FINANCIAL COUNCIL, LLC

Item 1 – Cover Page Form ADV PART 2A Brochure Financial Council, LLC 100 West Road, Suite 504 Towson, Maryland 21204 Phone: (410) 821-9200 September 5th, 2025 This brochure provides information about the qualifications and business practices of Financial Council, LLC [“Financial Council” or “Adviser”], formerly known as Financial Council Asset Management, Inc. or FCAM. If you have any questions regarding the contents of this Brochure, please contact us at (410) 821-9200 and/or via electronic mail at jodig@financialcouncil.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. Financial Council is a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. Additional information about Financial Council is available on the SEC’s website at www.adviserinfo.sec.gov. Free and simple tools are available to you to review Financial Council and its financial professionals at Investor.gov/CRS, which also provides free educational materials about broker-dealers, investment advisers, and investing. 1  Item 2 – Material Changes Below is a summary of changes made to this brochure since it was last updated on March 28th, 2025.  Item 14 was updated to include information on a new forgivable loan from LPL Financial This item discusses only specific material changes that are made to the Brochure since its last update. Minor updates and clarifications occur throughout this document and we encourage you to review the full Brochure. Financial Council will ensure that you receive a summary of any material changes to this and subsequent Brochures promptly as necessary. A current Brochure and/or Form CRS may be requested, free of charge, by contacting us by phone at (410) 821-9200 or via email at jodig@financialcouncil.com. Additional information about Financial Council is available on the SEC’s websites adviserinfo.sec.gov and Investor.gov/CRS. The SEC’s websites also provide information about individuals affiliated with Financial Council who are registered as investment adviser representatives. 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 Fee Schedule for Advisory Services ........................................ 5 Item 6 – Performance-Based Fees and Side-By-Side Management ............................................... 7 Item 7 – Types of Clients ........................................................................................................................... 7 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................... 7 Item 9 – Disciplinary Information .......................................................................................................... 11 Item 10 – Other Financial Industry Activities and Affiliations ........................................................ 11 Item 11 – Code of Ethics .......................................................................................................................... 12 Item 12 – Brokerage Practices ............................................................................................................... 13 Item 13 – Review of Accounts ................................................................................................................ 16 Item 14 – Client Referrals and Other Compensation ........................................................................ 17 Item 15 – Custody...................................................................................................................................... 18 Item 16 – Investment Discretion ............................................................................................................ 19 Item 17 – Voting Client Securities ......................................................................................................... 19 Item 18 – Financial Information ............................................................................................................. 19   Item 4 – Advisory Business Financial Council was established in July 1995 as Financial Council Asset Management, Inc. ("FCAM”). As of July 1, 2023, FCAM was combined with its financial planner affiliate, Financial Council, Inc. and restructured to Financial Council, LLC ("Financial Council”, “Adviser”, or “the Firm”). Financial Council offers the advisory services described below primarily to individuals, trusts, estates, charitable organizations, and corporations. The firm is owned by William M. Leeb, President, Chief Compliance Officer and Chief Investment Officer, Jodi L. Greenlund, Chief Operating Officer, David R. Travis, Co-Chief Financial Officer, and Jeffrey R. Reynolds, Co-Chief Financial Officer. As of December 31, 2024 Financial Council managed discretionary client assets valued at $1,099,779,929. Portfolio Management Services Financial Council provides investment advisory services by developing a range of asset allocation models implemented primarily using mutual funds. Multiple asset allocation models are available depending on each client’s goals, risk tolerance and expectations. Such allocations are designed to support specific groups of clients that fit certain criteria – portfolios are not individually tailored. Clients may not impose restrictions on the allocations. Financial Council assists clients, by evaluating a client’s goals, risk tolerance and other factors, in selecting an appropriate allocation model or models. Specific asset management includes but is not limited to periodic rebalancing (or choosing not to rebalance, if conditions warrant) of the asset allocation models chosen by the client. Rebalancing is at the discretion of Financial Council, and is partially based on, but not limited to, market movement, market environment, client risk tolerance, client risk capacity, asset performance, percent to total deviation from allocation models and manager performance. Other parts of the asset management process include quarterly market commentary and the annual (or more frequent, at the discretion of the applicant) review of the investment and or allocation to fund managers. Fees for our asset management services are described in Item 5 of this brochure and are based on the level of assets in your managed account. IRA Rollovers As part of our advisory services, we may provide you with recommendations and advice concerning your employer retirement plan or other qualified retirement account (“Plan”). When appropriate, we may recommend that you withdraw the assets from your employer’s Plan and roll the assets over to an individual retirement account (“IRA”) to be managed by Financial Council. When Financial Council provides investment advice to clients regarding Plan accounts or IRAs, Financial Council is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. If you elect to roll Plan assets to an IRA under our management, we will charge you an asset-based fee as described in Item 5. This practice presents a conflict of interest because we have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if you do complete the rollover, you are under no obligation to have your IRA assets managed by Financial Council. You have the right to decide whether to complete the rollover and the right to consult with other financial professionals. Clients should thoroughly evaluate the material considerations used in making a rollover decision, including the availability of investment options, relative fees, statutory requirements and protections, and other services or options available through the Plan provider and the IRA account, respectively. It is important that you understand your options, their features, and their differences, and decide  whether a rollover is best for you. If you have questions, contact us at our main number