FRANK FINANCIAL ADVISORS

Frank Financial Advisors Form ADV Part 2A Investment Adviser Brochure January 1, 2026 2710 Loker Avenue West Suite 230 Carlsbad CA 92010 760-438-3360 todd@frankfinancialadvisors.com www.frankfinancialadvisors.com This brochure provides information about the qualifications and business practices of Frank Financial Advisors. If you have any questions about the contents of this brochure, please contact Todd E. Frank, President and Chief Compliance Officer, at 760-438-3360 and/or todd@frankfinancialadvisors.com. 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. Additional information about Frank Financial Advisors is also available on the SEC’s website at www.adviserinfo.sec.gov. S0174696.1i  Item 2: Summary of Material Changes This Item of the brochure is updated if material changes have occurred during the course of Frank Financial Advisors’ fiscal year; or with Frank Financial Advisors’ Annual Updating Amendment (ADV). Material Changes since the Last Update Since the last ADV Part 2A dated January 1, 2025, the firm has made no material changes to this brochure. Full Brochure Available We will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Currently, our Brochure may be requested by contacting Todd E. Frank, President and Chief Compliance Officer at 760-438-3360 or todd@frankfinancialadvisors.com. Additional information about Frank Financial Advisors is also available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with Frank Financial Advisors who are registered, or are required to be registered, as investment adviser representatives of Frank Financial Advisors. S0174696.1ii  Item 3: Table of Contents FORM ADV ....................................................................................................................... I ITEM 2: SUMMARY OF MATERIAL CHANGES ............................................................ II ITEM 3: TABLE OF CONTENTS .................................................................................... III ITEM 4: ADVISORY BUSINESS .................................................................................... 1 ITEM 5: FEES AND COMPENSATION .......................................................................... 4 ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ......... 6 ITEM 7: TYPES OF CLIENTS ........................................................................................ 6 ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ............................................................................................................................... 6 ITEM 9: DISCIPLINARY INFORMATION ....................................................................... 9 ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ............. 9 ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ........................................................... 10 ITEM 12: BROKERAGE PRACTICES ......................................................................... 11 ITEM 13: REVIEW OF ACCOUNTS ............................................................................. 15 ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION .............................. 16 ITEM 15: CUSTODY ..................................................................................................... 16 ITEM 16: INVESTMENT DISCRETION ........................................................................ 16 ITEM 17: VOTING CLIENT SECURITIES .................................................................... 17 ITEM 18: FINANCIAL INFORMATION ......................................................................... 17 FORM ADV PART 2B – INVESTMENT ADVISER BROCHURE SUPPLEMENT ........ 18 EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ............................. 19 TODD E. FRANK ........................................................................................................... 19 LINDA A. HALLERAN ................................................................................................... 21 S0174696.1iii  Item 4: Advisory Business Firm Description Frank Financial Advisors is an Investment Adviser providing discretionary asset management, financial planning, and consulting. Advice is given to individuals, profit sharing plans, trusts, estates, charitable organizations, and corporations or other business entities. Frank Financial Advisors is the dba for Frank Financial Services which was founded in 2003. In June 2021, the firm moved from state to SEC registration. “Registration” means only that Frank Financial Advisors has met the minimum requirements for registration as an investment advisor and does not apply a certain level of skill or training or that the SEC or any other regulator guarantees the quality of our services or recommends them. Principal Owners Frank Financial Advisors dba Frank Financial Services is wholly owned by Todd E. Frank. Discretionary Asset Management Assets are invested primarily in no-load or low-load mutual funds and exchange-traded funds, usually through discount brokers or fund companies. Investments may also include: equities (stocks), warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, fixed annuities, U. S. government securities, option contracts, interests in limited partnerships, private placement partnerships, private funds and oil and gas partnerships. Retirement Plans And Plan Participants Frank Financial Advisors offers various levels of advisory and consulting services to employee benefit plans (Retirement Plans) and to the participants of such plans (Participants). The services are designed to assist plan sponsors (Plan Sponsors) in meeting their management and fiduciary obligations to the Participants under the Employee Retirement Income Securities Act (ERISA) and the Pension Protection Act of 2006 (PPA). Generally, investment advice provided to Plan Sponsors and Participants is regulated under ERISA and the PPA. Plan Sponsors must make the ultimate decision to retain Frank Financial Advisors for pension consulting and other investment advisory services including, but not limited to, services at the participant level. The Plan Sponsor is free to seek independent advice about the appropriateness of any recommended services for the plan. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. S0174696.1 1  Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. Financial Planning Financial planning may address any or all of the following areas of concern: • Personal: Family records, budgeting, personal liability, estate information and financial goals. • Education: Education IRAs, financial aid, state savings plans, grants and general assistance in preparing to meet dependents continuing educational needs through development of an education plan. • Death and Disability: Cash needs at death, income needs of surviving dependents, estate planning and disability income analysis. • Retirement: Analysis of current strategies and investment plans to help the client achieve his or her retirement goals. • Investments: Analysis of investment alternatives and their effect on a client’s portfolio. • Estate: Living trusts, wills, estate tax review, powers of attorney, and asset protection plans. • Insurance: Review of existing policies to ensure proper coverage for life, health, disability, long term care. • Debt Management: Mortgage and other financial liability management. Financial planning clients may receive a written report, providing a detailed financial plan designed to achieve their stated financial goals and objectives. S0174696.1 2  Frank Financial Advisors gathers required information through in-depth personal interviews. Information gathered includes a client’s current financial status, future goals and attitudes towards risk. Related source documents which may include a questionnaire completed by the client, are carefully reviewed. A written report may be prepared. If a client chooses to implement the recommendations contained in the plan, Frank Financial Advisors suggests the client work closely with his/her attorney, accountant, insurance agent, and/or financial advisor. Implementation of financial plan recommendations is entirely at the client’s discretion. Financial planning recommendations are not limited to any specific product or service offered by a broker dealer or insurance company. Consulting Frank Financial Advisors also offers investment advice on a more limited basis. This may include advice on only an isolated area(s) of concern such as estate planning, retirement planning, reviewing a client’s existing portfolio, or any other specific topic. Additionally, Frank Financial Advisors may provide advice on non-securities matters; generally, in connection with the rendering of estate planning, debt management, insurance, and/or annuity advice. An initial meeting, which may be by telephone, is free of charge and is considered an exploratory interview to determine the extent to which financial planning and investment management may be beneficial to the client. Use of Third-Party Advisers Dependent upon the client’s needs or objectives, the Firm may recommend the services of an independent third-party adviser ("TPA") to manage a portion of a client’s portfolio. Typically, this involves the selection of certain programs, or money managers, which will enter into a separate agreement with Frank Financial Advisors or with the Client directly. The Firm's recommendations regarding the suitability of a TPA and its investment style is based on, but not limited to, the client’s financial needs, long-term goals, and investment objectives. Upon selection of a TPA, Frank Financial Advisors will conduct periodic due diligence ensure that the TPA's performance, portfolio strategies and management remain aligned to the client’s overall investment goals and objectives. Frank Financial Advisors will retain discretionary authority to hire and fire TPAs and reallocate the client’s assets to other TPAs, where such action is deemed to be in the best interest of the client. Clients may be required to sign a separate investment management agreement directly with the TPA(s) selected, in addition to the advisory agreement signed with Frank Financial Advisors. If the TPA is compensated in advance, the client will typically receive a pro-rata refund of any prepaid advisory fees upon termination. Should the Firm select a TPA to manage a portion of the client’s portfolio, the Firm will instruct the TPA to deliver a copy of the TPA’s Form ADV Part 2A (or other similar Client Brochure) to the client at the time of appointing the TPA. Client Assets As of February 7, 2026, Frank Financial Advisors managed $188,217,262 in assets; $182,408,083 is managed on a discretionary basis, and $5,809,179 is managed on a non-discretionary basis. S0174696.1 3  Item 5: Fees and Compensation Frank Financial Advisors’ fee schedules are described below. Discretionary Asset Management Frank Financial Advisors bases its asset management fees on a percentage of assets under management. The annual fees for Frank Financial Advisors portfolio management services range from 1.0% to 2.0% annually of assets under management. The specific manner in which fees are charged by Frank Financial Advisors is established in a client’s written agreement with Frank Financial Advisors. Frank Financial Advisors will generally calculate fees in advance on a quarterly basis based upon the value (market value or fair market value in the absence of market value) of the client’s account – see Items 6 and 10 for additional information), at the end of the previous quarter. Fees are debited from client accounts in accordance with the client authorization in the client’s written agreement. The annual fee for investment management services provided are based upon a percentage (%) of the market value of the Assets under management in accordance with the fee schedule in the Agreement signed by the Client. Frank Financial Advisors considers cash to be an asset class and part of Assets under management and subject to the same fee calculation as the Client’s non-cash investments. Management fees shall be prorated for each capital contribution and withdrawal made during the applicable calendar quarter (with the exception of de minimis contributions and withdrawals). Accounts initiated or terminated during a calendar quarter will be charged a prorated fee. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. Financial Planning and Consulting Services Financial Planning and Consulting fees will be charged in one of two ways: • As a fixed fee, typically ranging from $1,000 to $10,000 depending on the nature and complexity of each client’s circumstances, or • On an hourly basis of $250 per hour. Financial plans are priced according to the degree of complexity associated with the client’s situation. For certain asset management clients, financial planning and consulting services may be offered at a discount or included in asset management fees. All financial planning and consulting fees are due in arrears, upon presentation of the financial plan or consulting engagement for the client. Use of Third-Party Advisers Clients receiving services from a TPA should understand that the advisory fees assessed will vary dependent upon the TPA selected, the size of the account and the S0174696.1 4  services provided. These fees are separate from, and in addition to, the Firm’s fees. For information regarding the TPA’s minimum account size, requirements, management services and associated advisory and referral fees, please refer to the TPA’s Form ADV, client disclosure brochure, and other TPA materials. General Information on Compensation and Other Fees In certain circumstances, fees, account minimums and payment terms are negotiable depending on client’s unique situation – such as the size of the aggregate related party portfolio size, family holdings, low cost basis securities, or certain passively advised investments and pre-existing relationships with clients. Certain clients may pay more or less than others depending on the amount of assets, type of portfolio, or the time involved, the degree of responsibility assumed, complexity of the engagement, special skills needed to solve problems, the application of experience and knowledge of the client’s situation. Custodians may charge transaction fees on purchases, sales, custody or banking functions. These transaction charges are usually small and incidental to the purchase or sale of a security. The selection of the security is more important than the nominal fee that the custodian charges to buy or sell the security. Such charges, fees and transaction costs are exclusive of and in addition to Frank Financial Advisors’ fee, and Frank Financial Advisors shall not receive any portion of these transaction charges, fees, and costs. Item 12 further describes the factors that Frank Financial Advisors considers in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). All fees paid to Frank Financial Advisors for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and variable annuity sub-accounts to their shareholders. These fees and expenses are described in each fund’s or sub account’s prospectus. These fees will generally include a management fee, other expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or sub-account directly, without the services of Frank Financial Advisors. In that case, the client would not receive the services provided by Frank Financial Advisors which are designed, among other things, to assist the client in determining which mutual funds or sub-accounts are most appropriate to each client’s financial condition and objectives. Accordingly, the client should review both the fees charged by the funds/sub-accounts and the fees charged by Frank Financial Advisors to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Clients should note that similar advisory services may (or may not) be available from other registered investment advisers for similar or lower fees. Agreement Terms Either Frank Financial Advisors or a client may terminate the client agreement at any time by notification in writing. The client will be responsible for paying the rate for the time spent on the investment advisory engagement prior to notification of termination. If S0174696.1 5  the client made an advance payment, Frank Financial Advisors will refund any unearned portion of the advance payment. Item 6: Performance-Based Fees and Side-by-Side Management Performance-Based Fees Neither Frank Financial Advisors nor any of its Supervised Persons (employees) accepts performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client) in connection with services provided by Frank Financial Advisors. Frank Financial Advisors does not use a performance-based fee structure with regard the services it offers because of the potential conflict of interest. Performance-based compensation may create an incentive for the adviser to recommend an investment that may carry a higher degree of risk to the client. Item 7: Types of Clients Types of Clients Frank Financial Advisors provides investment advice to the types of clients described in Item 4, Advisory Business above. Account Minimums Frank Financial Advisors requires a minimum account of $500,000 for investment advisory clients, although this may be negotiable under certain circumstances. Frank Financial Advisors may group certain related client accounts for the purposes of achieving the minimum account size. Clients receiving ongoing investment management services will be assessed a $200 minimum annual fee. Clients with assets below the minimum account size may pay a higher percentage rate on their annual fees than the fees paid by clients with greater assets under management. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Frank Financial Advisors uses the following methods of analysis: Fundamental Analysis. Frank Financial Advisors attempts to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). S0174696.1 6  Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Charting/Technical Analysis. The terms “charting” and “technical” analysis are generally used synonymously and therefore, for the purpose of this document, the term, “technical analysis” will be used. Frank Financial Advisors analyzes past market movements and applies that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company. This presents a risk in that a poorly-managed or financially unsound company may underperform regardless of market movement. Cyclical Analysis. In this type of technical analysis, Frank Financial Advisors measure the movements of a particular security against the overall market in an attempt to predict the price movement of the security. Investment Strategies The investment strategy for a specific client is based upon the objectives stated by the client during consultations updated verbally or in writing on a periodic basis. The client may change these objectives at any time. Each client executes a Client Profile that documents their objectives and their desired investment strategy. Frank Financial Advisors may use any of the following investment strategies to implement investment advice. Long-term purchases (securities held at least a year); Short-term purchases (securities sold within a year);Trading (securities sold within 30 days); Short sales; Margin transactions; Option writing, including covered options, uncovered options or spreading strategies; or 3rd Party Managers. The private funds in which Frank Financial Advisors clients may invest pursue different investment processes and strategies than Frank Financial Advisors, which generally are considered risky. The processes and strategies for the private funds are disclosed in each private fund’s offering documents and can include, but are not limited to hedging, leverage, short sales, uncovered options, futures, and forward foreign exchange contracts, private loans, real estate investments, and other non-liquid investments. Such strategies carry a risk of total loss of principal. Each private fund investment has varying degrees of illiquidity depending on the type of fund and its underlining investments, which are outlined in a fund’s offering documents and should be reviewed prior to investment. Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks: • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. S0174696.1 7  • Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic and social conditions may trigger market events. • Inflation Risk: When any type of inflation is present, a dollar next year will not buy as much as a dollar today, because purchasing power is eroding at the rate of inflation. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. This is a risk associated with an investment in private funds. • Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Private Funds Depending on the sophistication and risk tolerances of its clients, Frank Financial Advisors may recommend, as part of a client’s overall investment strategy, that a portion of such client’s assets be invested in private funds or other alternative investments. Such investments present special risks for Frank Financial Advisors’ clients, including without limitation, limited liquidity, higher fees, volatile performance, heightened risk of loss, limited transparency, special tax considerations, subjective valuations and limited regulatory oversight. Therefore, private investments may not be suitable for all Frank Financial Advisors clients and will be offered only to those qualifying clients for whom an investment therein is determined to be suitable. Generally, such investments are available for investment only to a limited number of sophisticated investors who meet the definition of “accredited investor” under S0174696.1 8  Regulation D of the Securities Act of 1933, as amended (the “Securities Act”) and “qualified client” under the Investment Advisers Act of 1940. Private funds often impose performance-based fees or incentive allocations payable to the fund manager or general partner. Such performance-based fee/incentive allocation structures may create an incentive for the managers of the private funds to make investments that are riskier or more speculative than would be the case in the absence of a performance-based fee/incentive allocation structure. Additionally, the performance-based fee structure could also cause the portfolio managers responsible for the private funds to devote a disproportionate amount of time to the management of the private funds, and compensation may be larger than it otherwise would have been because the fee/incentive allocation will be based on account performance instead of a percentage of assets under management. Please refer to Item 6 above for additional information. Additionally, certain private funds may be more illiquid than others, meaning that an investor’s investment may be “locked up” for a defined period of time or for the life of the private fund. The illiquidity of each private fund depends on a few factors, including but not limited to the type and liquidity of the private fund’s underlying investments. It is important for investors to read the private fund’s offering documents fully before investing. Other Investments Frank Financial Advisors reserves the right to advise clients on any other type of investment that it deems appropriate based on the client’s stated goals and objectives. Frank Financial Advisors may also provide advice on any type of investment held in a client’s portfolio at the inception of the advisory relationship or on any investment on which the client requests advice. Frank Financial Advisors may provide investment advice on such investments as limited partnerships, private placement partnerships, annuities, life insurance, and oil and gas partnerships. 