Foundry Financial LLC

Item 1: Cover Page Foundry Financial LLC Form ADV Part 2A Brochure Address: 479 S Marengo Ave Pasadena, CA 91101 Phone: (213) 802-8662 Email: hello@foundryfinancial.org Website: https://www.foundryfinancial.org/ This brochure provides information about the qualifications and business practices of Foundry Financial LLC. If you have any questions about the contents of this brochure, please contact us at the telephone number or email address listed above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Foundry Financial LLC is a registered investment adviser, but registration does not imply a certain level of skill or training. Additional information about Foundry Financial LLC is also available on the SEC’s website at www.adviserinfo.sec.gov and by searching for CRD# 300122. Page 1 of 21 Date of Brochure: September 1, 2026  Item 2: Material Changes In this Item, Foundry Financial LLC is only required to identify and discuss material changes since filing its last annual amendment. Since the firm’s last annual updating amendment filed on January 23, 2025, we have no material changes to report. Page 2 of 21 Date of Brochure: September 1, 2026  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes Item 3: Table of Contents Item 4: Advisory Business Item 5: Fees and Compensation Item 6: Performance-Based Fees & Side-By-Side Management Item 7: Types of Clients Item 8: Methods of Analysis, Investment Strategies & Risk of Loss Item 9: Disciplinary Information Item 10: Other Financial Industry Activities & Affiliations Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading Item 12: Brokerage Practices Item 13: Review of Accounts Item 14: Client Referrals and Other Compensation Item 15: Custody Item 16: Investment Discretion Item 17: Voting Client Securities Item 18: Financial Information 1 2 3 4 6 8 9 10 12 13 14 15 16 17 18 19 20 21 Page 3 of 21 Date of Brochure: September 1, 2026  Item 4: Advisory Business A. Foundry Financial LLC (the “Adviser,” “we,” “us,” or “our”) is an investment adviser founded in 2019, registered with the U.S. Securities and Exchange Commission (“SEC”), and principally owned by Kevin Lum. B. Adviser offers the following types of advisory services: i. Discretionary Investment Management. Adviser provides ongoing discretionary investment management services to its clients based upon each client’s current financial condition, goals, risk tolerance, income, liquidity requirements, investment time horizon, and other information that is relevant to the management of clients’ account(s). This information will then be used to make investment decisions that reflect clients’ individual needs and objectives on an initial and ongoing basis. Adviser’s investment decisions will allocate portions of clients’ account(s) to various asset classes classified according to historical and projected risks and rates of return. Adviser will retain the discretion to buy, sell, or otherwise transact in securities and other investments in a client’s accounts without first receiving the client’s specific approval for each transaction. Such discretionary authority is granted by a client in his or her investment management agreement with Adviser. Clients may impose restrictions on investing in certain securities or types of securities so long as such restrictions may reasonably be implemented by Adviser. Adviser generally implements its investments strategy by allocating clients’ investable assets across a diversified risk-based portfolio of no-load mutual funds and/or exchange traded funds (“ETFs”), stocks, bonds, certificates of deposit, municipal securities, and money market funds. ii. Financial Planning. When rendering financial planning services, Adviser will evaluate and make recommendations with respect to various financial planning topics that are relevant to a particular client. Such topics can include, for example, retirement planning, education savings, cash flow management, debt reduction, estate planning, insurance needs, risk mitigation, tax planning, charitable giving strategies, and/or financial goal tracking. Implementation of Adviser’s recommendations will be at the discretion of the client. When rendering financial planning services, a conflict exists between Adviser’s interests and the interests of its clients; clients are under no obligation to act upon Adviser’s financial planning recommendations. If a client elects to act on any of the recommendations made by Adviser, the client is under no obligation to effect the transaction through Adviser or any of its personnel. C. Pension Consulting Services. To the extent Adviser is retained by a defined contribution plan, defined benefit plan, or other employee benefit plan (a “Plan”), Adviser shall review the Plan’s investment objectives, risk tolerance, and goals, and shall work in partnership with applicable third-parties (such as the Plan’s recordkeeper, third-party administrator, and/or discretionary investment manager) to establish an appropriate investment policy statement and deploy applicable investment options into the Plan’s account. Adviser shall periodically review the investment options available