listed on the cover page of this brochure. Prior to engaging Financial Council to provide any advisory services, clients first enter into an investment management agreement with Financial Council setting forth the terms and conditions under which Financial Council renders our services (the “Investment Management Agreement”). Please see items 12 and 14 of this Brochure for more detailed information our relationship with Commonwealth. Item 5 - Fees and Compensation Fee Schedule for Advisory Services Portfolio Management Services Clients who elect to receive asset management services through Financial Council’s asset management program will generally pay Financial Council for those services with an annual asset management fee based on a percentage of assets under management, including cash and money market positions. Clients are urged to carefully review and discuss the contents of this Brochure with their advisor, including descriptions of the program and services offered, the fees and charges clients will pay, the means by which Financial Council and your advisor are compensated, and the conflicts of interest that exist between the client and Financial Council and your advisor in respect to each program or service offered, to determine the most appropriate programs or services for your specific needs. The fee schedule for assets under management up to $500,000 is 1.25% of assets under management. The complete current fee schedule is as follows: The amount up to the first $500,000.00 On the next $500,000.00 to $1,000,000.00 Amounts from $1,000,000.01 to $3,000,000.00 Amounts from $3,000,000.01 to $7,500,000.00 Amounts from $7,500,000.01 to $50,000,000.00 Amounts from $50,000,000.01 and up 1.25% per year 1.00% per year 0.75% per year 0.50% per year 0.25% per year Negotiable EXAMPLE: an account valued at $1,500,000 would pay 1.25% on the first $500,000, 1.00% on the next $500,000 and 0.75% on the remaining $500,000 for an effective aggregate, or average, fee rate of 1.00%. In addition to the annual management fee, and unless otherwise agreed between the client and the advisor, clients will pay charges as described in the “Other Fees and/or Costs” section below. Clients may pay more or less than they might otherwise pay if purchasing the services separately. There are several factors that determine whether such costs would be more or less, including, but not limited to, the size of the account; the types of securities and strategies involved; the amount of trading effected; and the actual costs of such services if purchased separately Financial Council advisory fees are negotiable as indicated in the fee schedule above. Program and/or platform fees (if applicable), transaction charges and other account-related fees assessed by the account custodian or Commonwealth are not negotiable. Financial Council may waive all or a portion of the advisory fee, whether on an ongoing or a one-time basis, in its sole discretion. In the event a client terminates an advisory agreement with Financial Council, any unearned fees resulting from payments made by clients in advance will be refunded to the client.  Payment of Advisory Fees Commonwealth performs fee billing on our firm’s behalf. Fees are collected in arrears, i.e., fees are collected based on the period just ending and not in advance of the upcoming quarter period. Managed account fees are typically automatically charged to the client’s account pursuant to instructions provided to the account custodian by Financial Council. Fees are deducted from client assets. If the advisory relationship is terminated by either party (within 30 days written notice by one to the other), fees for the current billable period will not be charged. The specific way fees are charged by Financial Council is described in a client’s written agreement with Financial Council. Financial Council allows for the aggregation of assets among a client’s “related” managed accounts for purposes of determining the applicable advisory fee to be paid by a client. We reserve the right to determine whether client accounts are “related” for purposes of aggregating a client’s accounts together for a reduction in the percentage fee amount. Billing groups are established and maintained by Financial Council. Financial Council rebates to client accounts any mutual fund 12(b)-1 fees, where applicable, as they are paid by the applicable mutual fund and collected by Financial Council. These rebates appear as a separate credit in client accounts. Financial Council fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which can be incurred by the client. Clients will incur certain charges imposed by custodians, brokers and other third parties such as fees charged by custodians, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. These fees are in addition to the advisory fees charged by Financial Council. Client portfolios are invested in mutual funds and ETFs as part of Financial Council’s investment strategy in order to gain access to certain sectors, markets, or securities. Investments in mutual funds however, generally include an embedded investment management fee paid to the investment adviser of the mutual fund, as well as other fees and expenses associated with the mutual fund, with the exception of 12b-1 fees as described above. As such, Client portfolios with investments in mutual funds are subject to two layers of management fees on that portion of their account invested in mutual funds: Fees charged by Financial Council, and fees charged by the mutual fund’s investment manager. Financial Council clients are responsible for all fees and expenses charged by the mutual fund in addition to the management fee charged by Financial Council. Account values in the Commonwealth reporting system will be used for our firm’s quarterly fee calculations for advisory accounts custodied at National Financial Services (NFS). Although account holdings and asset valuations should generally match, month-end market values reflected in Commonwealth's Practice 360 reporting system sometimes differ from those provided by NFS on their month-end statements. The three most common reasons why these values may differ are (i) differences in the manner in which accrued interest is calculated, (ii) differences in the date upon which "as of" dividends and capital gains are reported, and (iii) differences in whether settlement date valuations or trade date valuations are used. If you have any questions or believe there are material discrepancies between your NFS custodial statement and Commonwealth's reporting system, please contact us. The Commonwealth report valuations are available online via your Investor360 account or you may request a copy from your advisory representative. For California Residents: Subsection (j) of Rule 260.238 of the California Code of Regulations requires that all investment advisers disclose to their advisory clients that lower fees for comparable services may be available from other sources.  