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 Frank Financial Advisors or the integrity of Frank Financial Advisors’ management. Frank Financial Advisors has no information to disclose applicable to this Item. Item 10: Other Financial Industry Activities and Affiliations Accountant Todd E. Frank, President and CEO, is a Certified Public Accountant. He no longer practices public accounting, or gives tax advice. S0174696.1 9  Prime Brokerage Frank Financial Advisors may purchase bonds for clients using a third party broker through the use of a prime brokerage account. The prime brokerage account is in the name of Frank Financial Advisors. Bonds may be purchased in block from the third party broker, placed into the prime brokerage account, and then allocated to clients as instructed by Frank Financial Advisors. All securities are distributed to clients on the same business day. The prime broker charges a commission and a service fee for each trade, which is included in the cost of the bond. Frank Financial Advisors reviews all trades in the prime brokerage account to ensure consistency of allocation methods and fairness of prime brokerage service fees. Other Investment Managers Frank Financial Advisors may select other investment managers for its clients for specific investment needs when deemed appropriate. Commodities Neither Frank Financial Advisors nor any of its management persons is registered as (or associated with) a futures commissions merchant, commodity pool operator, or a commodity trading advisor. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Frank Financial Advisors employees must comply with a Code of Ethics and Statement for Insider Trading. The Code describes the Firms’ high standard of business conduct, and fiduciary duty to its clients. The Code’s key provisions include: • Statement of General Principles • Policy on and reporting of Personal Securities Transactions • A prohibition on Insider Trading • Restrictions on the acceptance of significant gifts • Procedures to detect and deter misconduct and violations • Requirement to maintain confidentiality of client information Todd E. Frank, President and Chief Compliance Officer reviews all employee trades each quarter. These reviews ensure that personal trading does not affect the markets, and that clients of Frank Financial Advisors receive preferential treatment. Since most employee trades are small mutual fund trades or exchange-traded fund trades, the trades do not affect the securities markets. S0174696.1 10  Frank Financial Advisors’ employees must acknowledge the terms of the Code of Ethics at least annually. Clients and prospective clients can obtain a copy of Frank Financial Advisors’ Code of Ethics by contacting Todd E. Frank at 760-438-3360. Personal Securities Transactions Frank Financial Advisors and its employees may buy or sell securities identical to those recommended to clients for their personal accounts. The Code of Ethics, described above, is designed to assure that the personal securities transactions, activities and interests of the employees of Frank Financial Advisors will 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. Employee trading is continually monitored under the Code of Ethics, and designed to reasonably prevent conflicts of interest between Frank Financial Advisors and its clients. Employees are required to put the best interests of the client first. Employees must comply with a Code of Ethics and Statement for Insider Trading. The Code contains provisions reasonably necessary to deter misconduct and conflicts of interest and to detect any violation. Participation or Interest in Client Transactions Frank Financial Advisors and its employees do not recommend to clients, or buy or sell for client accounts, securities in which they have a material financial interest. Principal/Agency Cross Frank Financial Advisors does not affect principal cross transactions for client accounts. Aggregation Frank Financial Advisors and its employees may trade in the same securities with client accounts on an aggregated basis when consistent with Frank Financial Advisors’ obligation of best execution. In such circumstances, the affiliated and client accounts will share commission costs equally and receive securities at a total average price. Frank Financial Advisors will retain records of the trade order (specifying each participating account) and its allocation, which will be completed prior to the entry of the aggregated order. Completed orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro rata basis. Any exceptions will be explained on the order. Item 12: Brokerage Practices Research and Other Soft Dollar Benefits Frank Financial Advisors does not receive formal soft dollar benefits other than execution from broker/dealers in connection with client securities transactions. Brokerage for Client Referrals Frank Financial Advisors does not receive client referrals from Broker/Dealers. S0174696.1 11  Directed Brokerage The Custodian and Brokers Frank Financial Advisors Uses Frank Financial Advisors does not maintain custody of client assets managed, however, as disclosed in Item 15, Frank Financial Advisors may be deemed to have custody of client assets if given authority to withdraw fees from client accounts. Client assets must be maintained in an account at a “qualified custodian,” generally a broker- dealer or bank. Frank Financial Advisors generally recommends that clients use Charles Schwab & Co., Inc. (Schwab), a FINRA registered broker-dealer, member SIPC, as the qualified custodian. Frank