campbell Deegan Item 1 – Cover Page CAMPBELL DEEGAN WEALTH MANAGEMENT, LLC (d/b/a CAMPBELL DEEGAN FINANCIAL) FORM ADV PART 2A BROCHURE Sponsored by 8730 Stony Point Pkwy., Suite 100, Richmond, VA 23235 (804) 913-1112 www.cdfva.com March 30, 2026 This brochure provides information about the qualifications and business practices of Campbell Deegan Wealth Management, LLC (d/b/a Campbell Deegan Financial; hereinafter “Campbell Deegan” or the “Firm”). If you have any questions about the contents of this brochure, please contact the Firm at the telephone number listed above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Additional information about the Firm is available on the SEC’s website at www.adviserinfo.sec.gov. The Firm is a registered investment adviser. References herein to Campbell Deegan as a "registered investment adviser" or any reference to being "registered" does not imply a certain level of skill or training.  Form ADV Part 2A Brochure Campbell Deegan Item 2. Material Changes Since our last annual update filed on March 20, 2025, there have been no material changes made to this brochure. 2 | P a g e  Form ADV Part 2A Brochure Campbell Deegan Item 3. Table of Contents Item 1 – Cover Page ............................................................................................................................................................................... 1 Item 2. Material Changes ...................................................................................................................................................................... 2 Item 3. Table of Contents ...................................................................................................................................................................... 3 Item 4. Advisory Business .................................................................................................................................................................... 4 Item 5. Fees and Compensation…………………………………………………………………………………………………...7 Item 6. Performance Based Fees and Side by Side Management ....................................................................................................... 8 Item 7. Types of Clients ........................................................................................................................................................................ 8 Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss .............................................................................................. 9 Item 9. Disciplinary Information ........................................................................................................................................................ 12 Item 10. Other Financial Industry Activities and Affiliations ........................................................................................................... 12 Item 11. Code of Ethics, Participation or Interest in Client Transactions………………………………………………………14 Item 12. Brokerage Practices………………………………………………………………………………………..14 Item 13. Review of Accounts………………….……………………………………………………………………15 Item 14. Client Referrals and Other Compensation……………………………..………………………………….16 Item 15. Custody………………………………..…………………………………………………………………..17 Item 16. Investment Discretion…………………………………………….……………………………………….17 Item 17. Voting Client Securities……………………………………….…………………………………………..18 Item 18. Financial Information………………………………….…………………………………………………..18 3 | P a g e  Form ADV Part 2A Brochure Campbell Deegan Item 4. Advisory Business Campbell Deegan is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, Campbell Deegan is a wholly-owned indirect subsidiary of Focus LLC. Focus Financial Partners Inc. is the sole managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board of directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority-owned, indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”). Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC. Because Campbell Deegan is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of Campbell Deegan. Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business managers and other firms (the “Focus Partners”), most of which provide wealth management, benefit consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment companies as disclosed on their respective Form ADVs. Campbell Deegan is managed by Sean Campbell and Tim Deegan (“Campbell Deegan Principals”), pursuant to a management agreement between CDF Partners, LLC and Campbell Deegan. The Campbell Deegan Principals serve as officers of Campbell Deegan and are respon sible for the management, supervision and oversight of Campbell Deegan. While this brochure generally describes the business of Campbell Deegan, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on Campbell Deegan’s behalf and is subject to the Firm’s supervision or control. Description of the Program Campbell Deegan offers a variety of advisory services, which include financial planning consulting, and investment management services. Prior to Campbell Deegan rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with Campbell Deegan setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). Clients must also open a new securities brokerage account and complete a new account agreement with Fidelity Institutional Wealth Services (“Fidelity” or the "Custodian") or another broker-dealer that Campbell Deegan approves (collectively “Financial Institutions”). After an analysis of a client’s financial situation and needs, Campbell Deegan assists its clients in developing an appropriate strategy for managing their assets. Clients’ investment portfolios are managed on either a discretionary o r non-discretionary basis by Campbell Deegan’s investment adviser representatives or an independent investment manager, as recommended or selected by Campbell Deegan. As of December 31, 2025, Campbell Deegan had $578,145,172 in discretionary assets under management and $166,905,661 in non-discretionary assets under management. 