For District of Columbia Residents: Section 1811.1 Subsection (j) of the DC Rules requires Financial Council to disclose that lower fees for comparable services may be available from other sources. Subsection (k) requires Financial Council to indicate that all material conflicts of interest that relate to the advisor or to any of its employees, and that would cause Financial Council not to render unbiased and objective advice, have been disclosed to the client in writing via the disclosure provided in this Form ADV Part 2. For Massachusetts Residents: Massachusetts General Law Section 203A requires disclosure that information about the disciplinary history and the registration of Financial Council and its associated persons may be obtained by contacting the Public Reference Branch of the SEC at 202.942.8090, or by contacting the Massachusetts Securities Division at One Ashburton Place, 17th Floor, Boston, MA 02108 or at 617.727.3548. Item 12, Brokerage Practices, further describes the factors used in selecting or recommending broker- dealers for client transactions, including related conflicts of interest, and determining the reasonableness of their compensation. Item 6 – Performance-Based Fees and Side-By-Side Management Financial Council does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). Item 7 – Types of Clients Financial Council offers advisory services primarily to individuals, trusts, estates, charitable organizations, and corporations. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Investing in securities involves risk of loss that investors should be sure they understand and should be prepared to bear. Financial Council provides investment advisory services by developing a range of asset allocation models implemented primarily using mutual funds. Multiple asset allocation models are available depending on each client’s goals, risk tolerance and expectations. Such allocations are designed to support specific groups of clients that fit certain criteria – portfolios are not individually tailored. Clients may not impose restrictions on the allocations. As a firm, Financial Council does not favor any specific method of analysis over another and, therefore, would not be considered to have one approach deemed to be a “significant strategy.” There are, however, a few common approaches that may be used by us or your advisor, individually or collectively, in the course of providing advice to clients. It is important to note that there is no investment strategy that will guarantee a profit or prevent loss. Following are some common strategies employed by advisors in the management of client accounts:  Dollar Cost Averaging (“DCA”): The technique of buying a fixed dollar amount of a particular investment on a regular schedule, regardless of the share price. More shares are purchased when prices are low, and fewer shares are bought when prices are high. DCA is believed to lessen the risk of investing a large amount in a single investment at higher price. DCA strategies are not effective and do not prevent loss in declining markets.   Asset Allocation: An investment strategy that aims to balance risk and reward by allocating assets among a variety of asset classes. At a high level, there are three main asset classes— equities (stocks), fixed income (bonds), and cash/cash equivalents—each of which has different risk and reward profiles/behaviors. Asset classes are often further divided into domestic and foreign investments, and equities are often divided into small, intermediate, and large capitalization. The general theory behind asset allocation is that each asset class will perform differently from the others in different market conditions. By diversifying a portfolio of investments among a wide range of asset classes, advisors seek to reduce the overall volatility and risk of a portfolio through avoiding overexposure to any one asset class during various market cycles. Asset allocation does not guarantee a profit or protect against loss.  Fundamental Analysis: A method of evaluating a security that entails attempting to measure its intrinsic value by examining related economic, financial, and other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect the security’s value, including macroeconomic factors (e.g., the overall economy and industry conditions) and company-specific factors (e.g., financial condition and management). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security’s current price, with the aim of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short). This method of security analysis is considered to be the opposite of technical analysis.  Qualitative Analysis: Securities analysis that uses subjective judgment based on non- quantifiable information, such as management expertise, industry cycles, strength of research and development, and labor relations. This type of analysis technique is different from quantitative analysis, which focuses on numbers. The two techniques, however, are often used together. Financial Council will obtain comprehensive investment information about the prospective client, record such information on the financial planning or other questionnaire, and assist clients in evaluating their goals, risk tolerance and other factors and selecting an appropriate allocation model or models. Financial Council will use this information to monitor the ongoing activity in the client’s account and ensure that such activities are in accordance with the financial requirements and investment objectives shown in information obtained and documented in client interviews. Specific asset management includes but is not limited to; periodic rebalancing (or choosing not to rebalance, if conditions warrant) of the asset allocation models chosen by the client. Rebalancing is at the discretion of Financial Council, and is partially based on, but not limited to, market movement, market environment, client risk tolerance, client risk capacity, asset performance, percent to total deviation from allocation models and manager performance. Other parts of the asset management process include quarterly market commentary and the annual (or more frequent, at the discretion of the applicant) review of the investment / fund managers allocated. Material Risks The list of risk factors below is not a complete enumeration or explanation of the risks involved in an investment through Financial Council or any of the client portfolios it manages. It is possible that some of the investment vehicles and direct investments selected by Financial Council will not meet all the above criteria, and that some or all the investments selected by Financial Council will not perform as anticipated. Depending on conditions and trends in the financial and securities markets and the economy in general, Financial Council may pursue any objectives, employ any investment techniques or purchase any type of security that it considers appropriate and in the best interests of clients that may not be described subject to restrictions imposed by clients. There can be no assurance that the  Financial Council’s investment strategy will achieve profitable results, and results may vary substantially over time. Past performance of a portfolio or past performance of Financial Council or its affiliates are not indicative of future results. Investors risk the loss of their entire investment. Note that the risks below are also applicable to the extent that a mutual fund recommended by Financial Council holds the types of securities described below. Common Stock Risk. Common stock risks include the financial risk of selecting individual companies that do not perform as anticipated, the risk that the stock markets in which a portfolio invests may experience periods of turbulence or instability, and the general risk that domestic and global economies may go through periods of decline and cyclical change. Small and Mid-Cap Stock Risk. Companies with small and medium market capitalizations are relatively small compared to large-capitalization companies; they may be engaged in business mostly within their own geographic region; and may be less well known to the investment community. Also, these companies often have less liquidity, less management depth, narrower market penetrations, less diverse product lines and fewer resources than larger companies. As a result of these factors, small