to the Plan and, if applicable, will make recommendations to assist the Plan with respect to the selection of the Plan’s qualified default investment alternative (“QDIA”). Adviser will provide reports, information and recommendations, on a reasonably requested basis, to assist the Plan in monitoring the selected investments. If elected by the Plan, Adviser may also provide various services related to the Plan’s governance, the education of Plan participants, and the review of other service providers to the Plan. In connection with Plans subject to the Employee Retirement Income Security Act of 1974 (“ERISA”) and applicable provisions of the Internal Revenue Code of 1986, as amended (the “Code”) Adviser acknowledges that it is a fiduciary under ERISA and the Code, shall render prudent investment Page 4 of 21 Date of Brochure: September 1, 2026  advice that is in Plan’s best interest, shall avoid making misleading statements, and shall receive no more than reasonable compensation. D. Referral to Other Investment Advisers. From time to time and when appropriate for a prospective financial planning client, Adviser will refer prospective financial planning clients to an independent and unaffiliated third-party financial planner (“Third-Party Planner”) to provide ongoing financial planning services. As of the date of this brochure, we refer certain prospective financial planning clients to Domain Money Advisors LLC (“Domain Money”) as the Third-Party Planner. E. Selection of other investment advisers. From time to time and when appropriate for a particular client, we will recommend or retain an independent and unaffiliated third-party investment adviser (“Third-Party Adviser”) to manage and/or execute trades for all or a portion of a client’s portfolio. Third-Party Advisers are evaluated based on a variety of factors, not the least of which include performance return history, asset class specialization, management tenure, risk profile, and trade execution quality and efficiency. We will conduct due diligence as appropriate to confirm that such Third-Party Advisers are duly registered and otherwise well-equipped to manage and/or execute trades in applicable clients’ accounts. We generally retain the discretionary authority to hire or fire Third-Party Advisers with or without notice to the client. As of the date of this brochure, Adviser engages Sage Trading Collective, LLC (“Sage”) as a Third-Party Adviser. No additional fee is charged to clients when Sage is retained to manage and/or execute trades in their accounts, the fee charged by Sage in consideration of its services is paid directly by Adviser. F. Adviser does not participate in any wrap fee programs. G. 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 (“ERISA”) and/or the Internal Revenue Code (the “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: i. Meet a professional standard of care when making investment recommendations (give ii. iii. iv. 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 v. vi. Give you basic information about conflicts of interest. H. Adviser manages the following amount of discretionary and non-discretionary client assets calculated as of December 31, 2025: i. ii. iii. Discretionary: Non-Discretionary: Total: $232,611,535 $0 $232,611,535 Page 5 of 21 Date of Brochure: September 1, 2026  Item 5: Fees and Compensation A. Adviser is compensated for its advisory services primarily by fees charged based on a client’s assets under management with Adviser and/or flat fees. Fees are negotiable, and each client’s specific fee schedule is included as part of the investment advisory agreement signed by Adviser and the client. Investment Management Fees Adviser’s standard fee schedule for investment management services is included below, which is generally subject to a minimum annual fee of $10,000, applied in quarterly increments in arrears: Client Assets Under Management First $500,000 From $500,001 - $5,000,000 From $5,000,001 - $10,000,000 $10,000,001+ Annual Fee Percentage (paid quarterly) 1.25% 0.75% 0.50% 0.25% The fee schedule above is a “tiered” or “blended” fee schedule, which means that different annual fee percentages will apply to different ranges of client assets under Adviser’s management. Fees are typically deducted in arrears on a quarterly basis from clients’ assets and based upon the average daily balance of such assets managed by Adviser during the prior calendar quarter. Outstanding margin balances and cash are included in the assets upon which fees are assessed. Fees are prorated from the date a client’s assets are first designated to be under our management through the effective date of termination of the advisory agreement. In the event of termination of the advisory agreement, pro rata fees earned through the effective date of the termination will be billed to the client. Financial Planning Fees In consideration of its one-time financial planning services, Adviser generally charges a flat fee that ranges from $1,000 to $10,000 and that is dependent on the nature and complexity of a client’s specific financial situation and needs. Fifty percent (50%) of the fee is due upon execution