4 | P a g e  Form ADV Part 2A Brochure Campbell Deegan Financial Planning and Consulting Services Campbell Deegan offers clients a broad range of financial planning and consulting services, which may include any or all of the following functions: Investment Consulting Insurance Planning • Business Planning • Education Planning • Liability and Risk Management • Trust and Estate Planning • Retirement Planning • Cash Flow Forecasting • • • Charitable Giving • Distribution Planning • Tax Planning • Manager Due Diligence These services are provided in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below). In performing these services, Campbell Deegan is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. Campbell Deegan may recommend clients engage the Firm for additional related services and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage Campbell Deegan or its affiliates to provide additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by Campbell Deegan under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Campbell Deegan’s recommendations and/or services. Investment and Wealth Management Services Campbell Deegan provides clients with wealth management services which include a broad range of comprehensive financial planning and consulting services as well as non-discretionary management of investment portfolios. Campbell Deegan primarily allocates client assets among various mutual funds, but will also utilize exchange-traded funds (“ETFs”), individual debt and equity securities, and private investment funds and/or independent investment managers, or external managers of separately managed accounts (“Independent Managers”) in accordance with clients’ stated investment objectives. When requested, the Firm may also provide advice about any type of legacy position or other investment held in client portfolios. Clients may engage Campbell Deegan to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as assets held in employer 5 | P a g e  Form ADV Part 2A Brochure Campbell Deegan sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Campbell Deegan directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the custodian designated by the product’s provider. Campbell Deegan tailors its advisory services to meet the needs of its individual clients and seeks to ensure that client portfolios are managed in a manner consistent with those needs and objectives. Campbell tolerance, time Deegan consults with clients on an initial and ongoing basis to assess their specific risk horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify Campbell Deegan if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if Campbell Deegan determines, in its sole discretion that the conditions would not prove overly burdensome to the Firm’s management efforts. Campbell Deegan is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to ERISA plan clients, including ERISA plan participants. Campbell Deegan is also a fiduciary under the Internal Revenue Code (the “IRC”) with respect to investment management services and investment advice provided to ERISA plans, ERISA plan participants, IRAs and IRA owners (collectively, “Retirement Account Clients”). As such, Campbell Deegan is subject to specific duties and obligations under ERISA and the IRC that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice in which it has a conflict of interest, the fiduciary must either avoid or eliminate the conflict or rely upon a prohibited transaction exemption (a “PTE”). As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any non -waivable rights you possess. Use of Independent Managers As mentioned above, Campbell Deegan may select certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager may be set forth in a separate written agreement with the designated Independent Manager. In addition to this brochure, clients may also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. Campbell Deegan evaluates a variety of information about Independent Managers, which may include the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to 6 | P a g e  Form ADV Part 2A Brochure Campbell Deegan takes its clients’ individual portfolio allocations and risk exposure. Campbell Deegan also into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. Campbell Deegan continues to provide services relative to the non-discretionary selection of the Independent Managers. The Firm will monitor the performance of those accounts being managed by Independent Managers. Campbell Deegan seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. While the assets managed by the Independent Managers are included in the Firm’s assets under management for fee billing, the Independent Managers’ fees are not included in the Program Fee. Item 5. Fees and Compensation The Program is offered on a fee basis, meaning participants pay a single annualized fee based upon assets under management, including accrued interest and accrued dividends. This management fee, as set forth in our investment management agreement with the client, ranges up to 200 basis points (2.00%) depending upon the size and composition of a client’s portfolio and the type of services rendered. For the initial quarter, the fee is charged in arrears based upon the average daily account balance of the assets being managed by the Firm during the initial quarter. In subsequent quarters, the fee is charged in advance based upon the market value of the average daily account balance of the assets being managed by the Firm for the previous quarter. For the initial period of an engagement, the fee is calculated on a pro rata basis, while the fees for subsequent quarters are adjusted because the Firm uses the average daily account balance for the previous quarter. In the event the advisory agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination and the outstanding or unearned portion of the fee is charged or refunded to the client, as appropriate. Fee Discretion Campbell Deegan may, in its sole discretion, negotiate with a client to charge a lesser fee than is charged to another client based upon certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre- existing/legacy client relationship, account retention and for certain non-profit groups or charitable organizations. Other Charges In addition to the advisory fees paid to Campbell Deegan, clients may also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions. These additional charges include fees charged by the Independent Managers, fees attributable to alternative assets, reporting charges, margin costs, charges imposed directly by a mutual fund or ETF in 7 | P a g e  Form ADV Part 2A Brochure Campbell Deegan a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), mark-ups or mark-downs priced in to fixed income products by the broker-dealer, fees and commission for assets not held with the Custodian (such as 401(k) or 529 plan assets), deferred sales charges, odd-lot differentials, transfer taxes, check reorder fees, wire transfer and electronic fund fees, and close-out fees from the custodian. Direct Fee Debit Clients generally provide Campbell Deegan and/or certain Independent Managers with the authority to directly debit their accounts for payment of the investment advisory fees. The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct transactions, fees, have agreed to send statements to clients not less than quarterly detailing all account including any amounts paid to Campbell Deegan. Clients should compare the account statements they receive from their custodian with any documents or reports they receive from Campbell Deegan or an outside service provider. Account Additions and Withdrawals Clients may make additions to and withdrawals from their account at any time, subject to Campbell Deegan’s right to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. Clients may withdraw account assets on notice to Campbell Deegan, subject to the usual and customary securities settlement procedures. However, Campbell Deegan designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. Campbell Deegan may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charge) and/or tax ramifications. Use of Margin Campbell Deegan may be authorized to use margin in the management of the client’s investment portfolio. In these cases, the fee payable will be assessed net of margin such that the market value of the client’s account and corresponding fee payable by the client to Campbell Deegan will not be increased. The Firm may, however, charge financial planning or consulting fixed fees based on structuring loans. Item 6. Performance Based Fees and Side by Side Management Campbell Deegan does not provide any services for a performance-based fee (i.e., a fee based on a share of capital gains or capital appreciation of a client’s assets). 8 | P a g e  Form ADV Part 2A Brochure Campbell Deegan Item 7. Types of Clients Campbell Deegan seeks t o offer services to individuals, corporations and business entities, pension and profit sharing plans, and trusts and estates. Campbell Deegan does not impose a minimum portfolio value or fee as a condition for starting or maintaining an investment management relationship. Certain Independent Managers may, however, impose more restrictive account requirements and billing practices than the Firm. In these instances, Campbell Deegan may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. This may result in the client paying a minimum fee to that Independent Manager or not have access to an Independent Manager if the client does not meet that firm’s minimum portfolio value. Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss Methods of Analysis Campbell Deegan primarily utilizes fundamental analysis when managing client assets. Fundamental analysis involves an evaluation of the fundamental financial condition and competitive position of a particular fund or issuer. For Campbell Deegan, this process involves an analysis of an issuer’s management team, investment strategies, style drift, past performance, reputation and financial strength in relation to the asset class concentrations and risk exposures of the Firm’s model asset allocations. A substantial risk in relying upon fundamental analysis is that while the overall health and position of a company may be good, evolving market conditions may negatively impact the security. Investment Strategies After an analysis of a client’s financial situation and needs, Campbell Deegan assists its clients in developing an appropriate strategy for managing their assets. Through understanding each client's cash flows, current and future financial obligations, risk perceptions, liquidity, time horizon, and investment objectives, the Firm believes it can custom tailor portfolios to meet each client's personal objectives. Campbell Deegan believes a diversified approach improves clients' probability of achieving their financial goals. Diversification is sought through investment among asset classes, investment styles, and maximum allocations to specific positions. The Firm will include equity, fixed income, alternatives, and cash in each client's account, as appropriate. Further, Campbell Deegan may utilize Independent Managers to invest in direct equity and fixed income positions, open-end and closed-end mutual funds, ETFs, UITs, and direct investment. The Firm will have up to five primary investment strategies ranging from conservative to aggressive. A client will be invested based on one or more of those strategies, but specific holdings will vary amongst clients since the management is customized to a certain degree for each client. Risk of Loss Investment Risks 9 | P a g e  Form ADV Part 2A Brochure Campbell Deegan 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 or investment strategies recommended or undertaken by Campbell Deegan) will be profitable or equal any specific performance level(s). Every method of analysis has its own inherent risks. To perform an accurate market analysis Campbell Deegan must have access to current/new market information. Campbell Deegan has no control over the dissemination rate of market information; therefore, unbeknownst to Campbell Deegan certain analyses may be derived from stale information, severely limiting the value of Campbell Deegan’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 or profitable investment opportunities. 