CARDIFF PARK ADVISORS,LLC

Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 Cardiff Park Advisors, LLC Firm Brochure Part 2A & 2B of Form ADV Cardiff Park Advisors, LLC 7161 Aviara Drive Carlsbad, CA 92011 Phone: Fax: Website: Email: (760) 635-7526 (760) 284-5550 http://cardiffpark.com jgorlow@cardiffpark.com June 30, 2025 This brochure provides information about the qualifications and business practices of Cardiff Park Advisors, LLC (Cardiff Park). 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. Cardiff Park is a registered investment advisor, which does not imply a certain level of skill or training. Additional information about Cardiff Park is available on the SEC website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Cardiff Park is 126752. If you have questions after reading this brochure, please contact us at (760) 635-7526. 1 | P a g e  Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 Item 2: Summary of Material Changes This brochure, dated June 30, 2025, replaces our previous brochure dated March 24, 2025. As of June 30, 2025, Cardiff Park Advisors managed approximately $2.8 Billion in client assets on a non-discretionary basis. Fixed Income Management Update We have revised our regulatory disclosures to reclassify fixed income portfolio management from discretionary to non-discretionary. This change more accurately reflects how portfolios have long been managed in practice, through a collaborative and customized approach. Cardiff Park remains actively involved in developing strategy, selecting securities, and facilitating execution, while clients retain final investment authority. Retainer Range and Review Policy Our pricing framework reflects the comprehensive nature of our advisory work and the level of responsibility we assume on behalf of each client. For new engagements, annual retainers typically range from $8,000 to $14,000. These retainers are reviewed periodically and may be adjusted to reflect changes in scope, complexity of planning work, and inflation. Separately Billed Services Certain advisory services fall outside the scope of our standard retainer. Examples include estate settlement, financial restructuring, fixed income ladder construction, restricted stock liquidation, and management of concentrated equity positions. We are pleased to provide these additional services, which are often time-intensive and require customized, collaborative work across disciplines. We will review each client’s needs individually, and when warranted, propose a separate fee arrangement. Cash Management At Cardiff Park, we coordinate cash management activity with clients to ensure sufficient liquidity to meet near-term and recurring spending needs. This includes monitoring cash positions across accounts, coordinating inflows and outflows with tax sensitivity in mind, and putting idle balances to work through sweep vehicles or higher-yielding money market options. Effective cash management requires timely communication. We ask clients to alert us to upcoming liquidity events so we can proactively position funds and ensure cash availability when needed. 2 | P a g e  Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 Transition to Quarterly Client Reporting Beginning in September 2025, Cardiff Park Advisors will transition from monthly to quarterly reporting as our default client-reporting protocol. This change is designed to reduce short-term performance noise and reinforce a planning mindset that focuses on long-term investment goals. The format and content of our reports will remain consistent with prior practice, providing consolidated, reconciled data across accounts and clear insight into portfolio positioning and strategy. Clients who prefer monthly reporting may continue to receive it upon request. Advisory Fee Payment Preferences Cardiff Park’s default payment method for new advisory relationships is direct fee debiting from a linked custodial account. This ensures timely, accurate processing and minimizes the administrative burden for clients. While we encourage all clients to authorize this method, those currently remitting payments by check, ACH transfer, or bill-pay services may continue doing so. 3 | P a g e  Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 Item 3: Table of Contents Table of Contents Item 2: Summary of Material Changes ....................................................2 Fixed Income Management Update.......................................................2 Retainer Range and Review Policy........................................................2 Separately Billed Services ...................................................................2 Cash Management .............................................................................2 Transition to Quarterly Client Reporting ................................................3 Advisory Fee Payment Preferences.......................................................3 Item 3: Table of Contents......................................................................4 Item 4: Advisory Business .....................................................................7 Overview ..........................................................................................7 Principal Owner and Business Team .....................................................7 Wealth Management Services..............................................................8 Item 5: Our Fees..................................................................................8 General ............................................................................................8 Initial Evaluation................................................................................9 Annual Retainers ...............................................................................9 Onboarding Fees................................................................................9 Separately Billed Services ...................................................................9 Family Member Accounts .................................................................. 