and mid- capitalization stock prices have greater volatility than large company securities. Growth Stock Risk. Financial Council may invest in companies or mutual funds that contain what appear to be growth- oriented companies. If perceptions of a company’s growth potential are wrong, the securities purchased may not perform as expected, reducing a client portfolio’s return. Bond Risks. Also known as corporate debt securities, bonds are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default, when the bond is set to mature, and whether the bond can be “called” prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same rate of return. Money Market Fund Risks: A money market fund is a security and thus there is a risk of loss of principal, although it is generally rare. In return for this risk, you should earn a greater return on your cash than you would expect from a FDIC-insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or down. If it goes down and you earn less than you expected, you may end up needing more cash. Finally, because money market funds are considered to be safer than other investments (like stocks), long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods of time, inflation can act as a material drag on your returns. Mutual funds and ETFs: Mutual funds and ETFs are managed collective investments that pool money from many investors and invest in other securities. A fund will have a manager that trades the fund’s investments in accordance with the fund’s investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, uses leverage (i.e., borrows) to a significant degree, or concentrates in a particular type of security. ETFs differ from mutual funds in that they can be bought and sold throughout the day like stock and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are “no load,” meaning there’s no fee to buy into or sell out of the fund, other types of mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be “closed-end” or “open- end.” Open-end mutual funds continue to allow new investors indefinitely, whereas closed-end funds have a fixed number of shares to sell, which can limit their availability to new investors. Interest Rate Risks. The prices of, and the income generated by, most debt and equity securities will most likely be affected by changing interest rates and by changes in the effective maturities and credit ratings of these securities. For example, the prices of debt securities generally decline when interest rates rise and increase when interest rates fall. In addition, falling interest rates may cause an issuer to redeem, “call,” or refinance a security before its stated maturity date, which would typically result in having to reinvest the proceeds in lower-yielding securities.  Credit Risks. Debt securities are also subject to credit risk, which is the possibility that the credit strength of an issuer will weaken and/or an issuer of a debt security will fail to make timely payments of principal or interest and the security will go into default. Liquidity Risk. The risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or it may not be possible to sell the investment at all. Certain structured products, interval funds, and alternative investments are less liquid than securities traded on an exchange, and you should be aware of the fact that you may not be able sell these products outside of prescribed time periods. You should consult your advisor prior to purchasing products considered illiquid and in instances where changes in your financial situation and objectives may increase your need for liquidity. Inflation Risk. Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client’s future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many types of fixed income investments to decline. Foreign Securities Risk. Investments in foreign securities involve greater risks compared to domestic investments for the following reasons: foreign companies may not be subject to the regulatory requirements of United States companies, so there may be less publicly available information about foreign issuers than United States companies; foreign companies generally are not subject to uniform accounting, auditing and financial reporting standards; foreign countries may offer limited investor protections or place limitations on shareholder rights and remedies, particularly for foreign investors; dividends and interest on foreign securities may be subject to foreign withholding taxes and such taxes may reduce the net return to client accounts; and foreign securities are often denominated in a currency other than the United States dollar. Accordingly, client portfolios will be subject to the risks associated with fluctuations in currency values. Issuers of foreign securities may still be subject to the risk of expropriation, confiscation, taxation, currency blockage, or political or social instability, any of which could negatively affect client portfolios. Emerging Markets Risk. Risks described above for Foreign Securities Risk are applicable in emerging markets, and are typically more pronounced. Additionally, investments in developing countries may experience high rates of inflation or sharply devalue their currencies against the United States dollar, causing the value of investments in companies located in those countries to decline. Transaction costs are often higher in developing countries, and there may be delays in the settlement process. Currency Risks. Investments may also be affected by currency controls; different accounting, auditing, financial reporting, disclosure, and regulatory and legal standards and practices; expropriation (occurs when governments take away a private business from its owners); changes in tax policy; greater market volatility; different securities market structures; higher transaction costs; and various administrative difficulties, such as delays in clearing and settling portfolio transactions or in receiving payment of dividends. These risks may be heightened in connection with investments in developing countries. Investments in securities issued by entities domiciled in the United States may also be subject to many of these risks. Portfolio Turnover Risk. A mutual fund selected by Financial Council may engage in aggressive portfolio trading, and could, thus, experience high turnover. A high rate of portfolio turnover in any year may increase brokerage commissions paid and could generate greater taxes for client portfolios on realized investment gains. Investment Concentration. At times, a substantial portion of a portfolio’s assets may be invested in the securities of a limited number of issuers, including mutual funds. Investing a significant portion of a portfolio’s assets in a single issuer will make the portfolio susceptible to a greater degree than would otherwise be the case to risks affecting investments in such issuer. Such concentration of investments will increase the volatility of the value of the portfolio’s portfolio investments. Management Risk. Client portfolios are subject to management risk because they are actively managed by Financial Council. Financial Council will apply its investment techniques and risk  analyses in making investment decisions for client portfolios, but there is no guarantee that its decisions will produce the intended result. Risks Related to Regulation. Laws and regulations affecting our business change from time to time, and we are currently operating in an environment of significant regulatory reform, both in the U.S. and globally. We cannot predict the effects, if any, of future legal and regulatory changes on our business or the services we provide. Risks Related to