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. Generally, the market value of equity stocks will fluctuate with market conditions, and small- stock prices generally will fluctuate more than large-stock prices. The market value of fixed income securities will generally fluctuate inversely with interest rates and other market conditions prior to maturity. Fixed income securities are obligations of the issuer to make payments of principal and/or interest on future dates, and include, among other securities: bonds, notes and debentures issued by corporation s; debt securities issued or guaranteed by the U.S. government or one of its agencies or instrumentalities, or by a non-U.S. government or one of its agencies or instrumentalities; municipal securities; and mortgage-backed and asset- backed securities. These securities may pay fixed, variable, or floating rates of interest, and may include zero coupon obligations and inflation-linked fixed income securities. The value of longer duration fixed income securities will generally fluctuate more than shorter duration fixed income securities. Investments in overseas markets also pose special risks, including currency fluctuation and political risks, and it may be more volatile than that of a U.S. only investment. Such risks are generally intensified for investments in emerging markets. In addition to fundamental investment strategies, Campbell Deegan may also implement options strategies. The use of option strategies, even as a hedge, has a high level of inherent risk. Option transactions establish a contract between two parties concerning the buying or selling of an asset at a predetermined price during a specific period of time. During the term of the option contract, the buyer of the option gains the right to demand fulfillment by the seller. Fulfillment may take the form of either selling or purchasing a security depending upon the nature of the option contract. Generally, the purchase or the recommendation to purchase an option contract by Campbell Deegan shall be with the intent of offsetting/“hedging” a potential market risk in a client’s portfolio. Although Campbell Deegan’s intent of the options-related transactions implemented may be to hedge against principal risk, certain of the options- related strategies (i.e., straddles, short positions, etc.), may, in and of themselves, produce principal volatility or risk. Thus, a client must be willing to accept these enhanced risks associated with such strategies. 10 | P a g e  Form ADV Part 2A Brochure Campbell Deegan In light of these enhanced risks, client may direct Campbell Deegan, in writing, not to employ any or all such strategies for their accounts. Mutual Funds and ETFs 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 mutual funds and ETFs 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. Shares of mutual funds are generally 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 to the market value of the fund’s holdings. The trading prices of a mutual fund’s shares may 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 actual 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 potentially more frequently for actively managed ETFs. However, certain inefficiencies may 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. Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 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. COVID Risk The transmission of COVID and efforts to contain its spread have resulted in border closings and other travel restrictions and disruptions, market volatility, disruptions to business operations, supply chains and customer activity and quarantines. With widespread availability of vaccines, the U.S. Centers for Disease Control and Prevention has revised its guidance, travel restrictions have started to lift, and businesses have reopened. However, the COVID pandemic continues to evolve and the extent to which our investment strategies will be impacted will depend on various factors beyond our control, including the extent and duration of the impact on economies around the world and on the global securities and commodities markets. Volatility in the U.S. and global financial markets caused by the COVID pandemic may continue and could impact our firm’s investment strategies. Although currently there has been no significant impact, the COVID outbreak, and future pandemics, could negatively affect vendors on which our firm and clients rely and could disrupt the ability of such vendors to perform essential tasks. 