10 Billing of Advisory Fees..................................................................... 10 Cancellation and Termination ............................................................ 10 12B-1 Fees and Sales Commissions.................................................... 10 Third-Party Costs and Custodian Charges............................................ 10 Comparison to Other Firms ............................................................... 11 Item 6: Performance-Based Fees.......................................................... 11 Item 7: Types of Clients ...................................................................... 11 4 | P a g e  Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 Item 8: Investment Strategies, Methods of Analysis, and Risk of Loss....... 11 Investment Strategy ........................................................................ 11 Portfolio Design and Implementation .................................................. 12 Tax Efficiency and Rebalancing .......................................................... 12 Alternative Investments.................................................................... 13 Separately Managed Accounts ........................................................... 13 Risk Management ............................................................................ 13 Understanding the Risk of Loss .......................................................... 13 Summary........................................................................................ 14 Item 9: Disciplinary Information........................................................... 14 Item 10: Other Financial Industry Activities and Affiliations ..................... 14 Item 11: Code of Ethics, Client Transactions and Personal Trading ........... 15 Code of Ethics ................................................................................. 15 Recommendations of Securities and Material Financial Interests ............ 15 Participation in Client Transactions..................................................... 15 Item 12: Brokerage Practices............................................................... 16 Designated Brokers .......................................................................... 16 Custodian Selection.......................................................................... 16 Directed Brokerage .......................................................................... 16 Soft Dollar Arrangements.................................................................. 16 Trade Aggregation and Allocation....................................................... 17 Monitoring and Oversight .................................................................. 17 Item 13 Retirement Plan Rollovers........................................................ 17 Item 14: Review of Accounts ............................................................... 18 Review of Accounts .......................................................................... 18 Regular Portfolio Reports .................................................................. 18 Rebalancing .................................................................................... 18 Tax Loss Harvesting ......................................................................... 19 Item 15: Custody ............................................................................... 19 Item 16: Investment Discretion ........................................................... 20 5 | P a g e  Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 Item 17: Voting Client Securities.......................................................... 20 Item 18: Financial Information............................................................. 20 Additional Information ...................................................................... 21 Business Continuity.......................................................................... 21 Information Security ........................................................................ 21 Client Privacy .................................................................................. 21 Brochure Supplement ......................................................................... 23 Item 2: Educational Background and Business Experience ....................... 23 Item 3: Disciplinary Information........................................................... 24 Item 4: Other Business Activities.......................................................... 24 Item 5: Additional Compensation ......................................................... 24 Item 6: Supervision ............................................................................ 24 6 | P a g e  Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 Item 4: Advisory Business Overview Cardiff Park Advisors is an SEC-registered investment advisor headquartered in Southern California. We provide integrated wealth management services to high net-worth individuals, families, trusts, and foundations across the United States and internationally. Clients include both U.S. and non-U.S. clients living or working abroad, who rely on Cardiff Park Advisors for U.S.