FRIDAY FINANCIAL

Item 1 – Cover Page Friday Financial, Inc. 600 Star Brewery Drive, Ste 400 Dubuque, IA 52001 (563) 552-7526 February 09, 2026 This Brochure provides information about the qualifications and business practices of Friday Financial, Inc. If you have any questions about the contents of this Brochure, please contact us at the phone number 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. Friday Financial is a registered investment adviser. Registration of an Investment Advisor does not imply any level of skill or training. The oral and written communications of an Advisor provide you with information about which you determine to hire or retain an Advisor. Additional information about Friday Financial is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The CRD number for Friday Financial is 329748. i  Item 2 – Material Changes This Item of the Brochure discusses only specific material changes made to the Brochure since the last annual update and provides Clients with a summary of such changes. In this update, we: • Added language to disclose the use of AQR as an Independent Manager in Item 4 and Item 5; • Updated our assets under management in Item 4. 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 Brian Griffin at (563) 552-7526. Additional information about Friday Financial 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 Friday Financial who are registered, or are required to be registered, as investment adviser representatives of Friday Financial. Date of Brochure: 02/09/2026 Date of Most Recent Annual Updating Amendment: 02/09/2026 ii  Item 3 – Table of Contents Item 1 – Cover Page .................................................................................................................................................................. i Item 2 – Material Changes ....................................................................................................................................................... ii Item 3 – Table of Contents ..................................................................................................................................................... iii Item 4 – Advisory Business ...................................................................................................................................................... 1 Item 5 – Fees and Compensation ............................................................................................................................................ 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 ........................................................................................................................................... 10 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................................ 10 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 ............................................................................................................................................... 13 Item 14 – Client Referrals and Other Compensation ............................................................................................................ 14 Item 15 – Custody ................................................................................................................................................................. 15 Item 16 – Investment Discretion ........................................................................................................................................... 15 Item 17 – Voting Client Securities ......................................................................................................................................... 15 Item 18 – Financial Information ............................................................................................................................................. 16 Brochure Supplements (provided to Clients) iii  Item 4 – Advisory Business Friday Financial, Inc. is an Iowa corporation owned by Ryan Burbach, Nicholas Heiar, and Brian Griffin. Friday Financial has been providing advisory services since 2024. As of December 31, 2025, Friday Financial managed $408,704,683 on a discretionary basis and $619,332 on a non-discretionary basis, for a total of $409,324,015 assets under management. Friday Financial also advised on $42,405,904 of retirement plan assets. Managed funds and advised funds totaled $451,729,919. Friday Financial offers a variety of investment advisory services to our Clients with discretionary authority. Friday Financial’s services include investment management, financial planning and consulting services. Prior to providing advisory services, Clients are required to enter into a written agreement with Friday Financial. Investment Management Services Friday Financial manages investment portfolios for individuals, trusts, charitable organizations, businesses and qualified retirement plans. Friday Financial will work with a Client to determine the Client's investment objectives and investor risk profile and will design a written investment policy statement. Friday Financial uses investment and portfolio allocation software to evaluate alternative portfolio designs. Friday Financial evaluates the Client's existing investments with respect to the Client's investment policy statement. Friday Financial works with new Clients to develop a plan to transition from the Client's existing portfolio to the portfolio recommended by Friday Financial. Friday Financial will then continuously monitor the Client's portfolio holdings and the overall asset allocation strategy and hold review meetings with the Client regarding the account as necessary. Friday Financial will typically create a portfolio of no-load mutual funds and may use model portfolios if the models match the Client's investment policy. Friday Financial will allocate the Client's assets among various investments taking into consideration the overall management style selected by the Client. Friday Financial primarily recommends