11 | P a g e  Form ADV Part 2A Brochure Campbell Deegan Cybersecurity Risk The computer systems, networks and devices used by Campbell Deegan and service providers to the Firm and the Firm’s clients to carry out routine business operations employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks, or devices potentially can be breached. A client could be negatively impacted as a result of a cybersecurity breach. Cybersecurity breaches can include unauthorized access to systems, networks, or devices; infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow, or otherwise disrupt operations, business processes, or website access or functionality. Cybersecurity breaches may cause disruptions and impact business operations, potentially resulting in financial losses to a client; impediments to trading; the inability by Campbell Deegan and other service providers to tran sact business; violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs; as well as the inadvertent release of confidential information. Similar adverse consequences could result from cybersecurity breaches affecting issuers of securities in which a client invests; governmental and other regulatory authorities; exchange and other financial market operators, banks, brokers, dealers, and other financial institutions; and other parties. In addition, substantial costs may be incurred by these entities in order to prevent any cybersecurity breaches in the future. Use of Margin While the use of margin borrowing can substantially improve returns, it may also increase overall portfolio risk. Margin transactions are generally effected using capital borrowed from a Financial Institution, which is secured by a client’s holdings. Under certain circumstances, a lending Financial Institution may demand an increase in the underlying collateral. If the client is unable to provide the additional collateral, the Financial Institution may liquidate account assets to satisfy the client’s outstanding obligations, which could have extremely adverse consequences. In addition, fluctuations in the amount of a client’s borrowings and the corresponding interest rates may have a significant effect on the profitability and stability of a client’s portfolio. Cryptocurrency Cryptocurrency is a digital representation of value that functions as a medium of exchange, a unit of account, or a store of value, but it does not have legal tender status. Cryptocurrencies are sometimes exchanged for U.S. dollars or other world currencies, but they are not generally backed or supported by any government or central bank. They are more volatile than traditional currencies. Their value is speculative, given that they are not currently, widely accepted as a medium or exchange, is derived by market forces of supply and demand, and may be impacted by the continued willingness of market participants to exchange fiat currency for cryptocurrency. Cryptocurrencies are not covered by either FDIC or SIPC insurance. 12 | P a g e  Form ADV Part 2A Brochure Campbell Deegan Bitcoin, Ethereum and other cryptocurrencies are very speculative investments and involve a high degree of risk. An investment in cryptocurrency is not suitable for all investors, and may not generally be appropriate, particularly with funds drawn from retirement savings, student loans, mortgages, emergency funds, or funds set aside for other purposes. Investors must have the financial ability, sophistication/experience and willingness to bear the risks of an investment, and a potential total loss of their investment. An investment in cryptocurrency should be discretionary capital set aside strictly for speculative purposes. Fees and expenses associated with a cryptocurrency investment may be substantial. Private Investment Funds Private investment funds are generally subject to a high degree of risk (including the potential for complete loss of principal), are not suitable for all investors, and typically have high fees, limited liquidity and delays in tax reporting. By themselves, private investment funds do not constitute a balanced investment portfolio. Clients should carefully review and consider potential risks before investing in private investment funds, including carefully reviewing all disclosure documents, private offering memoranda, prospectuses, or other offering materials and/or consulting tax or legal counsel, if appropriate. Item 9. Disciplinary Information Campbell Deegan has not been involved in any legal or disciplinary events that are material to a client’s evaluation of its advisory business or the integrity of its management. Item 10. Other Financial Industry Activities and Affiliations Use of Independent Managers As stated above, Campbell Deegan may select certain Independent Managers to manage a portion of its clients’ assets. In these situations, Campbell Deegan continues to conduct initial and ongoing due diligence of such managers. However, the performance of those assets managed by Independent Managers implement their will depend to a great extent on the Independent Managers’ ability to successfully investment strategies. Campbell Deegan is not involved with the day-to-day operations of an Independent Manager's business nor does Campbell Deegan supervise the Independent Managers. Campbell Deegan, however, regularly monitors the client accounts and assets managed by Independent Managers. FOCUS OPERATING, LLC, FOCUS FINANCIAL PARTNERS, LLC and FOCUS FINANCIAL PARTNERS INC. As noted above in response to Item 4, certain investment vehicles affiliated with CD&R collectively are indirect majority owners of Focus LLC, and certain investment vehicles affiliated with Stone Point are indirect owners of Focus LLC. Because Campbell Deegan is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of Campbell Deegan. 