- based investment oversight and cross-border coordination. As of June 30, 2025, Cardiff Park Advisors manages approximately $2.8 billion in client assets on a non-discretionary basis. Our core services include financial planning and portfolio management. These services are delivered through a structured, client-centered framework that aligns planning and investment strategy with each client’s goals and evolving needs. Cardiff Park does not prepare tax returns or draft legal documents. However, when warranted, we will work closely with other professionals serving our clients, including trust & estate attorneys, CPAs, insurance brokers, and real estate professionals. Our role is to help integrate the work of these specialists into a unified financial framework. We participate in planning conversations, review legal and tax documents, and flag opportunities that may otherwise be overlooked. By staying aligned with a client’s professional team, we aim to bring clarity and cohesion to the decision-making process. We also recognize the importance of professional boundaries. By respecting each service provider’s domain while remaining strategically involved, we reduce the risk of conflict and reinforce the value of coordinated, high- quality expertise across disciplines. This structure helps ensure that our clients receive advice that is technically sound and aligned with their long- term financial goals. Principal Owner and Business Team Cardiff Park Advisors was established in 2003 and has served clients continuously for more than 23 years. The firm remains independently owned and fully integrated, operating under a philosophy that ensures strategic alignment, in-house execution, and personalized client service. 7 | P a g e  Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 John Gorlow is the founder, president, chief investment officer, and chief compliance officer. He directs the firm’s investment strategy and wealth management process and serves as the primary advisor for most client relationships. All core functions, including financial planning, portfolio construction, risk oversight, and client reporting, are managed in-house under Mr. Gorlow’s leadership. The Cardiff Park team supports each relationship with close coordination, operational discipline, and attention to detail. Account execution, recordkeeping, and administrative support are handled in direct coordination with custodians such as Schwab and Fidelity to ensure security and efficiency. Wealth Management Services We seek a comprehensive understanding of each client’s financial structure, including liquid assets, retirement accounts, real estate holdings, private investments, pension income, business cash flows, and human capital. This foundational insight enables us to create customized portfolios to hedge liabilities, meet essential spending needs, and fund longer-term goals. The aim is to deliver higher-confidence outcomes, a more grounded investment experience, and greater potential for long-term wealth creation. Our investment strategies emphasize global diversification, long-term discipline, and tax efficiency. We build portfolios using third-party mutual funds and ETFs, including those offered by Dimensional Fund Advisors (Dimensional), Avantis Investors, and select index-tracking funds from Vanguard, Schwab, and Fidelity among others. This work is supported by integrated cash flow modeling, investment planning, and coordinated distribution strategies—all with the aim of ensuring capital is aligned with timing, purpose, and risk. Allocations are made with each of these factors in mind. We provide ongoing portfolio oversight, disciplined rebalancing, tax-aware adjustments, and proactive communication. Item 5: Our Fees General Cardiff Park operates under a straightforward retainer model. We charge an annual fee that reflects the level of work and responsibility involved in each client relationship. This structure supports ongoing financial planning, 8 | P a g e  Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 portfolio oversight, and coordinated implementation across the client’s full financial picture. Initial Evaluation We start with an initial evaluation to assess fit and share early insights into the client’s financial picture. This typically includes one or two meetings and a review of relevant materials. In some cases, we may request additional information to support a more thoughtful analysis. To proceed beyond this phase, clients are asked to enter a formal engagement. Annual Retainers Most new client engagements today fall within an annual retainer range of $8,000 to $14,000. Fees are billed quarterly, in arrears, and are adjusted based on the scope and complexity of each relationship. For larger or more complex situations — including multi-generational families or business entities — retainers may exceed this range and are customized to reflect the level of services provided. These retainers are periodically reviewed and may be adjusted to reflect changes in scope, complexity, or inflation. Any updates are communicated prior to year-end and take effect at the start of the following calendar year. We recognize that many long-standing client relationships were established under earlier pricing structures. These are periodically reviewed and adjusted with care and transparency. Onboarding Fees To cover the up-front work required to initiate the relationship—linking accounts, organizing financial data, configuring systems, and establishing the structure and direction needed to move forward—we charge a one-time onboarding fee. This fee typically ranges from $1,800 to $3,600 and is discussed and agreed upon in advance. Separately Billed Services Some services involve a level of complexity or coordination that falls outside the scope of the standard retainer. These services are priced separately. They may include bond ladder construction, restricted stock liquidation planning (e.g., in merger-related contexts), estate settlement administration, and financial restructuring due to divorce or re-partnering. Where appropriate, we offer a fixed quote in advance. In cases where hourly billing is warranted, we apply a standard rate of $450, always with prior discussion and agreement. 