FELDMAN, INGARDONA & CO.

Form ADV Part 2A Investment Advisor Brochure Feldman, Ingardona & Co. 2001 Butterfield Road, Suite 170 Downers Grove, Illinois 60515 (630) 663-1800 www.feldmaningardona.com September 16, 2025 This Form ADV Part 2A (Investment Advisor Brochure) provides information about the qualifications and business practices of Feldman, Ingardona & Co. If you have any questions about the contents of this brochure, please contact us at (630) 663-1800 and/or wfeldman@feldmaningardona.com. 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. Feldman, Ingardona & Co. is a registered investment advisor. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. Additional information about our firm is available on the SEC’s website at: www.adviserinfo.sec.gov. 1  Item 2 Material Changes Material changes to the ADV Brochure will be provided to clients who have received previous versions of brochure. There have been no material changes made to our ADV Brochure since our last other-than-annual amendment dated December 30, 2024. Within 120 days of our fiscal year end we will deliver our annual Summary of Material Changes if there have been material changes since the last annual updating amendment. 2  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 ............................................................................................................... 4 Item 6: Performance-Based Fees and Side-By-Side Management ....................................................... 5 Item 7: Types of Clients ............................................................................................................................ 5 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................................ 5 Item 9: Disciplinary Information ............................................................................................................. 6 Item 10: Other Financial Industry Activities and Affiliations ................................................................ 6 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...... 7 Item 12: Brokerage Practices ..................................................................................................................... 7 Item 13: Review of Accounts ...................................................................................................................... 8 Item 14: Client Referrals and Other Compensation ................................................................................ 8 Item 15: Custody ......................................................................................................................................... 8 Item 16: Investment Discretion .................................................................................................................. 9 Item 17: Voting Client Securities ............................................................................................................... 9 Item 18: Financial Information.................................................................................................................. 9 3  Item 4 Advisory Business Feldman, Ingardona & Co. is an investment advisory firm privately owned by William M. Feldman, the Chairman & Chief Executive Officer, Alex M. Ingardona, the President & Chief Operating Officer, Timothy M. Hart, Executive Vice President and Michael A. Ingardona, Vice President, that has been providing investment advisory services since 1997. Feldman, Ingardona & Co provides investment advisory services for portfolios of high-net-worth individuals and families, institutions, pension and profit-sharing plans, trusts and business entities. These services focus on the entire process of portfolio management by working with the client to organize the portfolio and develop an overall strategy to address the needs and investment objectives for the portfolio. The strategy includes a long-term strategic asset allocation, selection of investment managers and mutual funds to be used in the portfolio and performance measures according to which the overall portfolio and all investments for the portfolio will be monitored. The strategy is tailored to the individual needs and objectives of each client relationship. As such, clients may impose restrictions on investing in certain securities or types of securities that will be incorporated into the overall strategy. As of June 30, 2025, Feldman, Ingardona & Co. has $1,212,339,000 of assets under management on a discretionary basis and $521,227,000 of assets under management on a non-discretionary basis. Item 5 Fees and Compensation The fee schedule applicable as of this Brochure is as follows: Client Assets On the first $2,000,000 On the next $3,000,000 On the next $20,000,000 On all amounts in excess of $25,000,000 Annual Fee (%) for all assets 0.80% 0.50% 0.40% 0.30% These fees are for advisory services only and do not include any transaction fees or commissions, which may be charged separately by the client’s broker-dealer and custodial firm. Please see Item 12 - Brokerage Practices for more information. The specific manner in which fees are charged by Feldman, Ingardona & Co. is normally established in a client’s written investment advisory agreement. Generally, the fee will be payable quarterly in advance. The first payment is due and payable upon execution of the advisory agreement and will be assessed pro- rata in the event the agreement is executed other than the first day of the new calendar quarter. Subsequent payments are due and will be assessed on the first day of each calendar quarter based on the value of the portfolio as of the last day of the previous calendar quarter. Payment of fees may be paid direct by the client, or client may authorize the custodian holding client funds and securities to deduct advisory fees direct from the client account in accordance with the calculation prepared and submitted to the custodian by Feldman, Ingardona & Co. The custodian will provide periodic account statements to the client. Such statements will reflect all fee withdrawals by Feldman, Ingardona & Co. It is the client’s responsibility to verify the accuracy of the fee calculation. The custodian will not determine whether the fee is properly calculated. 