portfolios consisting of passively managed asset class and index mutual funds. Friday Financial primarily recommends mutual funds that follow a passive asset class investment philosophy with low holdings turnover. Client portfolios may also include some individual equity securities in situations where disposition of these securities would present an overriding tax implication or the Client specifically requests they be retained for a personal reason. These situations will be specifically identified in the Client’s Investment Policy Statement (“IPS”). Friday Financial manages mutual fund and equity portfolios on a discretionary basis according to the investment policy selected by the Client. A Client may impose any reasonable restrictions on Friday Financial’s discretionary authority, including restrictions on the types of securities in which Friday Financial may invest Client’s assets and on specific securities, which the Client may believe to be appropriate. 1  Friday Financial has retained Focus Partners Advisor Solutions (“FPAS”) to act as a discretionary sub- advisor. FPAS shall provide various model asset allocation portfolios (each a “Portfolio”, collectively “Portfolios”) for selection by Friday Financial. Each Portfolio strives to achieve long-term risk and return objectives through diversification among multiple asset classes using investment options available to FPAS, which may include, but are not limited to, mutual funds and/or exchange traded funds from Dimensional Fund Advisors LP, Bridgeway Capital Management, Inc., AQR Capital Management, LLC, The Vanguard Group, Inc., Stoneridge Asset Management, LLC or other providers selected by FPAS. Each Portfolio is designed to meet a particular investment goal which Friday Financial has determined is suitable based on the Client's circumstances. Once the appropriate Portfolio(s) has been determined, the Portfolio will continuously be managed based on the Portfolio’s goal and FPAS will have the discretionary authority to manage the Portfolio(s), including periodically rebalancing. However, Friday Financial, on behalf of its Client, will have the opportunity to place reasonable restrictions on the types of investments to be held in the Portfolio. Should material life events occur, Clients should immediately contact Friday Financial to determine if changes to an account and the allocation of the assets held in the account are necessary. Additionally, in certain circumstances, as determined by Friday Financial and the client, Friday Financial engages AQR Capital Management, LLC (“AQR”) as an Independent Manager to manage portfolios of individual securities for clients. In these instances, AQR’s fees are separate, distinct, and in addition to Friday Financial’s advisory fees. On an ongoing basis, Friday Financial will answer Clients’ inquiries regarding their accounts and review periodically with Clients the performance of their accounts. Friday Financial will periodically, and at least annually, review Clients’ investment policy and discuss the re-balancing of each Client's accounts to the extent appropriate. Friday Financial will provide to investment manager any updated Client financial information or account restrictions necessary for investment manager to provide sub-advisory services. In addition to managing the Client’s investment portfolio, Friday Financial may consult with Clients on various financial areas including income and estate tax planning, business sale structures, college financial planning, retirement planning, insurance analysis, personal cash flow analysis, establishment and design of retirement plans and trust designs, among other things. Friday Financial does not participate in or sponsor any wrap fee programs. Financial Planning Services Friday Financial offers a broad range of financial planning and consulting services for our Clients. Financial Planning services are provided in conjunction with our investment management services. Financial Planning includes, in all or part, but is not limited to, the preparation of a financial plan which may include reviews and recommendations on any or all of the following areas depending on the Client’s circumstances: • Investment Planning • Investment Policy Statements • Portfolio Review and Evaluation • Budgeting and Cash Flow Planning 2  • Debt Management • Capital Needs Analysis (Goal Funding) • Insurance Analysis • Employee Benefits • Tax Management & Planning • Trust and Estate Planning • Charitable Giving • Social Security • Retirement Planning Financial planning services can vary and are customized depending on each Client’s complexity and circumstances. The financial planning services will be defined and agreed upon by both parties in advance. For example, a Client not using Friday Financial’s investment management services may request a comprehensive financial plan, or certain components of our planning services. The amount of time it takes to provide each of the financial planning services will depend on the Client’s unique circumstances and will vary from Client to Client. Our services are customized based on what a Client may request. In addition, the amount of time it takes to provide these services is dependent on the quality and scope of the information that is provided by the Client to the advisor. Friday Financial’s financial planning service follows the process and average timeframe below: 1) Establish/define relationship with Client – This includes meeting with Clients to discuss Friday Financial’s service offerings. We will also spend time learning about the Client’s situation, goals, objectives, attitudes and values and overall satisfaction with the Client’s current financial situation. 2) Data gathering – Friday Financial will work with the Client to collect necessary data regarding multiple aspects of a Client’s financial situation and, where applicable, confer with outside financial professionals with whom the Client may be working. 