9 | P a g e  Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 Family Member Accounts When clients request portfolio management for adult children or other family members, we evaluate the scope of involvement and determine an appropriate fee structure. In some cases, these accounts may be covered under the primary retainer; in others, a separate engagement is warranted. Each situation is assessed individually, with clear communication and fairness. Billing of Advisory Fees Advisory fees accrue daily and are billed quarterly in arrears. The first billing period for clients will be prorated. Invoices are sent electronically and may also be mailed upon request. New clients are asked to authorize direct debiting from a custodial account, which simplifies administration. Existing clients are also encouraged to pay through direct debiting, but may continue to pay by check, ACH, or bill-pay. Cancellation and Termination Our agreement may be terminated at any time with 30 days’ written notice. We will continue servicing the account until the termination date and issue a final prorated invoice. Any remaining obligations become the client’s responsibility. 12B-1 Fees and Sales Commissions Cardiff Park operates exclusively as a fee-only advisory firm. We do not accept commissions, 12b-1 fees, revenue sharing, referral fees, or any form of third-party compensation. Our compensation derives solely from the clients we serve, ensuring that our advice is objective, transparent, and aligned with their best interests. Professional integrity and transparency are fundamental underpinnings of our business. Clients can be confident that every recommendation we make is guided solely by what’s best for them, rather than by outside incentives. Third-Party Costs and Custodian Charges Clients may incur third-party costs related to fund management or custodial services. These include internal fund expenses, wire fees, and transaction charges. We do not receive any portion of these costs. Our investment approach aims to keep these costs low. Clients transferring accounts may face termination fees from prior firms, typically $0–$200. We encourage confirming these costs directly. 10 | P a g e  Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 Comparison to Other Firms Cardiff Park operates solely as a fiduciary, charges a fixed retainer, and provides services on a non-discretionary basis. We don’t promote proprietary products or accept third-party compensation. Our recommendations are rooted in academic research, implemented with low-cost, tax-efficient strategies, and delivered with full transparency. Our process is clear and client-focused. The result is a disciplined, cost-effective approach to wealth management, aligned with our clients’ goals and free from conflicts of interest. Item 6: Performance-Based Fees Cardiff Park does not charge performance-based fees. Such fees are generally calculated as a percentage of capital gains or appreciation in a client’s account, and are common among hedge fund operators, private equity underwriters, and their affiliated investment advisors or sales professionals. Performance-based fees can create conflicts of interest when an advisor's financial incentives do not align with the client’s best interests. We believe a transparent, fixed-fee model avoids conflicts of interest and promotes alignment with our clients. All clients are treated equally under our fee schedule. Item 7: Types of Clients Our clients value clarity, discipline, and a long-term perspective. We advise high-net-worth individuals, multigenerational families, trusts, estates, retirement plans, charitable organizations, and private entities. Our clients typically have portfolios of $3 million or more. Most are U.S. citizens, though we also serve foreign nationals and expatriates, coordinating as needed with international custodians and outside advisors. Item 8: Investment Strategies, Methods of Analysis, and Risk of Loss Investment Strategy At Cardiff Park, we believe capital markets work. Prices reflect available information, and while short-term movements are unpredictable, disciplined 11 | P a g e  Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 investors are rewarded over time. Our strategy emphasizes diversification, consistency, and patience—as opposed to speculation. We avoid tactics like market timing and individual stock selection. Instead, we focus on persistent drivers of long-term returns, including broad market exposure and well-documented factors such as company size, relative value, and profitability. This approach is grounded in academic research and honed through decades of practical application. Our objective is simple: to help clients build resilient, cost-effective portfolios that can navigate uncertainty and deliver meaningful long-term outcomes. Portfolio Design and Implementation We build portfolios from the ground up, beginning with a strategic allocation between equities and fixed income that reflects each client’s objectives, cash flow needs, time horizon, and risk capacity. Our goal is to design resilient, tax-aware portfolios that remain effective across changing market conditions. We start with broad market exposure through low-cost index tracking funds from providers like Vanguard, Schwab, and Fidelity. These vehicles offer efficient, diversified access to global capital markets. From there, we further diversify across well-documented sources of expected return—company size, relative price, and profitability—using structured strategies from Dimensional Fund Advisors (Dimensional) and Avantis Investors. Each