of this Agreement, and the remaining fifty percent (50%) is due upon delivery of the financial plan. To the extent a financial planning engagement is terminated before delivery of the financial plan, Adviser shall charge a prorated portion of the flat fee depending on the percentage of the financial plan that has already been completed by Adviser. Financial planning fees are generally payable through a third-party payment processor or deducted directly from an account that is under Adviser’s discretionary management. Pension Consulting Fees In consideration of its pension consulting services, Adviser generally charges both an asset-based fee up to 1.00% per year to the Plan (as payable by Plan participants pro rata based on participants’ respective account balances) plus a one time or recurring fixed fee paid by the Plan sponsor up to $2,500 to $10,000 per year. The specific asset-based and fixed fee amounts, as well as the timing and mechanics of fee payments, are set forth in the retirement plan services agreement signed by a Plan. B. In addition to the fees charged by Adviser, clients will incur brokerage and other transaction costs. Please refer to Item 12: Brokerage Practices, for further information on such brokerage and other transaction-related practices. Depending on the specific investment products held in a client’s account and the services provided, a client may also incur additional fees and costs charged by Page 6 of 21 Date of Brochure: September 1, 2026  other independent and unaffiliated third-parties. Such additional fees and costs may include, but are not necessarily limited to, the internal fees and costs of an investment product (like a mutual fund or exchange traded fund), margin interest, account or asset transfer fees, subadvisory or third-party investment manager fees, account type fees, early redemption charges, market-maker or bid-ask spreads, retirement plan fees, trade-away or prime brokerage fees, fees for receiving paper copies of documents in lieu of electronically-delivered documents, and other fees and taxes on brokerage accounts and securities transactions. These additional charges are separate and apart from the fees charged by Adviser. Lower fees for comparable services may be available from other sources. C. Neither Adviser nor any of its supervised persons accepts compensation for the sale of securities or other investment products. Page 7 of 21 Date of Brochure: September 1, 2026  Item 6: Performance-Based Fees & Side-By-Side Management Neither Adviser nor any of its supervised persons accepts performance-based fees (fees based on a share of capital gains or capital appreciation of the assets of a client). Neither Adviser nor any of its supervised persons engage in side-by-side management. Page 8 of 21 Date of Brochure: September 1, 2026  Item 7: Types of Clients Adviser generally provides its services to individuals, high-net-worth individuals, and charitable organizations. Adviser does not require a minimum account value to open or maintain an account. Page 9 of 21 Date of Brochure: September 1, 2026  Item 8: Methods of Analysis, Investment Strategies & Risk of Loss A. The investment strategies used by Adviser when formulating investment advice or managing assets include fundamental analysis, technical analysis, cyclical analysis, charting analysis, and passive investment management. Investing in securities involves risk of loss that clients should be prepared to bear. Past performance does not guarantee future returns. B. Like any investment strategy, ours involve material risks. Such material risks are described in further detail below: i. Investing for the long term means that a client’s account will be exposed to short-term fluctuations in the market and the behavioral impulse to make trading decisions based on such short-term market fluctuations. Adviser does not condone short-term trading in an attempt to “time” the market, and instead coaches clients to remain committed to their financial goals. However, investing for the long term can expose clients to risks borne out of changes to interest rates, inflation, general economic conditions, market cycles, geopolitical shifts, and regulatory changes. ii. Inflation risk is the risk that the value of a client’s portfolio will not appreciate at least in an amount equal to inflation over time. General micro- and macro-economic conditions may also affect the value of the securities held in a client’s portfolio, and general economic downturns can trigger corresponding losses across various asset classes and security types. Market cycles may cause overall volatility and fluctuations in a portfolio’s value, and may increase the likelihood that securities are purchased when values are comparatively high and/or that securities are sold when values are comparatively low. Geopolitical shifts may result in market uncertainty, lowered expected returns, and general volatility in both domestic and international securities. Regulatory changes may have a negative impact on capital formation and increase the costs of doing business, and therefore result in decreased corporate profits and corresponding market