Financial Advisors is independently owned and operated and is not affiliated with Schwab. Schwab will hold client assets in a brokerage account and buy and sell securities when Frank Financial Advisors instructs them to. While Frank Financial Services recommends that clients use Schwab as custodian/broker, the client will decide whether to do so and will open client account with Schwab by entering into an account agreement directly with them. Frank Financial Advisors does not open the account for client, although Frank Financial Advisors may assist client in doing so. Even though client account is maintained at Schwab, Frank Financial Advisors can still use other brokers to execute trades for client account as described below (see “Client Brokerage and Custody Costs”). How Frank Financial Advisors Selects Brokers/Custodians Frank Financial Advisors seeks to recommend a custodian/broker who will hold client assets and execute transactions on terms that are, overall, most advantageous when compared to other available providers and their services. Frank Financial Advisors consider a wide range of factors, including, among others: • Combination of transaction execution services and asset custody services (generally without a separate fee for custody) • Capability to execute, clear, and settle trades (buy and sell securities for client account) • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, exchange- traded funds (ETFs), etc.) • Availability of investment research and tools that assist Frank Financial Advisors in making investment decisions • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices S0174696.1 12  • Reputation, financial strength, and stability • Availability of other products and services that benefit Frank Financial Advisors, as discussed below (see “Products and Services Available to Us From Schwab”) Products and Services Available to Us From Schwab Schwab Advisor Services™ (formerly called Schwab Institutional®) is Schwab’s business serving independent investment advisory firms like Frank Financial Advisors. They provide Frank Financial Advisors and clients with access to its institutional brokerage - trading, custody, reporting, and related services - many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help Frank Financial Advisors manage or administer clients’ accounts, while others help Frank Financial Advisors manage and grow Frank Financial Advisors business. Schwab’s support services generally are available on an unsolicited basis (Frank Financial Advisors doesn’t have to request them) and at no charge to Frank Financial Advisors. Services That Benefit Clients Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which Frank Financial Advisors might not otherwise have access or that would require a significantly higher minimum initial investment by Frank Financial Advisors clients. Schwab’s services described in this paragraph generally benefit client and client account. Services That May Not Directly Benefit Clients Schwab also makes available to Frank Financial Advisors other products and services that benefit Frank Financial Advisors but may not directly benefit clients or client accounts. These products and services assist Frank Financial Advisors in managing and administering Frank Financial Advisors clients’ accounts. They include investment research, both Schwab’s own and that of third parties. Frank Financial Advisors may use this research to service all or a substantial number of Frank Financial Advisors clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab 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 and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of Frank Financial Advisors fees from Frank Financial Advisors clients’ accounts • Assist with back-office functions, recordkeeping, and client reporting S0174696.1 13  Services That Generally Benefit Only Us Schwab also offers other services intended to help Frank Financial Advisors manage and further develop Frank Financial Advisors business enterprise. These services include: • Educational conferences and events • Consulting on technology, compliance, legal, and business needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Frank Financial Advisors. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide Frank Financial Advisors with other benefits, such as occasional business entertainment of Frank Financial Advisors personnel. Frank Financial Advisors Interest in Schwab’s Services The availability of these services from Schwab benefits Frank Financial Advisors because Frank Financial Advisors does not have to produce or purchase them. Frank Financial Advisors does not have to pay for Schwab’s services. These services are not contingent upon Frank Financial Advisors committing any specific amount of business to Schwab in trading commissions or assets in custody. Frank Financial Advisors believes, however, that Frank Financial Advisors’ selection of Schwab as custodian and broker is in the best interests of Frank Financial Advisors’ clients. Frank Financial Advisors’ selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How Frank Financial Advisors Selects Brokers/Custodians”) and not Schwab’s services that benefit only Frank Financial Advisors. Client Brokerage and Custody Costs For clients’ accounts that Schwab maintains, Schwab generally does not charge clients separately for custody services but is compensated by charging client commissions or other fees on trades that it executes or that settle into client Schwab account. This commitment benefits client because the overall commission rates client pay are lower than they would be otherwise. In addition to commissions, Schwab charges client a flat dollar amount as a “prime broker” or “trade away” fee for each trade that Frank Financial Advisors have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into client Schwab