component plays a distinct role in the portfolio, contributing to a cohesive, evidence-based investment framework. For fixed income, we combine bond funds and ETFs with individual securities when appropriate. These may include U.S. Treasuries, municipal bonds, agency notes, investment-grade corporate bonds, FDIC-insured CDs, and inflation-protected instruments. Fixed income design is tailored to tax considerations, liquidity needs, and the client’s preference for direct holdings versus pooled exposure. Tax Efficiency and Rebalancing Tax awareness is integral to our investment approach. We coordinate portfolios across taxable and tax-deferred accounts, strategically placing assets to improve after-tax returns and support efficient rebalancing. Our rebalancing process is disciplined, opportunistic, and cost-conscious, designed to manage drift, harvest losses, and preserve long-term tax advantages without unnecessary churn. 12 | P a g e  Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 Alternative Investments We may incorporate alternative investments to further diversify client portfolios. These include publicly traded real estate investment trusts (REITs), gold, precious metals, commodity-linked ETFs, and crypto-oriented strategies. We view these assets as complementary—uncorrelated to traditional stocks and bonds—and potentially valuable in specific portfolio contexts. Recommendations in this space are made with care and intention, based on alignment with the client’s long-term objectives and overall asset allocation. Separately Managed Accounts In some cases, clients may wish to engage an unaffiliated investment manager to oversee a portion of their portfolio. When this occurs, Cardiff Park facilitates communication to ensure that the manager’s style, discipline, and cost structure align with the client’s goals. While we cannot be responsible for performance of unaffiliated accounts, we will monitor performance and progress to ensure that the strategy complements the investment framework that we manage for our clients. Risk Management Our portfolios are designed to manage uncertainty, not to eliminate it. Our first layer of diversification spans core sectors: equities, fixed income, cash, and alternatives. Within each sector, we diversify across geographic categories, incorporating asset classes with distinct characteristics and roles. This structure allows us to align capital with intended purpose, liquidity needs, and time horizon. We select high-quality holdings and seek tax- efficient implementation. Where appropriate, we incorporate public market alternatives that can serve as ballast or offer differentiated return potential. Through this layered construction and ongoing oversight, we help clients remain invested through periods of volatility while maintaining confidence in the integrity of the strategy. Understanding the Risk of Loss All investments involve risk, including the potential for loss. Periods of volatility are inevitable. We help clients anticipate and plan for these events so they can remain focused and invested when it matters most. While historical evidence supports the outperformance of value stocks, small caps, and emerging markets over long periods, each may underperform for years at a time. Bonds can also decline in value during rising interest rate environments or under credit stress. 13 | P a g e  Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 Beyond traditional market risks, clients must also contend with broader systemic forces that may include economic disruption, inflation, political instability, climate-related events, and cyber threats. No strategy is immune to these realities. But by staying grounded in what works—diversification, tax efficiency, and long-term discipline—we help clients navigate uncertainty with confidence. Summary Our investment strategy is deliberate, disciplined, and research-driven. Rather than chasing short-term outcomes, our portfolios are built to serve each client’s short-term needs and long-term goals. With deep attention to risk, tax planning, and long-term alignment, we help clients stay focused on building wealth over the course of a lifetime. Item 9: Disciplinary Information Cardiff Park Advisors has no legal or disciplinary events to disclose. Neither the firm nor any members of its management team have ever been subject to regulatory, civil, or criminal proceedings. We maintain a clean record and operate with the highest standards of fiduciary responsibility and professional conduct. Item 10: Other Financial Industry Activities and Affiliations Cardiff Park Advisors is fully independent and operates free of outside affiliations or brokerage entanglements. Neither the firm nor any members of our management team are engaged in business activities outside their roles at Cardiff Park. We are not affiliated with any broker-dealer, and no employee is a registered representative or has a pending application to become one. This independence ensures that our advice remains objective, free of conflicts-of-interest, and solely in service of our clients’ best interests. At a client’s direction, we may assist in selecting an unaffiliated investment manager to oversee a portion of their portfolio. In these cases, we maintain oversight, monitoring performance and alignment with the client’s goals to ensure consistency with the overall strategy. 