values of securities. iii. Investing in mutual funds does not guarantee a return on investment, and shareholders of a mutual fund may lose the principal that they’ve invested into a particular mutual fund. Mutual funds invest into underlying securities that comprise the mutual fund, and as such clients are exposed to the risks arising from such underlying securities. Mutual funds charge internal expenses to their shareholders (which can include management fees, administration fees, shareholder servicing fees, sales loads, redemption fees, and other fund fees and expenses, e.g.), and such internal expenses subtract from its potential for market appreciation. Shares of mutual funds may only be traded at their stated net asset value (“NAV”), calculated at the end of each day upon the market’s close. Investing in ETFs bears similar risks and incurs similar costs to investing in mutual funds as described above. However, shares of an ETF may be traded like stocks on the open market and are not redeemable at an NAV. As such, the value of an ETF may fluctuate throughout the day and investors will be subject to the cost associated with the bid-ask spread (the difference between the price a buyer is willing to pay (bid) for an ETF and the seller's offering (asking) price). Clients are encouraged to carefully read the prospectus of any mutual fund or ETF to be purchased for investment to obtain a full understanding of its respective risks and costs. iv. Investing in common stocks means that a client will be subject to the risks of the overall market as well as risks associated with the particular company or companies whose Page 10 of 21 Date of Brochure: September 1, 2026  stock is owned. These risks can include, for example, changes in economic conditions, growth rates, profits, interest rates and the market’s perception of these securities. Common stocks tend to be more volatile and more risky than certain other forms of investments, especially as compared to fixed income products like bonds. v. Investing in municipal securities carries unique risks, depending on the type of bond offered. General obligation bonds are issued by governmental entities and are not backed by revenues from a specific project or source. In some instances, municipalities may not have taxing authority to repay bondholders. Revenue bonds are backed by revenues from a specific project or source and can vary greatly in terms of credit risk. Some revenue bonds are “non-course” bonds, meaning that should the revenue stream dry up or the conduit borrower fails to pay, the bondholder will not have a claim to the underlying revenue or against the conduit borrower. vi. Investing in corporate debt, including corporate bonds, carries additional risks to those noted above for fixed income securities. Corporate debt is also subject to credit risk - the risk that the bond issuer may default on one or more payments before the bond reaches maturity. In the event of a default, you may lose some or all of the income you were entitled to, and even some or all of the principal amount invested. Some corporate bonds may also be subject to early redemption risk, with the issuer having the principal repaid prior to the maturity date of the bond. vii. Investing in certificates of deposit (“CDs”), while relatively safe, can still carry some risks. CDs have terms of different lengths, ranging up to 10 years. During the term length, your funds invested in the CD will be inaccessible; if you opt to withdraw early, you will be subject to early withdrawal fees, which can erode any interest accrued and can decrease the principal amount originally invested. It is also subject to inflation risk, as CD rates tend to lag behind rising inflation and drop more quickly than inflation on the way down. viii. Investing in money market funds carries interest rate risk. Securities with longer maturities typically offer higher yields, but have greater interest rate sensitivity. There is also liquidity risk - the money market fund may impose a fee upon the sale of your shares, or may temporarily suspend your ability to sell shares, if the fund’s liquidity falls below required minimums because of market conditions or other factors. ix. Investing in options has the potential to amplify losses as well as to limit potential gains, and whether or not an option will result in a gain or a loss is wholly dependent on the market value of the option’s underlying security. Options require the payment of a premium (which may not be recouped), and have the potential to trigger a purchase or sale obligation within a shorter timeframe than a more traditional long-term investment. Implementing certain options strategies creates certain time sensitivities, such that an options strategy may not be successful if exercises are not executed within an applicable period of time. When selling covered calls, there is a risk the underlying position may be called away at a price lower than the current market price. When purchasing puts, there is a risk that the premium paid will be a sunk cost if the option expires unexercised. x. Relying on the financial planning services of an independent and