Technology and Cyber Security. We and our clients depend heavily on telecommunication, information technology and other operational systems, whether ours or those of others (such as custodians, financial intermediaries, transfer agents and other parties to which we or they outsource the provision of services or business operations). These systems may fail to operate properly or become disabled as a result of events or circumstances wholly or partly beyond our or their control. Further, despite implementation of a variety of risk management and security measures, our information technology and other systems, and those of others, could be subject to physical or electronic break-ins, unauthorized tampering or other security breaches, resulting in a failure to maintain the security, availability, integrity and confidentiality of data assets. Technology failures or cyber security breaches, whether deliberate or unintentional, including those arising from use of third- party service providers or client usage of systems to access accounts, could have a material adverse effect on our business or our clients and could result in, among other things, financial loss, reputational damage, regulatory penalties or the inability to transact business. Reliance on Key Management Personnel - The success of Financial Council’s investment strategies will depend, in substantial part, upon the skill and expertise of Mr. Leeb. The death, disability or departure of whom may adversely affect our business and performance. Any of the common risks described above could adversely affect the value of your portfolio and account performance, and you can lose money. Even though these risks exist, Financial Council and your advisor will still earn the fees and other compensation described in this Brochure. Clients should carefully consider the risks of investing and the potential that they may lose principal while we and your advisor continue to earn fees and other forms of compensation. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of the Adviser or the integrity of its management. Financial Council has no applicable disciplinary information Item 10 – Other Financial Industry Activities and Affiliations William Leeb, President, Chief Compliance Officer, and Chief Investment Officer, David R. Travis, Co- Chief Financial Officer, and Jeffrey R. Reynolds, Co-Chief Financial Officer, are FINRA-registered broker-dealer representatives and investment adviser representatives of Commonwealth Financial Network (“Commonwealth”), an SEC-registered investment adviser and FINRA-registered broker dealer. As registered representatives and investment advisor representatives of Commonwealth, William Leeb, David Travis, and Jeffrey Reynolds are required to place all Financial Council client brokerage business through Commonwealth. Additionally, as representatives of Commonwealth they receive commissions on investment products sold or placed through Commonwealth not related to Financial Council and also receive commissions and/or renewals on various insurance products that they solicit. This is in addition to any compensation received from Financial Council. Additional information about Commonwealth is available on FINRA’s BrokerCheck at brokercheck.finra.org. Clients are under no obligation to purchase or sell securities through Commonwealth.  As a practice, clients of Financial Council pay no commissions or transaction fees for funds traded in their Financial Council portfolios, as transaction fees and commissions are rebated back to clients. Trading costs are ultimately borne by Financial Council. As a general practice Financial Council does not accept client directed broker arrangements. However, any client who directs Financial Council to use a specific broker may pay higher commission rates or receive less favorable execution on same transactions than non-directing clients, at least in part because the directed broker may maintain a higher commission schedule. In such instances where the client directs Financial Council to use a specific broker, the commission rate may be negotiated by the client or by the Financial Council depending on the arrangement, or client instructions. Financial Council compensates approved, properly licensed solicitors and investment adviser representatives of Commonwealth up to 90% of the fee collected for the referral of clients to Financial Council and for performing certain administrative tasks and for conducting the annual client review and update. Endorsers of Financial Council have entered into and are bound by a Endorser’s Agreement with Financial Council. Reference Item 14 below. Item 11 – Code of Ethics The Financial Council Code of Ethics is designed to ensure that the personal securities transactions, activities and interests of the employees and owners of Financial Council do not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. In addition, the Code of Ethics describes Financial Council’s standard of business conduct and fiduciary duty to its clients. It includes provisions relating to the confidentiality of client information, a prohibition on insider trading, preclearance of certain securities, reporting of securities holdings and transactions, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, among other things. Financial Council has also outlined sanctions for failing to comply with these policies and procedures. Financial Council and its principals may, from time to time, buy or sell the same securities recommended to clients in their own account(s). All related persons are required to submit personal securities logs every month for review by the CCO. Any conflicting transactions of a related person are denied. A copy of Financial Council’s Code of Ethics is available on request. Specific to ERISA, IRA, Roth IRA, Keogh, or 401K accounts (“Retirement Investor”). Financial Council confirms that with respect to Retirement Investors it is acting as a fiduciary as defined by the Department of Labor and that advice is based on the investment needs of the advice recipient. As a fiduciary, Financial Council complies with the following Impartial Conducts Standards:  Financial Council will act in the best interest of client. This is defined as acting with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk tolerance, financial circumstances and needs of the Retirement Investor, without regard to the financial or other interests of Financial Council, or any affiliate, related entity or other party.  Compensation received by Financial Council (or its affiliates or related entities) with respect to any  recommended transactions will be reasonable. Financial Council and its employees will not make any materially misleading statements to the Retirement Investor about recommended transactions, fees and compensation, conflicts of interest and any other matters relevant to the Retirement Investor's investment decisions.  