14 | P a g e  Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 Item 11: Code of Ethics, Client Transactions and Personal Trading Code of Ethics At Cardiff Park, our Code of Ethics governs every aspect of our conduct. It reflects our commitment to the highest standards of integrity and our fiduciary responsibility to put clients’ interests first at all times. In compliance with SEC Rule 204A-1 under the Investment Advisers Act of 1940, all covered persons are required to observe federal securities laws and uphold the principles that define ethical advisory practice. We are committed to acting in our clients’ best interests with unwavering integrity, maintaining objectivity and independence in every recommendation, and continually advancing our knowledge in portfolio theory, asset allocation, and comprehensive financial planning. Our Code is available to any client or prospective client upon request. Recommendations of Securities and Material Financial Interests Cardiff Park does not engage in principal trades, cross trading, or agency cross transactions. In the rare event that an exception is considered, advance approval by the firm’s Chief Compliance Officer is required to preserve full transparency and protect client interests. Participation in Client Transactions Employees of Cardiff Park may invest in securities also recommended to clients. While this may create the appearance of a conflict, we have instituted strict controls to ensure that client interests always take priority. Employees and their immediate families are prohibited from transacting in any security that is being actively bought or sold for a client account. If Cardiff Park is recommending or executing a trade for a client, no employee may trade in that security until the client’s transaction has been completed or the recommendation is withdrawn. We maintain comprehensive oversight and reporting procedures to monitor employee transactions. Exceptions are limited to specific cases—such as trades in accounts over which the employee has no control, trades in highly liquid securities where individual activity has no market impact, and transactions involving U.S. government obligations, CDs, high-quality short- term debt, or registered open-end mutual funds. 15 | P a g e  Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 All exceptions must be documented, reviewed, and justified to ensure alignment with our ethical standards and our clients’ best interests. Item 12: Brokerage Practices Designated Brokers At Cardiff Park, we place a premium on clarity, consistency, and institutional-grade service. To support this, we typically recommend that client accounts be held at Charles Schwab or Fidelity Investments—two of the most trusted and capable custodians in the industry. These firms offer secure custody, low-cost execution, robust infrastructure, and reliable support for portfolio management, trade execution, and reporting. We are not affiliated with Schwab or Fidelity and receive no compensation, soft-dollar arrangements, or revenue-sharing of any kind. Our recommendation is based solely on the strength of their platforms and their ability to support a professional, streamlined experience for clients and advisors alike. Custodian Selection While clients may request to use another custodian, we strongly encourage them to work with Schwab or Fidelity to ensure operational continuity, simplified oversight, and full integration with our advisory systems. Their scale, independence, and institutional capabilities allow us to focus on delivering consistent, high-quality service. Directed Brokerage We do not permit directed brokerage arrangements. All trades are placed through the client’s designated custodian, which ensures fair pricing, consolidated oversight, and efficient coordination across accounts. This structure helps eliminate conflicts of interest and promotes the best execution of every transaction. Soft Dollar Arrangements At Cardiff Park, we do not participate in soft dollar arrangements. We do not accept research, technology, or operational support in exchange for trading volume or custodial relationships. These arrangements—common in parts of the investment industry—create potential conflicts of interest, obscure the true cost of services, and compromise the objectivity clients deserve. While custodians and fund providers may broadly offer access to research tools, technology platforms, or educational content, we maintain strict 16 | P a g e  Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 policies to ensure these non-monetary benefits are not tied to any product recommendation or business commitment. Our independence is deliberate and uncompromising. We are aligned solely with our clients, and every decision we make reflects that commitment. Trade Aggregation and Allocation When appropriate, we aggregate trades across accounts to secure pricing efficiency and operational consistency. All trades are allocated fairly and without preference. We do not receive additional compensation from block trading or allocations. Our approach is systematic, transparent, and governed by firm policy. Monitoring and Oversight We routinely monitor the quality of trade execution to ensure that our clients receive competitive pricing, timely settlement, and institutional execution standards. Schwab and Fidelity are held to the same expectations: performance, reliability, and service. Item 13 Retirement Plan Rollovers When leaving an employer, clients generally have several options for managing assets in an employer-sponsored retirement plan. These may include leaving the assets in the former employer’s plan (if permitted), rolling them into a new employer’s plan (if available), transferring them to an Individual Retirement Account (IRA), or cashing out the account. Each option involves trade-offs related to fees, investment flexibility, tax treatment, and access to funds. In some cases, a combination of options may be appropriate. If Cardiff Park recommends rolling over assets into an account under our management, that recommendation may result in new or increased compensation to the firm. This creates a potential conflict of interest. We do not receive commissions or third-party compensation and do not act as a product distributor. We encourage clients to carefully evaluate all available options and, where appropriate, consult with outside professionals before proceeding with a rollover decision. Our goal is to provide objective guidance and ensure that clients receive advice aligned with their best interests. 