13 | P a g e  Form ADV Part 2A Brochure Campbell Deegan Item 11. Code of Ethics, Participation or Interest in Client Transactions Code of Ethics Campbell Deegan has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”) that sets forth the standards of conduct expected of its Supervised Persons. Campbell Deegan’s Code of Ethics contains written policies reasonably designed to prevent certain unlawful practices such as the use of material non-public information by the Firm or any of its Supervised Persons and the trading by the same of securities ahead of clients in order to take advantage of pending orders. Personal securities transactions of Supervised Persons present potential conflicts of interest with the price obtained in client securities transactions or the investment opportunity available to clients. The Code of Ethics addresses these potential conflicts of interest by requiring certain of Campbell Deegan’s personnel to report their personal securities holdings and transactions for review by the Firm’s Chief Compliance Officer, or designee, and obtain pre-approval of certain investments (e.g., initial public offerings, limited offerings). The Firm’s Supervised Persons are permitted to buy or sell securities that it also recommends to clients if done in a fair and equitable manner that is consistent with the Firm’s policies and procedures. Clients and prospective clients may contact Campbell Deegan to request a copy of its Code of Ethics. Item 12. Brokerage Practices Campbell Deegan recommends that clients utilize the custody, brokerage and clearing services of the Custodian for investment management accounts. Factors which Campbell Deegan considers in recommending the Custodian or any other broker-dealer to clients include their respective financial strength, reputation, execution, pricing, research and service. In seeking best execution in recommending the Custodian, the Firm considers whether the transaction represents the best qualitative execution, taking into consideration the full range of a financial institution’s services, including among others, the value of research provided, execution capability, commission rates and responsiveness. Consistent with obtaining best execution, brokerage transactions may be directed to certain broker-dealers in return for investment research products and/or services which assist Campbell Deegan in its investment decision-making process. The receipt of investment research products and/or services poses a conflict of interest because Campbell Deegan does not have to produce or pay for the products or services. Campbell Deegan periodically and systematically reviews its policies and procedures regarding its recommendation of Financial Institutions in light of its duty to obtain best execution. Other Compensation Provided by Financial Institutions 14 | P a g e  Form ADV Part 2A Brochure Campbell Deegan Campbell Deegan may receive without cost from Fidelity computer software and related systems support, which allow Campbell Deegan to better monitor client accounts maintained at Fidelity. Specifically, Campbell Deegan may receive the following benefits from Fidelity: • Funds to be used toward qualifying third-party service providers for research, marketing, compliance, technology and software platforms and services; • Receipt of duplicate client confirmations and bundled duplicate statements; • Access to a trading desk that exclusively services its institutional traders; • Access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; and • Access to an electronic communication network for client order entry and account information. Campbell Deegan’s clients do not pay a higher Program fee as result of this arrangement. There is no corresponding commitment made by Campbell Deegan to Fidelity or any other entity to invest any specific amount or percentage of client assets in any specific mutual funds, securities or other investment products as a result of the above arrangement. Campbell Deegan’s Chief Compliance Officer is available to address any questions that a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest any such arrangement may create. Trade Aggregation Transactions for each client generally will be effected independently, unless Campbell Deegan decides to purchase or sell the same securities for several clients at approximately the same time. To the extent that Campbell Deegan determines to aggregate client orders for the purchase or sale of securities, including securities in which the Campbell Deegan’s supervised persons may invest, the Firm will generally do so in a fair and equitable manner in accordance with applicable rules promulgated under the Advisers Act and guidance provided by the staff of the SEC and consistent with policies and procedures established by the Firm. Item 13. Review of Accounts Campbell Deegan monitors client portfolios on a continuous and regular basis. In addition, a formal review of client portfolios will be conducted at least annually (with a three month grace period). The financial plan and investment portfolio of the client will be reviewed at that time. Such reviews are conducted by the Firm’s principals. All investment advisory clients are encouraged to discuss their needs, goals and objectives with Campbell Deegan and to keep the Firm informed of any changes thereto. Campbell Deegan 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 or financial situation, market corrections and client request. 15 | P a g e  Form ADV Part 2A Brochure Campbell Deegan Item 14. Client Referrals and Other Compensation The Firm does not currently provide compensation to any third-party solicitors for client referrals. Other Compensation As described above in Item 4, Campbell Deegan is part of the Focus Financial Partners partnership (“Focus”). From time to time, Focus holds partnership meetings and other industry and best -practices conferences, which typically include Campbell Deegan, other Focus firms and external attendees. These meetings are first and foremost intended to provide training or education to personnel of Focus firms, including Campbell Deegan. However, the meetings do provide sponsorship opportunities for asset managers, asset custodians, vendors and other third party service providers. Sponsorship fees allow these companies to advertise their products and services to Focus firms, including Campbell Deegan. Although the participation of Focus firm personnel in these meetings is not preconditioned on the achievement of a sales target for any conference sponsor, this practice could nonetheless be deemed a conflict as the marketing and education activities conducted, and the access granted, at such meetings and conferences