unaffiliated third-party adviser (including but not limited to the Third-Party Planner) means that clients will be subject to such third-party adviser’s continued ability to achieve its financial planning deliverables. To the extent that a third-party adviser is dependent on the services or intellectual capital of a select few individuals, the departure or death of such individuals may have a material impact on the continued viability of such third-party adviser and its ability to continue rendering financial planning services. There can be no guarantee that a third-party adviser will meet its financial planning expectations, or that its services will be free of any errors. Page 11 of 21 Date of Brochure: September 1, 2026  Item 9: Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of Adviser’s advisory business or the integrity of Adviser’s management. Page 12 of 21 Date of Brochure: September 1, 2026  Item 10: Other Financial Industry Activities & Affiliations A. Neither Adviser nor any of its management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. B. Neither Adviser nor any of its management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. C. Neither Adviser nor any of its management persons have any relationship or arrangement with any related person below: i. ii. iii. iv. v. vi. vii. viii. ix. broker-dealer, municipal securities dealer, or government securities dealer or broker investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund) other investment adviser or financial planner futures commission merchant, commodity pool operator, or commodity trading advisor banking or thrift institution lawyer or law firm pension consultant real estate broker or dealer sponsor or syndicator of limited partnerships D. Robert McAlister is a licensed insurance agent and from time to time will earn an ordinary and customary commission from the sale of an insurance product in such capacity. This creates a conflict of interest, because Robert McAlister has the potential to earn both an insurance commission and advisory fee revenue from a client. Robert McAlister addresses this conflict of interest by fully disclosing their relationship with the applicable insurance provider, and informing clients that they are under no obligation to purchase an insurance product through them. E. From time to time we refer prospective financial planning clients to Domain Money as a Third-Party Planner. Pursuant to an advisory and referral agreement between Adviser and Domain Money, Adviser is entitled to receive a percentage of the financial planning fees charged by Domain Money to clients referred by Adviser to Domain Money as a Third-Party Planner, and therefore is a conflict of interest. Adviser addresses this conflict of interest by fully disclosing it in this brochure, by only referring prospective financial planning clients to Domain Money when believed to be appropriate for the financial planning needs of a client, and by independently evaluating Domain Money based on the quality of financial planning services delivered to clients. As of the date of this brochure, Kevin Lum is the holder of certain unexercised shares of common stock of Domain Money, Inc., a corporation that is the parent company of Domain Money. This relationship presents a conflict of interest, since Kevin Lum stands to financially benefit from the ostensible increase in the value of the common stock of Domain Money, Inc. if Adviser refers clients to Domain Money for financial planning services and Domain Money earns additional revenue from such clients as a result. Kevin Lum addresses this conflict of interest by disclosing it in this brochure, by only referring prospective financial planning clients to Domain Money when believed to be in their best interests, and by performing reasonable due diligence to assess Domain Money’s continued suitability for clients’ financial planning needs. Page 13 of 21 Date of Brochure: September 1, 2026  Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading A. Adviser has adopted a code of ethics that will be provided to any client or prospective client upon request. Adviser’s code of ethics describes the standards of business conduct that Adviser requires of its supervised persons, which is reflective of Adviser’s fiduciary obligations to act in the best interests of its clients. The code of ethics also includes sections related to compliance with securities laws, reporting of personal securities transactions and holdings, reporting of violations of the code of ethics to Adviser’s Chief Compliance Officer, pre-approval of certain investments by access persons, and the distribution of the code of ethics and any amendments to all supervised persons followed by a written acknowledgement of their receipt. B. Neither Adviser nor any of its related persons recommends to clients, or buys or sells for client accounts, securities in which Adviser or any of its related persons has a material financial interest. C. From time to time, Adviser or its related persons will invest in the same securities (or related securities such as warrants, options or futures) that Adviser or a related person