17 | P a g e  Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 Item 14: Review of Accounts Review of Accounts One of our primary objectives is to ensure that each client’s portfolio remains firmly aligned with their long-term goals and investment strategy. To that end, we provide detailed portfolio reporting and maintain open lines of communication for ongoing review, clarification, and course-correction as needed. Regular Portfolio Reports Cardiff Park provides continuous oversight of client accounts and delivers detailed portfolio reports through our secure client portal. Beginning in September 2025, these reports will be issued quarterly, aligning with our long-term investment philosophy and reducing the distraction of short-term performance noise. Clients will receive their final monthly report in August 2025, with the first quarterly report (covering July through September) delivered in early October. While quarterly reporting is the default, clients who prefer monthly updates may continue to receive them upon request. Rebalancing Rebalancing is a core component of portfolio discipline. This is the process of realigning asset exposures to remain consistent with target allocations, which in turn helps manage risk and maintain intended portfolio characteristics. But rebalancing must be applied thoughtfully. It it’s too frequent, it may create friction from trading costs and taxes; if too infrequent it may allow “drift” that dilutes portfolio intent. We monitor portfolios for deviations from strategic targets, whether across high-level equity/fixed income splits or more granular asset class weights. Rebalancing is typically triggered when these exposures exceed predefined thresholds, with sensitivity to each client’s tax position, transaction costs, and liquidity needs. Where possible, we add to existing holdings rather than initiate new positions—unless otherwise dictated by tax considerations, wash-sale constraints, fund closures, or strategic fund changes. Market movements and cash flows may also create efficient opportunities to restore balance. Rebalancing decisions are implemented with care and clarity. All recommendations are reviewed with the client and approved before 18 | P a g e  Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 execution. We do not apply a one-size-fits-all rule; our process is responsive, efficient, and aligned with each client’s investment philosophy. Tax Loss Harvesting We monitor taxable portfolios for opportunities to harvest losses as part of a broader effort to improve after-tax outcomes. When requested, we evaluate potential trades, identify suitable replacement holdings, and coordinate with clients to ensure alignment with their goals. This service is performed upon client request. Item 15: Custody Cardiff Park does not accept custody of client assets, except in limited cases where clients have provided explicit written instructions to transfer, withdraw, or otherwise move cash or securities to another firm or third party. Cardiff Park does not deduct advisory fees from client accounts without the client’s explicit, written consent. While we generally request authorization to debit fees directly for efficiency, this is never assumed or automatic. Every fee arrangement is fully disclosed, clearly documented, and implemented only after the client’s express approval. All account statements, trade confirmations, and tax documents are issued directly by the custodian—typically Schwab or Fidelity—who maintains custody of the assets. To ensure accuracy and transparency, we strongly encourage clients to review their custodial statements and compare them to the reports provided by Cardiff Park. If clients identify any unauthorized activity—including unrecognized trades or transfers—they should immediately contact John Gorlow, Chief Compliance Officer, at 1-800-332-2238, and also notify the custodian holding their assets. Cardiff Park has never had an instance of theft or misappropriation of client funds. For assistance with custodial matters or account-related issues, clients are welcome to contact us directly. We can facilitate prompt coordination with the appropriate team at the custodian to resolve any concerns. 19 | P a g e  Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 Item 16: Investment Discretion Cardiff Park manages all client accounts on a non-discretionary basis. Every relationship begins with client authorization—granted through a limited power of attorney (LPOA)—which empowers us to act efficiently on the client’s behalf. There are no exceptions; we would not be able to do our job without this authority. That said, authority never replaces accountability. Clients remain in control and are always able to see exactly where they stand. With the LPOA agreement in place, we take over day-to-day execution of a client’s detailed plan, which includes implementing investment strategies, managing fixed income ladders, rebalancing portfolios, and deploying capital. All actions are firmly rooted in the investment framework built in partnership with the client, such as defining credit quality, maturity targets, tax preferences, and overall objectives. Item 17: Voting Client Securities We believe clients should retain full authority over decisions related to the securities they own, including the right to vote on corporate matters. For this reason, Cardiff Park does not vote proxies