4  In certain circumstances, advisory fees may be negotiated and may differ among clients based upon a number of factors, such as the number of investing entities or accounts in the investment portfolio and the complexity of the overall investment strategy. In addition to fees paid for advisory services, with respect to clients' investments in mutual funds, clients pay additional fees on the mutual fund investment because the mutual funds also pay advisory and/or management fees to an investment advisor. Clients are not obligated to use the services of the investment managers, mutual funds or any broker-dealer or custodian and may use any broker-dealer or custodian that they choose. Fees are not collected for services to be performed more than six months in advance. If termination occurs prior to the end of a calendar quarter, a pro-rata refund of unearned fees will be made to the client. Item 6 Performance-Based Fees and Side-By-Side Management Feldman, Ingardona & Co. does not charge performance-based fees, which is based on capital gains or capital appreciation of assets in the client account. Item 7 Types of Clients Feldman, Ingardona & Co. provides advisory services to high-net-worth individuals and families, institutions, pension and profit-sharing plans, trusts and business entities. Although minimum investment varies depending on the type of client and extent of services, generally the minimum account size is $5,000,000. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss As stated earlier under Item 4- Advisory Business, Feldman, Ingardona & Co. focuses on the entire process of portfolio management by working with the client to organize the portfolio and develop an overall strategy to address the needs and investment objectives for the portfolio. The strategy includes (1) a determination of the long-term strategic asset allocation for the portfolio, (2) the decision of whether to vary the asset allocation over shorter time periods, (3) the selection of the best and most cost-effective method to achieve the asset class returns incorporated in the long- term strategic asset allocation and (4) a comprehensive report to measure the portfolio’s investment performance against benchmark returns. The long-term asset allocation is a diversified mix of fixed income and equity asset classes that results in an overall portfolio with risk and return expectations that should address our client’s needs and investment objectives. Over shorter time periods, if agreed with the client, we may seek to enhance portfolio performance by opportunistically shifting the asset class mix of a portfolio in response to our assessment of relative rewards available in the capital markets. This tactical asset allocation process, which utilizes fundamental and technical analysis, adjusts the exposure to asset classes to percentages that vary from those of the long-term strategic asset allocation in order to attempt to capture incremental return for the portfolio. 5  The selection and oversight of investment managers to best achieve the asset class returns for the portfolio is generally implemented through mutual funds and exchange traded funds. Both active investment managers and passive, low-cost index funds are utilized to attempt to achieve or exceed the asset class benchmark returns used in the strategic asset allocation without undue risk and volatility. Our due diligence process incorporates ongoing quantitative and qualitative evaluation of the managers utilized within each client portfolio. On a quarterly basis, or if a significant change occurs in the operations of an investment manager (i.e., a change in portfolio manager), Feldman, Ingardona & Co. reviews every money manager employed in client portfolios. On a quarterly basis, or at any other interval the client requests, we prepare and deliver a written report that evaluates the performance of the overall portfolio. We evaluate the overall internal rate of return for the total portfolio against the results of its independent benchmark over various time periods. We also demonstrate the effect of any tactical asset allocation strategy produced when compared to the long-term strategic benchmark. The internal rates of return on each asset class within the portfolio are compared to their respective benchmark and peer group’s returns and each investment manager’s performance is compared against their assigned benchmark and peer group. We also present any recommendations for tactical strategy shifts to be made within the asset classes established by the long-term asset allocation. Additionally, we will present our trade recommendations to rebalance the portfolio to conform to the overall asset allocation. Any investment involves risk of loss that clients should be prepared to bear. There is no guarantee that the investment strategy selected for the client will result in the client’s goals being met, nor is there any guarantee of profit or protection from loss. Further, past performance is not indicative of future results and therefore, you should never assume that future performance of any specific investment or investment strategy will be profitable. For those investments sold by prospectus, such as mutual funds, clients should read the prospectus in full. Item 9 Disciplinary Information An investment advisor must disclose material facts about any legal or disciplinary event that is material to a client’s evaluation of the advisory business or of the integrity of its management personnel. Feldman, Ingardona & Co. has no events or information applicable to this item. Item 10 Other Financial Industry Activities and Affiliations Feldman, Ingardona & Co. is licensed as a business entity with the Illinois Department of Insurance. Mr. Austin E. L. Feldman, an employee of Feldman, Ingardona & Co., is qualified as an insurance producer for life contracts with the Illinois Department of Insurance. As such, Mr. Feldman may conduct certain insurance product transactions for our clients and Feldman, Ingardona & Co. would receive customary commissions for these transactions. In order to address this conflict of interest, we disclose to our clients any insurance commissions we would receive prior to implementing any insurance recommendations and in turn reduce the client advisory fee by that amount on a dollar-for-dollar basis. William M. Feldman, Alex M. Ingardona, Timothy M. Hart and Michael A. Ingardona are the owners of Strategic Tax Services LLC (STS), a tax return preparation company. Services provided by STS are separate and distinct from investment advisory services provided by Feldman, Ingardona & Co. and are offered at an additional cost. In order to address this conflict of interest, when we recommend STS to clients in need of tax preparation services, we also encourage them to evaluate other such providers. Our clients are not obligated to use STS for tax preparation and conversely no STS client is obligated to use our advisory services. There are no fee sharing or referral fee arrangements between STS and our firm. 6  Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Feldman, Ingardona & Co. has adopted a Code of Ethics that describes our high standard of business conduct and fiduciary duty to our clients. The Code of Ethics sets forth standards of conduct expected of advisory personnel; requires compliance with federal securities laws; and addresses conflicts that arise from personal trading by advisory personnel. Clients may request a copy of the Code of Ethics by contacting Mr. William Feldman. For purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. Feldman, Ingardona & Co. does not recommend securities in which we have a material financial interest. Feldman, Ingardona & Co. does not purchase any securities for its own account. Employees may invest in mutual funds, exchange traded funds and other investments which are also recommended for client portfolios. At the times employees take positions in the same securities as clients, we will try to avoid conflicts with clients. Employees will generally be “last in” and “last out” for the trading day when trading occurs in close proximity to client trades. We will not violate our fiduciary responsibilities to our clients. The monthly brokerage statements, which show all transactions of all employees of Feldman, Ingardona & Co., are reviewed by Mr. William Feldman, the Designated Compliance Officer. The brokerage statements of Mr. Feldman are reviewed by Mr. Ingardona. It is Feldman, Ingardona & Co.’s policy that the firm will not engage in any agency cross securities transactions for client accounts and not enter into principal transactions for client accounts. Item 12 Brokerage Practices Feldman, Ingardona & Co. does not recommend brokers-dealers to clients. Clients may choose any broker-dealer to have securities transactions executed through. The commission rates and fees charged by the broker-dealer the client selects will be negotiated solely by the client and may be higher or lower than commissions and fees paid if the transactions were executed through other broker-dealers. Clients may direct Feldman, Ingardona & Co. to effect transactions through any broker-dealers they choose. 7  Feldman, Ingardona & Co. does not receive and will not accept any compensation from any brokerage firm in the form of research, products or services (“soft dollars”). Feldman, Ingardona & Co. does not engage in the practice of directing brokerage commissions in exchange for the referral of advisory clients. Feldman, Ingardona & Co. does not aggregate client transactions. Client securities transactions generally involve mutual funds, which are not subject to aggregation, and exchange traded funds. If there would be an opportunity to lower client costs from aggregation, we are permitted to do so under the advisory agreement. Item 13 Review of Accounts The officers of Feldman, Ingardona & Co., Mr. William Feldman, Mr. Alex Ingardona, Mr. Hart and Mr. Michael Ingardona, are responsible for reviewing client investment portfolios at a minimum of once per quarter. Market conditions that might cause a wide variance in the overall asset allocation, or other factors, could cause a more frequent review. All clients receive standard account statements directly from custodians, investment sponsors and brokerage firms. Clients receive a written performance report from Feldman, Ingardona & Co. on a quarterly basis, or at any other interval the client requests, that provides a review of the client’s investment portfolio, including a review of asset allocation, performance comparisons for the client’s investment managers, the market value of all holdings and investment performance. Meetings with clients to discuss results, review objectives and discuss future strategy are scheduled according to the client’s wishes. Item 14 Client Referrals and Other Compensation Feldman, Ingardona & Co. does not compensate for client referrals. Feldman, Ingardona & Co. does not receive other compensation other than as disclosed in Item 5 - Fees and Compensation. Item 15 Custody Although client assets are held at third-party independent qualified custodians, Feldman, Ingardona & Co. is deemed to have custody of client funds because of the fee deduction authority granted by the client in the investment advisory agreement. Feldman, Ingardona & Co. is also deemed to have custody because certain clients have signed third party standing letters of authorization agreements (SLOAs) which permit us to submit instructions on their behalf for transfers of assets in accounts held at their qualified custodians. In accordance with guidance from the SEC, accounts with SLOAs are not subject to an annual surprise examination by an independent public accountant. Finally, Feldman, Ingardona & Co. is deemed to have custody because an employee acts as trustee for a client account. These trust accounts are subject to a surprise examination by an independent public accountant as required by the Advisers Act. 8  Clients will receive account statements at least quarterly directly from their broker-dealer or other qualified custodian. We urge our clients to compare the account statements they receive from qualified custodians with the statements prepared by Feldman, Ingardona & Co. for accuracy. Minor variations may occur because of reporting dates, accrual methods of interest and dividends, and other factors. The custodial statement is the official record for the client account for tax purposes. Item 16 Investment Discretion Under the investment advisory agreement, the client can choose to grant Feldman, Ingardona & Co. discretion to manage client investment portfolios as to securities and amount of securities. Clients can select whether to have their portfolios managed on a discretionary or non-discretionary basis under the agreement. Feldman, Ingardona & Co. will not have authority to withdraw funds or to take custody of client funds or securities, other than under the terms of the Fee clause in the investment advisory agreement with the client. Item 17 Voting Client Securities Feldman, Ingardona & Co. does not vote proxies for securities on behalf of our clients. It is the client's responsibility to vote proxies. Clients will receive proxy materials directly from the custodian. Questions about proxies may be made via the contact information on the cover page. Item 18 Financial Information Feldman, Ingardona & Co. has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. Feldman, Ingardona & Co. does not require or solicit prepayment of fees in excess of $1,200 per client more than six months in advance for services rendered; therefore, we are not required to include a balance sheet for our most recent fiscal year. 9