recommends to clients. This has the potential to create a conflict of interest because it affords Adviser or its related persons the opportunity to profit from the investment recommendations made to clients. Adviser’s policies and procedures and code of ethics address this potential conflict of interest by prohibiting such trading by Adviser or its related persons if it would be to the detriment of any client and by monitoring for compliance through the reporting and review of personal securities transactions. In all instances Adviser will act in the best interests of its clients. D. From time to time, Adviser or its related persons will buy or sell securities for client accounts at or about the same time that Adviser or a related person buys or sells the same securities for its own (or the related person’s own) account. This has the potential to create a conflict of interest because it affords Adviser or its related persons the opportunity to trade either before or after the trade is made in client accounts, and profit as a result. Adviser’s policies and procedures and code of ethics address this potential conflict of interest by prohibiting such trading by Adviser or its related persons if it would be to the detriment of any client and by monitoring for compliance through the reporting and review of personal securities transactions. In all instances Adviser will act in the best interests of its clients. Page 14 of 21 Date of Brochure: September 1, 2026  Item 12: Brokerage Practices A. Adviser considers several factors when recommending a custodial broker-dealer for client transactions and determining the reasonableness of such custodial broker-dealer’s compensation. Such factors include the custodial broker-dealer’s industry reputation and financial stability, service quality and responsiveness, execution price, speed and accuracy, reporting abilities, and general expertise. Assessing these factors as a whole allows Adviser to fulfill its duty to seek best execution for its clients’ securities transactions. However, Adviser does not guarantee that the custodial broker-dealer recommended for client transactions will necessarily provide the best possible price, as price is not the sole factor considered when seeking best execution. After considering the factors above, Adviser recommends Charles Schwab & Co., Inc. ("Schwab"), Fidelity Brokerage Services LLC ("Fidelity"), and Altruist Financial LLC ("Altruist") as the custodial broker-dealers for client accounts. i. Adviser does not receive research and other soft dollar benefits in connection with client securities transactions, which are known as “soft dollar benefits”. However, the custodial broker-dealer(s) recommended by Adviser do provide certain products and services that are intended to directly benefit Adviser, clients, or both. Such products and services include (a) an online platform through which Adviser can monitor and review client accounts, (b) access to proprietary technology that allows for order entry, (c) duplicate statements for client accounts and confirmations for client transactions, (d) invitations to the custodial broker-dealer(s)’ educational conferences, (e) practice management consulting, and (f) occasional business meals and entertainment. The receipt of these products and services creates a conflict of interest to the extent it causes Adviser to recommend Schwab, Fidelity, and Altruist as opposed to a comparable custodial broker-dealer. Adviser addresses this conflict of interest by fully disclosing it in this brochure, evaluating Schwab, Fidelity, and Altruist based on the value and quality of their services as realized by clients, and by periodically evaluating alternative broker-dealers to recommend. ii. Adviser does not consider, in selecting or recommending custodial broker-dealers, whether Adviser or a related person receives client referrals from a custodial broker-dealer. iii. Adviser does not routinely recommend, request, or require that a client direct Adviser to execute transactions through a specified custodial broker-dealer other than Schwab, Fidelity, and Altruist. B. Adviser retains the ability to aggregate the purchase and sale of securities for clients’ accounts with the goal of seeking more efficient execution and more consistent results across accounts. Aggregated trading instructions will not be placed if it would result in increased administrative and other costs, custodial burdens, or other disadvantages. If client trades are aggregated by Adviser, such aggregation will be done so as not to disadvantage any client and to treat all clients as fairly and equally as possible. Directing the purchase and sale of securities for clients’ accounts on an individual basis, rather than in aggregate blocks, may result in increased client transaction costs. To the extent the securities purchased and sold by Adviser are mutual funds (each of which generally price at the same respective net asset value at the end of each trading day), Adviser believes that the potential for increased client transaction costs by not aggregating orders is substantially eliminated. Page 15 of 21 Date of Brochure: September 