on behalf of clients. All proxy materials and related solicitations are delivered directly to clients by their custodian or the issuing transfer agent. Clients are solely responsible for reviewing and responding to these materials. While we do not assume voting authority, we are always available to discuss proxy-related issues or help clients interpret materials. We welcome the opportunity to support clients in making informed decisions, particularly when those decisions may have implications for their broader investment strategy. Item 18: Financial Information Cardiff Park may accept limited discretion over client accounts, as outlined in Item 16 of this brochure. In accordance with regulatory requirements, we are obligated to disclose any financial condition that could impair our ability to meet our fiduciary or contractual obligations to clients. We are pleased to confirm that no such condition exists. 20 | P a g e  Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 A balance sheet is not included with this brochure, as Cardiff Park does not maintain custody of client funds or securities, and we do not require or solicit prepayment of advisory fees. All fees are billed in arrears, consistent with our commitment to transparency and accountability. Additional Information At Cardiff Park, we take seriously our responsibility to safeguard client assets, maintain uninterrupted service, and protect client privacy. The following supplemental information outlines key protocols that support these commitments. Business Continuity We have a formal business continuity plan in place to ensure ongoing operations in the event of a natural disaster, cyberattack, or other disruption. The plan includes redundant systems, offsite data storage, and a designated alternate work location. If our primary office becomes inaccessible, we are committed to re-establishing contact with clients within five business days and resuming normal operations with minimal interruption. Information Security Cardiff Park employs rigorous security measures to protect against unauthorized access, data loss, or cyber breaches. To date, we have not experienced any compromise of client data. Our systems are protected by multiple layers of defense, including encryption, intrusion detection, and restricted access protocols. Nonetheless, we recognize that no system is immune to cyber risk. In the event of a breach, we will act swiftly to contain the threat, notify affected parties, and restore functionality. We also encourage clients to take full advantage of security features offered by custodial platforms, including two-factor authentication and password management tools. Client Privacy Cardiff Park collects nonpublic personal and financial information necessary to design, manage, and monitor client portfolios. We do not disclose this information to unaffiliated third parties unless required by law. Access is restricted to employees directly involved in providing service. We maintain physical, digital, and procedural safeguards to ensure compliance with federal privacy regulations and industry best practices. 21 | P a g e  Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 END PART 2A FORM ADV 22 | P a g e  Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 John Gorlow Brochure Supplement 2B of Form ADV Cardiff Park Advisors, LLC 7161 Aviara Drive Carlsbad, CA 92011 Phone: (760) 635-7526 Fax: (760) 284-5550 Website: http://cardiffpark.com Email: jgorlow@cardiffpark.com June 30, 2025 This Brochure Supplement provides information about John Gorlow that supplements the Cardiff Park Advisors, LLC (“Cardiff Park”) brochure (Part 2A of Form ADV). If you did not receive a copy of the Part 2A brochure or if you have any questions about the contents of this supplement, please contact us using the information provided below. Additional information about John Gorlow is available on the SEC’s website at www.adviserinfo.sec.gov Item 2: Educational Background and Business Experience John Gorlow, age 66, is the Founder and Chief Executive Officer of Cardiff Park Advisors, LLC. He established Cardiff Park in 2003, drawing on more than 20 years of experience in the financial services industry. The firm was registered with the U.S. Securities and Exchange Commission in May 2006. Prior to establishing Cardiff Park, John served as an investment advisor at Ernst & Young in San Francisco, managing advisory engagements for private clients. Earlier, he spent 14 years with leading Wall Street firms—including Merrill Lynch, Lehman Brothers, and Oppenheimer—delivering personal investment management services to private client groups. 23 | P a g e  Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 John holds an MBA from Fordham University and a Bachelor’s degree from Penn State University. He earned the Certified Investment Management Analyst® (CIMA®) designation through the Wharton School of the University of Pennsylvania. He is a member of both the CFA® Institute and the Financial Planning Association (FPA). Item 3: Disciplinary Information None Item 4: Other Business Activities None Item 5: Additional Compensation None Item 6: Supervision As CEO, John Gorlow provides supervisory oversight for all aspects of Cardiff Park’s operations, including investment management, client service, reporting, and compliance. While he is ultimately responsible for all firm activities, our internal processes and workflows are designed to ensure high standards, independent review, and regulatory compliance. For supervisory questions or concerns, please contact us at the phone number or email listed on the cover page of the Part 2A Brochure. 24 | P a g e  Cardiff Park Advisors, LLC Form ADV Part 2A SEC File Number CRD Number 126752 801-66660 END PART 2B FORM ADV 25 | P a g e