Insider Trading Policy Financial Council has adopted an "Insider Trading” policy in accordance with Section 204A of the Investment Advisers Act of 1940, which prohibits the misuse of material nonpublic information by Financial Council and all of its employees. In addition, the code of ethics contains restrictions on using inside information to engage in any personal transactions or to disclose any material nonpublic information. Any Financial Council officer, employee or other access person who fails to observe the above-described policies risks serious sanctions, including dis- missal and personal liability. Financial Council provides a copy of the Code of Ethics to any client or prospective client upon request. To obtain a copy of Financial Council’s code of ethics, please contact Jodi Greenlund, Client Service Liaison, by phone at (410) 821-9200 or via e-mail at jodig@financialcouncil.com. Item 12 – Brokerage Practices As disclosed previously in this brochure, our advisors are dually registered with Commonwealth Financial Network. Commonwealth policy restricts its advisors from conducting securities transactions away from Commonwealth unless Commonwealth provides the advisor with written authorization. Therefore, clients are advised that our advisors are substantially always limited to conducting securities transactions through Commonwealth and its clearing firms, National Financial Services LLC (“NFS”) and Pershing. Substantially all of Financial Councils clients must select Commonwealth as the broker/dealer of record and NFS as the clearing firm for their managed accounts. In all cases, the account custodian will be identified in the respective managed account client agreement. Client transactions will be charged according to Commonwealth's then-current commission schedule and clients may pay higher commission rates and other fees than otherwise available. The client may be assessed transaction or other fees charged by Commonwealth, custodians and/or product sponsors, in addition to normal and customary commissions, all of which are fully disclosed to the client. These fees and expenses are separate and distinct from any fee(s) charged by Financial Council. This additional compensation received by Commonwealth creates a conflict of interest. Additionally, by using Commonwealth as the broker/dealer for Financial Councils managed account program(s), Financial Councils may be unable to achieve most favorable execution of client transactions, which may cost clients more money. Financial Council attempts to mitigate this conflict of interest by engaging in a regular review of our relationship with Commonwealth to ensure that the costs incurred are reasonable in comparison to industry norms, and by advising our clients that you are not obligated to open an account with us or Commonwealth; you may open an account and implement advice provided by Financial Council with the firm of your choice. Our clients do not generally have the option to direct securities brokerage transactions to other broker/dealers or other account custodians. If, however, a client should request, and Commonwealth approve, the use of a broker/dealer other than NFS or Pershing for securities transaction execution, the client should be aware that Financial Council will generally be unable to negotiate commissions or other fees and charges for the client’s account, and Financial Council would not be able to combine the client’s transactions with those of other clients purchasing or selling the same securities (“batched trades”), as discussed further below. As a result, Financial Council would be unable to ensure that the client receives “best execution” with respect to such directed trades. Financial Council may also be unable to provide timely monitoring of transaction activity or provide the client with quarterly performance reporting.  How We Select Brokers/Custodians We seek to use a custodian/broker who will hold your assets and execute transactions on terms that are, overall, most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others:  Combination of transaction execution services and asset custody services  Capability to execute, clear and settle trades (buy and sell securities for your account)  Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, etc.)  Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], limited partnerships)  Availability of investment research and tools that assist us in making investment decisions.  Quality of services  Competitiveness of the price of those services and willingness to negotiate the prices  Reputation, financial strength, and stability  Prior service to us and our other clients  Availability of other products and services that benefit us Products and Services Available to Us from Commonwealth and Our Custodians Commonwealth Financial Network provides Financial Council with various products and services that enable us to both serve our clients and grow our business. Commonwealth (through their disclosed clearing relationships with National Financial Services and Pershing) provide us and our clients with access to its brokerage services— trading, custody, reporting, and related services. Commonwealth also makes available various support services. Some of those services help us manage or administer our client accounts, while others help us manage and grow our business. Following is a more detailed description of Commonwealth’s support services: Services That Benefit You Commonwealth’s brokerage services include access to a broad range of investment products, execution of securities transactions by Commonwealth’s clearing firms, and custody of client assets via their clearing firms. The investment products available through Commonwealth include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Services That Do Not Directly Benefit You Commonwealth also makes available to us other products and services that benefit our firm and our advisors but do not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Commonwealth’s and that of third parties. We use this research to service substantially all our client accounts, including accounts not maintained at Commonwealth. In addition to investment research, Commonwealth also makes available software and other technology that:  Provide access to client account data (such as duplicate trade confirmations and account statements)  Facilitate trade execution  Provide pricing and other market data  Facilitate payment of our fees from our client accounts   Assist with back-office functions, recordkeeping and client reporting Services That Generally Benefit Only Us Commonwealth also offers other services intended to help us manage and further develop our business enterprise. These services include:  Complimentary or discounted attendance at conferences and events  Consulting on technology, compliance, legal and business needs  Publications and conferences on practice management and business succession Best Execution A registered investment adviser has a duty to attempt to obtain the “best execution” for its clients’ securities transactions. As such, an adviser should periodically and systematically evaluate the performance of the broker/dealer executing its client’s transactions. The term “best execution” is meant to include not only commission expense, but to encompass the overall execution of the securities transaction. Since trading is a repetitive, continuous process, each trade communicates information about an adviser’s underlying trading procedures. This information can then be used to evaluate whether an investment manager is consistently seeking to achieve best execution and whether he/she is meeting that objective. In summary, “best execution” refers to a well-designed trade execution process made with the intention of maximizing the value of client portfolios under the circumstances at the time. Financial Council periodically reviews its brokerage practices to assess our broker’s contribution to meeting our duty to provide best execution. As advisory clients pay no commission, this assessment is driven largely by qualitative factors as described above under How We Select Brokers/Custodians. No single criteria will validate nor invalidate a broker, but rather, all criteria taken together will be used in evaluating the currently utilized custodian. Mutual fund share class selection Mutual funds offer various share classes with each structured for investors with certain