1, 2026  Item 13: Review of Accounts A. The Chief Executive Officer and Chief Compliance Officer of Adviser monitors client accounts on an ongoing basis, and typically reviews client accounts on an annual basis. Such reviews are designed to ensure that the client is still on track to achieve his or her financial goals, and that the investments remain appropriate given the client’s risk tolerance, investment objectives, major life events, and other factors. Clients are encouraged to proactively reach out to Adviser to discuss any changes to their personal or financial situation. B. Other factors that may trigger a review include, but are not limited to, material developments in market conditions, material geopolitical events, and changes to a client’s personal or financial situation (the birth of a child, preparing for a home purchase, plans to attend higher education, a job transition, impending retirement, death or disability among family members, etc.). C. The custodial broker-dealer will send account statements and reports directly to clients no less frequently than quarterly. Such statements and reports will be mailed to clients at their address of record or delivered electronically, depending on the client’s election. If agreed to by Adviser and client, Adviser or a third-party report provider will also send clients reports to assist them in understanding their account positions and performance, as well as the progress toward achieving financial goals. Page 16 of 21 Date of Brochure: September 1, 2026  Item 14: Client Referrals and Other Compensation A. Only clients provide an economic benefit to Adviser for providing investment advice or other advisory services to them, except as otherwise described in this brochure. However, as described above in Item 12, the custodial broker-dealer(s) recommended for client accounts provides certain products and services that are intended to directly benefit Adviser, clients, or both. In addition, please refer to Item 10 for (i) a description of the advisory and referral agreement with Domain Money as Third-Party Planner, pursuant to which Adviser is entitled to a percentage of the financial planning fees charged by Domain Money to clients referred by Adviser, and (ii) a description of Kevin Lum’s economic interest in Domain Money. These relationships with Domain Money create financial incentives and conflicts of interest which are important for prospective financial planning clients to understand. Each prospective financial planning client we refer to Domain Money will receive a separate written disclosure that describes our referral fee with particularity. B. Neither Adviser nor a related person directly or indirectly compensates a person who is not our supervised person for client referrals. Page 17 of 21 Date of Brochure: September 1, 2026  Item 15: Custody For clients that do not have their fees deducted directly from their account(s), Adviser will not have any custody of client funds or securities. For clients that have their fees deducted directly from their account(s), Adviser will generally be deemed to have custody over such clients’ funds pursuant to applicable custody rules and guidance thereto. At no time will Adviser accept custody of client funds or securities in the capacity of a custodial broker-dealer or other qualified custodian, and at all times client accounts will be held by a third-party qualified custodian as described in Item 12, above. If a client receives account statements from both the custodial broker-dealer and Adviser or a third-party report provider, such client is urged to compare such account statements and advise Adviser of any discrepancies between them. Page 18 of 21 Date of Brochure: September 1, 2026  Item 16: Investment Discretion Adviser accepts discretionary trading authority to manage securities accounts on behalf of clients only pursuant to the mutual written agreement of Adviser and the client through a power-of-attorney, which is typically contained in the advisory agreement signed by Adviser and the client. This includes the authority to buy, sell, and otherwise transact in securities and other investment products in clients’ account(s) without necessarily consulting with clients in advance. Clients may place reasonable limitations on this discretionary authority so long as it is contained in a written agreement and/or power-of-attorney. Page 19 of 21 Date of Brochure: September 1, 2026  Item 17: Voting Client Securities A. Adviser does not have and will not accept authority to vote client securities. B. Clients will receive their proxies or other solicitations directly from their custodial broker-dealer or a transfer agent, as applicable, and should direct any inquiries regarding such proxies or other solicitations directly to the sender. Page 20 of 21 Date of Brochure: September 1, 2026  Item 18: Financial Information A. Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. B. Adviser has no financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. C. Adviser has not been the subject of a bankruptcy petition at any time during the past ten years. Page 21 of 21 Date of Brochure: September 1, 2026