could cause Campbell Deegan to focus on those conference sponsors in the course of its duties. Focus attempts to mitigate any such conflict by allocating the sponsorship fees only to defraying the cost of the meeting or future meetings and not as revenue for it self or any affiliate, including Campbell Deegan. Conference sponsorship fees are not dependent on assets placed with any specific provider or revenue generated by such asset placement. The following entities have provided conference sponsorship to Focus from January 1, 2025 to February 1, 2026: • Addepar, Inc. • AQR Capital Management, LLC • Bigelow LLC • BlackRock, Inc. • BOWS Administrator LLC (Brookfield Oaktree Wealth Solutions) • Capital Integration Systems LLC (CAIS) • Charles Schwab & Co., Inc. • Cliffwater LLC • Dimensional Fund Advisors LP • Dinsmore Compliance Services, LLC (DCS) • Eaton Vance Distributors, Inc. (includes Parametric Portfolio Associates) • Edgewood Partners Insurance Center (EPIC) (includes Vanbridge) • Fidelity Brokerage Services LLC (includes FIAM and Wealthscape) • Flourish Financial LLC • Franklin Templeton Distributors LLC (includes O’Shaughnessy Asset Management, L.L.C. (OSAM) and CANVAS) Jackson National Life Distributors LLC • • K&L Gates LLP • Lord, Abbett & Co. LLC • Nuveen Securities, LLC • Orion Advisor Solutions, Inc. • Pacific Investment Management Company LLC (PIMCO) • Pinnacle Insurance & Financial Services, LLC • Practifi, Inc. • Quantinno Capital Management LP (includes TaxEdge and DEALS (Direct Equity Active Long Short)) • RedBlack Software, LLC (includes intelliflo) • SmartAsset Advisors LLC 16 | P a g e  Form ADV Part 2A Brochure Campbell Deegan • Stone Ridge Asset Management LLC • The Vanguard Marketing Corporation, Inc. • T. Rowe Price Investment Services, Inc. • TriState Capital Bank • VRGL Inc. You can access a more recently updated list of recent conference sponsors on Focus’ website through the following link: https://focusfinancialpartners.com/conference-sponsors/ Item 15. Custody All clients must utilize a “qualified custodian” as detailed in Item 12. Clients are required to engage the custodian to retain their funds and securities and direct Campbell Deegan to utilize the custodian for the client’s securities transactions. Campbell Deegan’s agreement with clients and/or the clients’ separate agreement with the B/D Custodian authorizes Campbell Deegan through such BD/Custodian to debit the client’s account for the amount of Campbell Deegan’s fee and to directly remit that fee to Cam pbell Deegan in accordance with applicable custody rules. The BD/Custodian recommended by Campbell Deegan has agreed to send a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of management fees paid directly to Campbell Deegan. Campbell Deegan encourages clients to review the official statements provided by the custodian, and to compare such statements with investment reports received from Campbell Deegan. For more information about Custodians and brokerage practices, see “Item 12 - Brokerage Practices.” For various clients, Campbell Deegan is provided authority pursuant to a standing letter of authorization permitting transfers from the custodian to unaffiliated third parties as designated by the client (“SLOAs”). The SEC has determined that advisers who can effect transfers pursuant to SLOAs have custody over these client accounts, but granted relief from the surprise examination requirement in a no-action letter to the Investment Adviser Association dated February 21, 2017, provided that certain conditions are met. Account Statements and Reports Clients are provided with transaction confirmation notices and regular summary account statements directly from the Financial Institutions where their assets are custodied. From time-to-time or as otherwise requested, clients may also receive written or electronic reports from Campbell Deegan and/or an outside service provider, which contain certain account and/or market-related information, such as an inventory of account holdings or account performance. Clients should compare the account statements they receive from their Financial Institution with any documents or reports they receive from Campbell Deegan or an outside service provider. Item 16. Investment Discretion Clients have the option of providing Campbell Deegan with investment discretion on their behalf, pursuant to a grant of a limited power of attorney contained in Campbell Deegan’s client agreement. By granting Campbell Deegan investment discretion, a client authorizes Campbell Deegan to direct securities transactions and determine which securities are bought and sold, the total amount to be bought and sold, and the costs at which the transactions will be 17 | P a g e  Form ADV Part 2A Brochure Campbell Deegan effected. Clients may impose reasonable limitations in the form of specific constraints on any of these areas of discretion with the consent and written acknowledgement of Campbell Deegan. Item 17. Voting Client Securities Campbell Deegan does not accept the authority to vote a client’s securities (i.e., proxies) on their behalf. Clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings, class action litigation or other type events pertaining to the client’s investment assets. Clients will receive their proxies or other solicitations directly from their Financial Institutions. Clients may contact Campbell Deegan to discuss any questions they may have with a particular solicitation. Item 18. Financial Information A. Balance Sheet Campbell Deegan does not require prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this Brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Campbell Deegan nor its management has any financial conditions that are reasonably likely to impair its ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Years Campbell Deegan has not been the subject of a bankruptcy petition. 18 | P a g e