restrictions, and distinct fees and expenses associated with that class. Financial Council endeavors to select for its clients the best share class available to the client when purchasing mutual fund securities. Financial Council takes into consideration fees, loads, purchase, sale and other restrictions prior to purchasing any specific class of shares for its clients in an effort to obtain the best share class option for each clients’ specific investment needs. Block Trading Policy Financial Council may aggregate (“bunch”) transactions in the same security on behalf of more than one client in an effort to strive for best execution and to possibly reduce the price per share. However, aggregated or bunched orders will not reduce the transaction costs to participating clients. Typically, the process of aggregating client orders is done in order to achieve better execution, to negotiate more favorable commission rates or to allocate orders among clients on a more equitable basis in order to avoid differences in prices and transaction fees or other transaction costs that might be obtained when orders are placed independently. Financial Council conducts aggregated transactions in a manner designed to ensure that no participating client is favored over another client. Participating clients will obtain the average share price per share for the security executed that day. To the extent the aggregated order is not filled in its entirety and when possible, securities purchased or sold in an aggregated transaction will be allocated pro-rata to the participating client accounts in  proportion to the size of the orders placed for each account. The amount of securities maybe increased or decreased to avoid holding odd-lot or a small number of shares for particular clients. It should be noted, Financial Council does not receive any additional compensation or remuneration as a result of aggregation. Advisory clients purchase funds at net asset value. Core Account Sweep Programs (“CASPs”) Through our relationship with Commonwealth, our firm has access to a core account sweep program (“CASP”). CASP is the core account investment vehicle for eligible accounts used to hold cash balances while awaiting reinvestment. The cash balance in your eligible accounts will be deposited automatically or “swept” into interest-bearing FDIC-insurance eligible deposit accounts at one or more FDIC-insured financial institutions The interest rates for your eligible accounts may be obtained from at www.commonwealth.com/clients/deposit-sweep-program.aspx. Specific features and account eligibility of CASP are further explained in the Disclosure Document provided to clients that participate in CASP. A current version of the CASP Disclosure Document is available at https://www.commonwealth.com/for-clients/disclosure/core-account-sweep-programs. Clients should note that, though the default options for cash held in accounts are the core account investment vehicles, clients may at any time seek higher yields in other available investment options. Commonwealth keeps a portion of the interest paid by the bank(s) participating in CASP as a fee for providing bank sweep services. This fee reduces the rate of interest you receive on your cash in the bank sweep program. Financial Council receives no financial benefits from the CASP program. We encourage our clients to review CASP program details to understand how Commonwealth and the program banks get paid for the sweep program and to discuss other available investment options should you wish to do so. Trade Errors At no time will Financial Council’s clients be disadvantaged by trade errors. All errors in client accounts will be recorded and resolved in the client’s favor as soon as practicable. Financial Council will maintain a list of trading errors relating to client accounts. The list will detail the transaction date of the trading errors, securities involved, broker-dealer involved, and a summary of the error and its solution. If any financial disbursements were made to the client or to Financial Council as a settlement of the trading error, they will be disclosed detailing the amount in the list of trading errors relating to client accounts. The investment advisory services provided by Financial Council may cost the client more or less than purchasing similar services separately. Clients should consider whether the appointment of Commonwealth as the sole broker/dealer may result in certain costs or disadvantages to the client as a result of possibly less favorable executions. Factors to consider include the type and size of the account and the client’s historical and expected account size or number of trades. Item 13 – Review of Accounts Model allocation portfolios are reviewed no less than annually by an Investment Advisor Representative (IAR) of the firm and are representative of the client portfolios under management. Individual client portfolios are reviewed no less than quarterly. Triggers that may cause management activity include fund or asset style drift, management changes at the fund company level, asset class percent to total deviation of +/- 5%; domestic and global economic indicators, domestic and /or global  events (natural or man-made), as well as any other situation that may impact the integrity of a client’s stated risk tolerance, capacity or financial goals/needs. The Investment Review Committee is composed of William M. Leeb, President, Chief Compliance Officer, and Chief Investment Officer, David R. Travis, Co-Chief Financial Officer and Jeffrey R. Reynolds, Co-Chief Financial Officer. Accounts are reviewed with the client and updated no less than annually or as the situation demands or warrants. Regular Reports Provided to Clients Financial Council provides quarterly account summary and performance reports in addition to those reports and statements provided by those custodians, trust companies, mutual funds, record keepers, and broker-dealers that are included in the client’s portfolio. Financial Council urges all clients to carefully review their custodial statements and compare the official custodial records to Financial Council reporting. Adviser statements may vary from custodial statements based on various factors including accounting procedures, reporting dates, non-managed assets held by the custodian, or valuation methodologies of certain securities. Especially with regard to cost basis, Financial Council recommends that clients rely on the statements of their qualified custodian. Item 14 – Client Referrals and Other Compensation Financial Council receives an economic benefit from Commonwealth in the form of the support, products and services Commonwealth makes available to us and other investment advisors whose clients maintain their accounts on Commonwealth’s platform. These products and services, how they benefit us, and the related conflicts of interest are described in Item 12 of this brochure. Our access to Commonwealth’s products and services is not conditioned on our firm or our advisors giving particular investment advice, such as buying particular securities for our clients. Product vendors recommended by Financial Council may provide monetary and non-monetary assistance for the purposes of funding marketing, distribution, business and client development, educational enhancement and/or due diligence reviews incurred by Financial Council or our advisors relating to the promotion or sale of the product vendor’s products or services. We do not select products as a result of the receipt or potential receipt of any monetary or non-monetary assistance. Financial Councils due diligence of a product does not take into consideration any assistance