3) Analyze Client situation and develop initial recommendations a. Budgeting and Cash Flow Planning – We will review income and expenses. Friday Financial may provide suggestions for expense reductions in certain situations. We will also address any concerns the Client may have currently or that we may foresee occurring in the future. b. Portfolio review and evaluation – We ensure investment accounts are properly diversified, in line with stated goals and objectives, and risk assumed is in line with Client’s objectives and comfort level. We review fees to verify fees being charged are not excessive. We ensure tax sensitivity is accounted for (where applicable). We will review stock options (where applicable). We may make recommendations to rebalance employer sponsored retirement programs (where applicable). c. Insurance analysis – We will review insurance policies in force, including life, disability, property and casualty, and long-term care. While we do not sell or recommend specific insurance products to purchase, we will perform a cost/benefit analysis. We will also perform an insurance needs analysis. 3  d. Employee benefits review – We review the Client’s benefits package to ensure Clients are taking full advantage of offerings available. e. Tax management – We will review the last 5 years of tax returns. We perform analysis to ensure the Client’s tax situation is being optimally managed both currently and in retirement. We conduct analysis to coordinate tax efficient withdrawal strategies in retirement. We do not prepare taxes and will coordinate with Client’s CPA. f. Estate plan review – We review documents currently in place and make recommendations for the Client to complete or revise missing or outdated documents in with their legal professional. g. Charitable giving – In cases where the Client has charitable intentions, we will review and provide charitable planning strategies. We will work with the Client’s legal professionals and/or CPA to implement the strategies the Client elects to adopt. h. Social Security analysis – We analyze the optimal time for each spouse to begin benefits, in coordination with other retirement income sources. i. Pension/Annuity analysis (if applicable) – We help determine the appropriate timing to begin receiving withdrawals, and appropriate method for taking withdrawals. j. Retirement Planning – We determine a tax efficient withdrawal sequence. We review the feasibility of Roth IRA conversions. k. Scenario development – We stress test the Client’s situation against unfortunate events (for example, a long-term care need, increase in expenses, increase in inflation). 4) Initial recommendation presentation a. We present our initial findings to the Client and discuss the findings. b. We prepare custom scenarios a Client may request (for example, wanting to retire early or purchase a vacation home) 5) Implementation of Financial Planning Recommendations a. We work with Clients to prioritize recommendations and put the recommendations into place. This may involve making a recommendation to an outside financial professional such as an attorney, accountant, or insurance agent. b. We will meet with the outside financial professional along with the Client if a more advanced strategy is being contemplated (such as substantial gifting). c. We may consult on cash flow – assist with implementation of expense monitoring suggestions (if applicable). 6) Monitor and Review a. Monitor cash flow – income, expenses, and spending if requested by the Client. b. Provide an annual review of tax returns and update Client information. We discuss any questions we may have regarding their tax situation. c. Provide investment account monitoring/rebalancing/suggestions for tax efficiency, d. Consult when new financial situations arise. This may include new investment opportunities; new major purchases; changes to insurance; modifications to estate plan; or new desires for gifting. e. We will meet with Clients at least annually. 4  Clients are free to decline any offer of financial planning services. Should a Client choose to implement the recommendations in the plan, Friday Financial suggests the Client work closely with his/her attorney, accountant or insurance agent. Implementation of financial plan recommendations is entirely at the Client’s discretion. Clients are encouraged to review their plan on a regular basis, especially if there are any changes in their financial situation, goals, need, or investment objectives. In certain circumstances, as agreed to between the Client and Friday Financial, these financial planning services may be scaled back to match the Client’s needs. These services are outlined in the Client’s financial planning agreement. Employee Benefit Retirement Plan Services Friday Financial provides advisory services to participant-directed retirement plans through third-party administration services, which are online bundled service providers offering an opportunity for plan sponsors to provide their participants with daily account access, valuation, and investment education. Friday Financial will analyze the plan's current investment platform and assist the plan in creating an investment policy statement defining the types of investments to be offered and the restrictions that may be imposed. Friday Financial will recommend investment options to achieve the plan's objectives, provide participant education meetings, and monitor the performance of the plan's investment vehicles. Friday Financial will recommend changes in the plan's investment vehicles as appropriate from time to time. Friday Financial generally will review the plan's investment vehicles and investment policy as necessary. For certain retirement plans, Friday Financial also works in coordination and support with FPAS and other 3(38) fiduciary providers (“fiduciary providers”). Retirement plan Clients will engage both Friday Financial and the fiduciary provider. The fiduciary provider will administer to the Client additional discretionary investment management services and will exercise discretionary authority