account. These fees are in addition to the commissions or other compensation client pay the executing broker-dealer. Because of this, in order to minimize client trading costs, Frank Financial Advisors has Schwab execute most trades for client account. Frank Financial Advisors has determined that having Schwab execute most trades is consistent with S0174696.1 14  Frank Financial Advisors duty to seek “best execution” of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How Frank Financial Advisors Select Brokers/Custodians”). Trade Aggregation At the sole discretion of Frank Financial Advisors, aggregate purchases or sales of the same security, instrument or obligation may be transacted on the same day for multiple accounts of one or more of Frank Financial Advisors’ clients. Although such aggregations potentially could be either advantageous or disadvantageous to any one or more particular accounts, they will be effected only when Frank Financial Advisors believes that to do so will be in the best interest of the affected accounts. When transactions are so aggregated the actual prices applicable to the aggregation transaction will be deemed to have purchased or sold its share of the security, instrument or obligation at the average price. If a partial execution is attained at the end of the trading day, Frank Financial Advisors will generally allocate shares on a pro rata basis, but may fill small orders entirely before applying the pro rata allocation. Accounts for Frank Financial Advisors or its employees may be included in a block trade with client accounts. Item 13: Review of Accounts Reviews All client accounts are reviewed quarterly by Todd E. Frank, President. Todd Frank reviews clients’ accounts with regards to their investment policies and risk tolerance levels. Review Triggers Other conditions that may trigger a review are changes in market, political or economic conditions, tax laws, new investment information, and changes in a client's own situation (such as retirement, termination of employment, physical move, or inheritance). Reporting At least quarterly, the custodian provides clients with an account statement for each client account, which may include individual holdings, cost basis information, deposits and withdrawals, accrued income, dividends, and performance. In addition, the custodian provides clients with trade confirmations for each position bought and sold. On demand, printed reports are sent to clients. Client meetings are encouraged and are scheduled quarterly or less frequently as specific situations dictate. Supplemental written reports, with more detailed information including investment performance, are provided to many clients. Financial Planning and Consulting clients will be reviewed as contracted for at the inception of the engagement. S0174696.1 15  Item 14: Client Referrals and Other Compensation Brokerage Arrangements See disclosure in Item 12 regarding compensation, including economic benefits received in connection with giving advice to clients. Item 15: Custody Fee Debiting Clients authorize Frank Financial Advisors (in the client agreement) to debit fees directly from the client’s account at the broker dealer, bank or other qualified custodian (custodian). Client investment assets will be held with a custodian agreed upon by the client and Frank Financial Advisors. The custodian is advised in writing of the limitation of Frank Financial Advisors’ access to the account. The custodian sends a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of advisory fees paid directly to Frank Financial Advisors. Account Statements As described in Item 13, clients receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains client’s investment assets. Clients are urged to carefully review such statements and compare such official custodial records to the account statements or other reports that Frank Financial Advisors provides. Frank Financial Advisors statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. If you are not receiving at least quarterly custodial account statements, please contact us at the number on the cover page of this brochure. Item 16: Investment Discretion Through the investment management agreement, Frank Financial Advisors may accept limited power of attorney to act on a discretionary basis on behalf of clients. A limited power of attorney allows Frank Financial Advisors to execute trades on behalf of clients. When such limited powers exist between the Frank Financial Advisors and the client, Frank Financial Advisors has the authority to determine, without obtaining specific client consent, both the amount and type of securities to be bought to satisfy client account objectives. Additionally, Frank Financial Advisors may accept any reasonable limitation or restriction to such authority on the account placed by the client. All limitations and restrictions placed on accounts must be presented to Frank Financial Advisors in writing. If Frank Financial Advisors has not been given discretionary authority, Frank Financial Advisors consults with the client prior to each trade. S0174696.1 16  Item 17: Voting Client Securities Frank Financial Advisors does not have any authority to and does not vote proxies on behalf of clients. Clients retain the responsibility for receiving and voting proxies and for securities maintained in their portfolios; clients receive proxies directly from either custodians or transfer agents. If requested, Frank Financial Advisors may provide advice to clients regarding proxy votes. If any conflict of interest exists, it will be disclosed to the client. Clients may contact Frank Financial Advisors at 760-438-3360 for information about proxy voting. Item 18: Financial Information Frank Financial Advisors 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. Frank Financial Advisors does not require prepayment of fees of