it may receive. While the receipt of products or services is a benefit for you and us, it also presents a conflict of interest. We attempt to mitigate this conflict of interest by: • • • Informing you of conflicts of interest in our disclosure document and agreement; Maintaining and abiding by our Code of Ethics which requires us to place your interests first and foremost; Advising you of the right to decline to implement our recommendations and the right to choose other financial professionals for implementation. Commonwealth offers our firm and our firm’s advisory representatives one or more forms of financial benefits based on our advisory representatives’ total AUM held at Commonwealth or financial assistance for advisory representatives transitioning from another firm to Commonwealth. The types of financial benefits Commonwealth provides include, but may not be limited to forgivable or unforgivable loans provided at below-market rates, equity ownership investments into our firm’s business, discounts or waivers on transaction, platform, and account fees, technology fees, research  licensing and package fees, financial planning software fees, administrative fees, brokerage account fees, account transfer fees, insurance costs, referral fees for recruiting new advisors to Commonwealth, and the cost of attending conferences and events. The financial benefits that our firm or our advisory representatives may receive from Commonwealth are a conflict of interest and provide a financial incentive for our firm and our advisory representatives to select Commonwealth as broker/dealer for your accounts over other broker/dealers from which we may not receive similar financial benefits. We attempt to mitigate this conflict of interest by disclosing the conflict in this brochure and engaging in a regular review of our relationship with Commonwealth to ensure the relationship continues to be appropriate in all respects for our firm’s clients. In connection with the acquisition of Commonwealth by LPL Financial Holdings, Inc. (“LPLH”), on August 1, 2025, Financial Council, LLC advisors received loans that are forgiven over a multi-year term subject to continued affiliation with Commonwealth, LPL Financial, LLC (“LPL”), a subsidiary of LPLH, or LPLH’s affiliates after the acquisition. The existence of the loans presents a conflict of interest in that our firm and/or our advisors have a financial incentive to maintain our relationship with LPL and/or Commonwealth. However, to the extent we direct clients to LPL and/or Commonwealth for services, it is because the firm believes that it is in that client’s best interest to do so given our regular review of the firm’s relationship with Commonwealth and/or LPL. Use of Endorsers In certain cases, Financial Council pays a percentage of the management fee for client referrals. Financial Council adheres to the safe harbor conditions found in Rule 206(4)-1 under the Investment Advisers Act of 1940. At the time of the endorsement , each prospective client will receive a copy of the endorser’s written disclosure document, which includes:       The name of the endorser; The name of the investment adviser to whom clients are being referred (Financial Council); The nature of the relationship between the adviser and the endorser; A statement that the endorser is being compensated for referring the client to the adviser; The terms of the compensation arrangement between the adviser and the endorser; and, Whether or not the client is going to have to pay more in fees than he/she would otherwise have to pay had there been no endorser’s compensation. Financial Council compensates Financial Council-approved, properly licensed endorsers and investment adviser representatives of Commonwealth and Financial Council acting as endorsers up to 90% of the fee collected for the referral of clients to the Firm and for performing certain administrative tasks and for conducting the annual client review and update. Endorsers of Financial Council have entered into and are bound by an Endorsers Agreement with Financial Council. Item 15 – Custody Financial Council does not maintain physical custody of any client funds or securities. However, the Firm is deemed to have custody of client assets despite not having physical custody in certain instances. For example, if clients authorize the Firm to deduct advisory fees directly from client accounts or clients establish certain first party and/or any third-party standing letters of authorization (SLOAs) for the Firm to move money from an advisory account to a different account, Financial Council is deemed to have custody. Financial Council complies with certain safe harbor provisions that exempts the Firm from the annual surprise custody examination requirement for advisers that have custody due to the existence of SLOAs.  Financial Council clients receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains client’s investment assets. Financial Council urges clients to carefully review such statements and compare such official custodial records to the Financial Council performance reports. Financial Council reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Especially with regard to cost basis, Financial Council recommends that clients rely on the statements of their qualified custodian. Item 16 – Investment Discretion At the start of a client relationship, the client grants Financial Council the discretionary authority to manage a clients’ account by executing an asset management agreement. Investment discretion as to the type and quantities of securities to be bought and sold or exchanged is limited to those funds or securities that fit the client’s profile, based on the asset management agreement, risk tolerance, and capacity, prospectus receipt, client allocation model and to either rebalance the client portfolio, sell shares for client income needs, replace a fund or funds and/or managers, etc. Item 17 – Voting Client Securities As a matter of firm policy and practice, Financial Council does not accept any authority to and does not vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for all securities maintained in client portfolios. Financial Council may provide advice to clients regarding the clients’ voting of proxies. As a matter of firm policy, neither Financial Council nor its advisors have or will accept the authority to file class action claims on behalf of clients. This policy reflects Financial Council’s recognition that it does not have the requisite expertise to advise clients regarding participating in class actions. Financial Council and its advisors have no obligation to determine if securities held by the client are subject to a pending or resolved class action settlement or verdict. Financial Council and its advisors also have no duty to evaluate a client’s eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, Financial Council and its advisors have no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may have been injured because of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients. The decision to participate in a class action or to sign a release of claims when submitting a proof of claim may involve the exercise of legal judgment, which is beyond the scope of services provided to clients by Financial Council or your advisor. In all cases, clients retain the responsibility for evaluating whether it is prudent to join a class action or to opt out. Item 18 – Financial Information A registered investment adviser is required to provide you with certain financial information or disclosures about its financial condition. Financial Council 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.