both more than $600 per client, and more than six months in advance, and therefore is not required to provide a balance sheet to clients. S0174696.1 17  Form ADV Part 2B – Investment Adviser Brochure Supplement Frank Financial Advisors Form ADV Part 2B Investment Adviser Brochure Supplement Supervisor: Todd E. Frank Supervisor of: Linda A. Halleran January 1, 2026 2710 Loker Avenue West Suite 230 Carlsbad CA 92010 760-438-3360 todd@frankfinancialadvisors.com www.frankfinancialadvisors.com This brochure supplement provides information about the Firm’s Supervised Persons that supplements the Frank Financial Advisors’ brochure. You should have received a copy of that brochure. Please contact Todd E. Frank at 760-438-3360 and/or todd@frankfinancialadvisors.com if you did not receive Frank Financial Advisors’ brochure or if you have any questions about the contents of this supplement. Additional information about the Firm’s Supervised Persons is also available on the SEC’s website at www.adviserinfo.sec.gov. S0174696.1 18  Educational Background and Business Experience Supervised Persons Todd E. Frank Born: 1964 Education Background: • University of California at Berkley, B.S. Business Administration 1987 • Duke University, Fuqua School of Business, MBA 1992 Business Background: • Frank Financial Advisors (aka) Frank Financial Services, President and CEO (2003 – Present) • Sprite Capital, LLC, Managing Member, (2020 – Present) • Purshe Kaplan Sterling Investments, Reg. Rep. (2010 – 2016) • LPL Financial Corporation, Reg. Principal (2003 – 2010) • Sutro & Co. (bought by RBC Dain Rauscher), Financial Consultant (2000 – 2003) • First Union Securities, Marketing (2000 – 2000) • Digitas, Vice President, Finance (1999 – 2000) • Thomson Financial Services (now ThomsonReuters) VP Finance (1993 – 1999) • Sara Lee Knit Products, Process Manager (1992 – 1993) • Walt Disney Corporation, Financial Analyst (1991 – 1991) • Arthur Andersen, Senior Consultant (1987 – 1990) Professional Certifications: • CPA - Certified Public Accountant • PFS - Personal Financial Specialist • Life, Health & Disability Licensed S0174696.1 19  Todd Frank’s Professional Certifications Todd E. Frank maintains professional designations, which required the following minimum requirements: CPA – Certified Public Accountant Issued by: State Boards of Accountancy Prerequisites/Experience Required: Candidate must meet the following requirements: • Minimum experience levels (most states require at least one year of experience providing services that involve the use of accounting, attest, compilation, management advisory, financial advisory, tax or consulting skills, all of which must be achieved under the supervision of or verification by a CPA); • Successful passing of the Uniform CPA Examination Educational Requirements: At minimum, a college education (typically 150 credit hours with at least a baccalaureate degree and a concentration in accounting); Examination Type: Uniform CPA Examination Continuing Education/Experience Requirements: Completion of 40 hours of continuing professional education each year (or 80 hours over a two year period) in order to maintain a CPA license PFS – Personal Financial Specialist Issued by: American Institute of Certified Public Accountants (AICPA). Prerequisites/Experience Required: Candidate must meet the following requirements: • Must hold an unrevoked CPA license; • Fulfill 3,000 hours of personal financial planning business experience; • Complete 80 hours of personal financial planning continuing professional education credits; • Pass a comprehensive financial planning exam (PFS Exam); and • Be an active member of the AICPA Educational Requirements: Must meet minimum education requirements for CPA. S0174696.1 20  Examination Type: PFS Exam Continuing Education Requirements: Completion of 20 hours of financial planning relevant Continuing Professional Development (CPD) each year. Linda A. Halleran Born: 1966 Education Background: • Sierra College, Rocklin A.A. Degree, General Studies 1997 Business Background: • Frank Financial Advisors (aka) Frank Financial Services, Administrative Manager (2021 – Present) • Frank Financial Advisors (aka) Frank Financial Services, Investment Adviser Representative (2021 – Present) • Goldman Sachs Private Financial Management (formerly United Capital Financial Advisors) Client Service Manager (2015-2021) • Valley Wealth Financial Advisors – Client Service Manager (2012-2015) • Halleran Insurance & Financial Services – Broker/Owner (2007-2012) Linda Halleran’s Professional Certifications: • Life, Health & Disability Licensed S0174696.1 21  Disciplinary Information Neither Frank Financial Advisors nor any Supervised Persons have been involved in any activities requiring a disciplinary disclosure. Other Business Activities Mr. Frank spends time in the following outside business activities: • Sale of non-variable life, health and disability insurance through various carriers. • Sprite Capital, LLC, a residential real estate management company that solely manages Frank Family real estate, Managing Member Ms. Halleran maintains her non-variable life, health and disability insurance through various carriers. Additional Compensation Mr. Frank receives outside compensation for those outside business activities disclosed above. Ms. Halleran receives outside compensation for those outside business activities disclosed above. Supervision Todd E. Frank, Chief Compliance Officer supervises all persons named in this Form ADV Part 2B Investment Adviser Brochure Supplement. Todd E. Frank supervises these persons by holding regular staff, investment and other ad hoc meetings. In addition, Todd E. Frank regularly reviews client reports, emails, and trading, as well as employees’ personal securities transaction and holdings reports. Todd E. Frank may be reached at 760-438-3360. S0174696.1 22