to select the plan investments made available to the plans’ participants by selecting and maintaining the plans’ investments according to the goals and investment objectives of the plan. Friday Financial will continue to work with plans to monitor plan investments, provide fiduciary plan advice including regular considerations of the goals and objectives of the plan, and provide participant education services to the plan. Item 5 – Fees and Compensation In certain circumstances, all fees, portfolio minimums and their applications to family circumstances may be negotiable. Friday Financial has contracted with Focus Partners Advisor Solutions (“FPAS”) for services including trade processing, collection of management fees, record maintenance, report preparation, marketing assistance, and research. Friday Financial has also contracted with FPAS for sub-advisory services with respect to Clients’ accounts. Friday Financial pays a fee for FPAS’s services based on management fees paid to Friday Financial on accounts which use FPAS. The fee paid by Friday Financial to FPAS consists of a portion of the fee paid by Clients to Friday Financial and varies based on the total Client assets administered and/or sub-advised by FPAS through Friday Financial. These fees are not separately charged to advisory Clients. The fee charged by Friday Financial to its Clients includes all sub-advisory fees charged by FPAS. 5  The specific manner in which fees are charged by Friday Financial is established in a Client’s written agreement with Friday Financial. Investment Management Clients will be invoiced in advance at the beginning of each calendar quarter based upon the value (market value based on independent third- party sources or fair market value in the absence of market value; Client account balances on which Friday Financial calculates fees may vary from account custodial statements based on independent valuations and other accounting variances, including mechanisms for including accrued interest in account statements) of the Client’s account at the end of the previous quarter. New accounts are charged a prorated fee for the remainder of the quarter in which the account is incepted (date of account transfer). For Investment Management Services, Friday Financial will request authority from the Client to receive quarterly payments directly from the Client's account held by an independent custodian. Clients may provide written limited authorization to Friday Financial or its designated service provider, FPAS, to withdraw fees from the account. Clients will receive custodial statements showing the advisory fees debited from their account(s). Certain third-party administrators will calculate and debit Friday Financial’s fee and remit such fee to Friday Financial. A Client agreement may be canceled at any time, by either party, for any reason upon receipt of thirty (30) days’ written notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded. The Client has the right to terminate an agreement without penalty within five (5) business days after entering into the agreement. Friday Financial’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the Client. Clients may incur certain charges imposed by custodians, brokers, third party investment and other third parties such as fees charged by managers, custodial fees, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. These fees will generally include a management fee and other fund expenses. All fees paid to Friday Financial for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and ETFs to their shareholders. Such charges, fees and commissions are exclusive of and in addition to Friday Financial’s fee, and Friday Financial shall not receive any portion of these commissions, fees, and costs. Investment Management Services The annual fee for investment management services will be charged as a percentage of assets under management, according to the schedule below: Assets Under Management On the first $1,000,000* On the next $1,000,000 On the next $3,000,000 On all amounts thereafter Annual Fee (%) 1.00% 0.90% 0.70% 0.50% 6  * Friday Financial’s minimum portfolio size is $250,000. All accounts for members of the Client’s family (husband, wife and dependent children) or related businesses may be assessed fees based on the total balance of all accounts. Independent Manager Fees As stated above in Item 4, Friday Financial (in coordination with the client) may decide to implement AQR as an Independent Manager for the management of portfolios of individual securities. In these instances, AQR will charge its own separate and distinct fee from Friday Financial’s advisory fees, which are noted above. Clients grant AQR authority at the client’s custodian for AQR to directly debit client accounts for AQR’s fee. Additionally, clients are required to sign an advisory agreement addendum with Friday Financial which outlines these additional fees. Employee Benefit Retirement Plan Services The annual fee for plan services will be charged as a percentage of assets within the plan. Fees charged range based on the Client’s needs, services, and assets managed. In no instance shall Friday Financial’s fees exceed 1% per year, charged quarterly in advance. The specific fee charged will be explicitly laid out in the Client’s agreement. The 3(38) fiduciaries referenced above in Item 4 charge a separate and distinct fee for their services, as laid out and agreed to in the Client agreement. Item 6 – Performance-Based Fees and Side-By-Side Management Friday Financial 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). All fees are calculated as described above and are not charged on the basis of income or capital gains or capital appreciation of the funds or any portion of the funds of an advisory Client. Item 7 – Types of Clients Friday Financial provides services to individuals, high-net-worth individuals, trusts, estates, and corporations. As stated above in Item 5, the minimum portfolio size for clients working with Friday Financial is $250,000. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategy Friday Financial's services are based on long-term investment strategies incorporating the principles of Modern Portfolio Theory. Friday Financial's investment approach is firmly rooted in the belief that markets are "efficient" over periods of time and that investors' long-term returns are determined principally by asset allocation decisions, rather than market timing or stock picking. Friday Financial recommends diversified portfolios, principally through the use of passively managed, asset class mutual funds. Friday Financial selects or recommends portfolios of broadly-traded, open end mutual funds, ETFs, and fixed income securities to implement this investment strategy. 7  Although all investments involve risk, Friday Financial's investment advice seeks to limit risk through broad diversification among asset classes and, as appropriate for particular Clients, the investment directly in conservative fixed income securities to represent the fixed income class. Friday Financial's investment philosophy is designed for investors who desire a buy and hold strategy. Frequent trading of securities increases brokerage and other transaction costs that Friday Financial's strategy seeks to minimize. In the implementation of investment plans, Friday Financial therefore primarily uses mutual funds and, as appropriate, portfolios of conservative fixed income securities. Friday Financial may also utilize Exchange Traded Funds (“ETFs”) to represent a market sector. Clients may hold or retain other types of assets as well, and Friday Financial may offer advice regarding those various assets as part of its services. Advice regarding such assets will generally not involve asset management services but may help to more generally assist the Client. Friday Financial’s strategies do not utilize securities that we believe would be classified as having any unusual risks and we do not recommend frequent trading, which can increase brokerage and other costs and taxes. Friday Financial receives supporting research from Focus Partners Advisor Solutions and from other consultants, including economists affiliated with Dimensional Fund Advisors (“DFA”). Friday Financial utilizes DFA mutual funds in Client portfolios. DFA mutual funds follow a passive asset class investment philosophy with low holdings turnover. DFA provides historical market analysis, risk/return analysis, and continuing education to Friday Financial. Analysis of a Client’s Financial Situation In the development of investment plans for Clients, including the recommendation of an appropriate asset allocation, Friday Financial relies on an analysis of the Client’s financial objectives, current and estimated future resources, and tolerance for risk. To derive a recommended asset allocation, Friday Financial may use a Monte Carlo simulation, a standard statistical approach for dealing with uncertainty. As with any other methods used to make projections into the future, there are several risks associated with this method, which may result in the Client not being able to achieve their financial goals. They include: • The risk that expected future cash flows will not match those used in the analysis; • The risk that future rates of return will fall short of the estimates used in the simulation; • The risk that inflation will exceed the estimates used in the simulation; and • For taxable Clients, the risk that tax rates will be higher than was assumed in the analysis. Risk of Loss Investing in securities involves risk of loss that Clients should be prepared to bear. All investments present the risk of loss of principal – the risk that the value of securities (mutual funds, ETFs and individual bonds), when sold or otherwise disposed of, may be less than the price paid for the securities. Even when the value of the securities when sold is greater than the price paid, there is the risk 8  that the appreciation will be less than inflation. In other words, the purchasing power of the proceeds may be less than the purchasing power of the original investment. The mutual funds and ETFs utilized by Friday Financial may include funds invested in domestic and international equities, including real estate investment trusts (REITs), corporate and government fixed income securities and commodities. Equity securities may include large capitalization, medium capitalization and small capitalization stocks. Mutual funds and ETF shares invested in fixed income securities are subject to the same interest rate, inflation and credit risks associated with the underlying bond holdings. Among the riskiest mutual funds used in Friday Financial’s investment strategies funds are the U.S. and International small capitalization and small capitalization value funds, emerging markets funds, and commodity futures funds. Conservative fixed income securities have lower risk of loss of principal, but most bonds (with the exception of Treasury Inflation Protected Securities, or TIPS) present the risk of loss of purchasing power through lower expected return. This risk is greatest for longer-term bonds. Certain funds utilized by Friday Financial may contain international securities. Investing outside the United States involves additional risks, such as currency fluctuations, periods of illiquidity and price volatility. These risks may be greater with investments in developing countries. Interval Fund Risk An interval fund is a type of closed-end fund containing shares that do not trade on the secondary market. Instead, the fund periodically offers to buy back a percentage of outstanding shares at net asset value. The rules for interval funds, along with the types of assets held, make this investment largely illiquid compared with other funds. The primary reasons for investors to consider investing in interval funds Friday Financial may utilize include, but are not limited to, gaining exposure to certain risk categories that provide diversified sources of expected returns, part of which may be in the form of illiquidity premiums. Access to the intended risk and expected return characteristics may not otherwise be available in more liquid, traditional investment vehicles. Where appropriate, Friday Financial may utilize certain interval funds structured as non-diversified, closed-end management investment companies, registered under the Investment Company Act of 1940. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender shares when or in the amount desired, and the fund may suspend or postpone purchases. Clients should carefully review the fund’s prospectus to more fully understand the interval fund structure and the corresponding liquidity risks. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a Client’s investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some or all of the investment. 9  The risk of loss described herein should not be considered to be an exhaustive list of all the risks which Clients should consider. More information about the risks of any particular market sector can be reviewed in representative mutual fund prospectuses managing assets within each applicable sector. Item 9 – Disciplinary Information Registered investment advisors are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Friday Financial or the integrity of Friday Financial’s management. Friday Financial has no information applicable to this Item. Item 10 – Other Financial Industry Activities and Affiliations The principal business of Friday Financial is that of a registered investment advisor. Some of our employees are also licensed insurance agents. Those employees can review insurance policies and provide analysis as part of Friday Financial’s financial planning services. Employees who are insurance agents may also be paid separate, yet customary commission compensation based on these services they provide. In cases where we receive additional payment, a conflict of interest exists. At all times, you are free to choose an outside agency. The implementation of any and all recommendations is solely at the discretion of the Client. Friday Financial will disclose any material conflict of interest relating to Friday Financial, our representatives, or any of our associates which could reasonably be expected to affect the decision- making of our Clients. Focus Partners Advisor Solutions, LLC As described above in Item 4, Friday Financial will exercise discretionary authority provided by a Client to select an independent third-party investment manager for the management of portfolios of securities. Friday Financial has selected Focus Partners Advisor Solutions (“FPAS”) for such sub-advisory management and also contracts with FPAS for back-office services. Friday Financial has a fiduciary duty to select qualified and appropriate managers in the Client’s best interest and believes that FPAS effectively provides both the back-office services that assist with its overall investment advisory practice and sub-advisory services. Friday Financial continuously analyzes and assesses the use of FPAS in this capacity. While Friday Financial has a contract with FPAS governing a time period for back-office services, Friday Financial has no such fixed commitment to the selection of FPAS for sub-advisory services and may select another investment manager for Clients upon reasonable notice to FPAS. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Friday Financial has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of business conduct, and fiduciary duty to its Clients. The Code of Ethics includes provisions relating to the confidentiality of Client information, a prohibition on insider trading, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and 10  personal securities trading procedures, among other things. All supervised persons of Friday Financial must acknowledge the terms of the Code of Ethics annually, or as amended. Friday Financial or individuals associated with Friday Financial may buy or sell securities identical to those recommended to Clients for their personal accounts. In addition, any related person(s) may have an interest or position in a certain security(ies) which may also be recommended to a Client. It is the expressed policy of Friday Financial that no person employed by Friday Financial will take inappropriate advantage of their positions, and the interests of Client accounts will be placed first at all times. Friday Financial anticipates that, in appropriate circumstances, consistent with Clients’ investment objectives, it will cause accounts over which Friday Financial has management authority to effect, and will recommend to investment advisory Clients or prospective Clients, the purchase or sale of securities in which Friday Financial, its affiliates and/or Clients, directly or indirectly, have a position of interest. Friday Financial’s employees and persons associated with Friday Financial are required to follow Friday Financial’s Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors and employees of Friday Financial and its affiliates may trade for their own accounts in securities which are recommended to and/or purchased for Friday Financial’s Clients. The Code of Ethics is designed to ensure the personal securities transactions, activities and interests of the employees of Friday Financial 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. Under the Code, certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of Friday Financial’s Clients. In addition, the Code requires pre-clearance of certain transactions. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as Clients, there is a possibility that employees might benefit from market activity by a Client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between Friday Financial and its Clients. Friday Financial will provide a complete copy of its Code of Ethics to any Client or prospective Client upon request. It is Friday Financial’s policy that the firm will not affect any principal or agency cross securities transactions for Client accounts. Friday Financial will also not cross trades between Client accounts. Principal transactions are generally defined as transactions where an advisor, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory Client. A principal transaction may also be deemed to have occurred if a security is crossed between an affiliated private fund and another Client account. An agency cross transaction is defined as a transaction where a person acts as an investment advisor in relation to a transaction in which the investment advisor, or any person controlled by or under common control with the investment advisor, acts as broker for both the advisory Client and for another person on the other side of the transaction. Agency cross transactions may arise where an advisor is dually registered as a broker-dealer or has an affiliated broker-dealer. Item 12 – Brokerage Practices 11  Friday Financial arranges for the execution of securities transactions with the operational assistance of Focus Partners Advisor Solutions (“FPAS”). Through FPAS, Friday Financial participates in the Schwab Advisor Services program offered to independent investment advisers by Charles Schwab & Company, Inc. (“Schwab”) and the Fidelity Institutional Wealth Services (“FIWS”) program, sponsored by Fidelity Brokerage Services. Schwab and Fidelity are unaffiliated SEC-registered broker dealers and FINRA member broker dealers. Schwab and FIWS offers services which include custody of securities, trade execution, clearance and settlement transactions. Schwab will generally be recommended to advisory Clients for the execution of mutual fund and equity securities transactions. Friday Financial regularly reviews these programs to ensure that its recommendations are consistent with its fiduciary duty. These trading platforms are essential to Friday Financial's service arrangements and capabilities, and Friday Financial may not accept Clients who direct the use of other brokers. As part of this program, Friday Financial receives benefits that it would not receive if it did not offer investment advice (See the disclosure under Item 14 of this Brochure). Since Friday Financial will not request the discretionary authority to determine the broker dealer to be used or the commission rates to be paid for mutual fund and equity securities transactions, Clients must direct Friday Financial as to the broker dealer to be used. In directing the use of a particular broker or dealer, it should be understood that Friday Financial will not have authority to negotiate commissions among various brokers or obtain volume discounts, and best execution may not be achieved. Not all investment advisors require Clients to direct the use of specific brokers. Friday Financial will not exercise authority to arrange Client transactions in fixed income securities. Clients will provide this authority to a fixed income manager retained by Friday Financial on Client's behalf by designating the portfolio manager with trading authority over Client's brokerage account. Clients will be provided with the Disclosure Brochure (Form ADV Part 2) of the fixed income manager. In this situation, Friday Financial will monitor the fixed income trading services provided by FPAS to assess the quality of broker dealer services and Client fixed income transactions, and approve the selection of those brokers or dealers which will provide the best services at the lowest commission rates possible. The reasonableness of brokerage costs, commissions and mark up/mark downs is based on the broker dealer's ability to provide professional services, competitive execution, and other services that will help Friday Financial in providing investment management services to Clients. Through FPAS’s trading desk, Client trades in fixed income securities may be blocked with transactions by other investment advisers participating in the Focus Partners Advisor Solutions program to achieve better pricing and commission costs. While this procedure will generally benefit Clients, certain trades may only be partially filled, in which case a Client's order may not be fulfilled. Partially filled orders will be allocated to the first orders received by Focus Partners Advisor Solutions for inclusion in the block trades. Friday Financial generally does not aggregate any Client transactions in mutual fund or other securities. Client accounts are individually reviewed and managed, and transaction costs are not saved by aggregating orders in almost all circumstances in which Friday Financial arranges transactions. FPAS, in the management of portfolios, will aggregate certain transactions among Client accounts that it 12  manages, in which case a Friday Financial Client’s order may be aggregated with an order for another Client of FPAS who is not a Friday Financial Client. See FPAS’s Form ADV Part 2. Friday Financial also does not have any arrangements to compensate any broker dealer for Client referrals. When trading Client accounts, errors may periodically occur. Friday Financial does not maintain any Client trade error gains. Friday Financial makes Client whole with respect to any trade error losses incurred by Client and caused by Friday Financial. Financial Planning Services: Friday Financial’s financial planning practice, due to the nature of its business and Client needs, does not include blocking trades, negotiating commissions with broker dealers or obtaining volume discounts, nor necessarily obtaining the best price. Clients will be required to select their own broker dealers and insurance companies for the implementation of financial planning recommendations. Friday Financial may recommend any one of several brokers. Clients must independently evaluate these brokers before opening an account. The factors considered by Friday Financial’s when making this recommendation are the broker's ability to provide professional services, Friday Financial experience with the broker, the broker's reputation, and the broker's financial strength, among other factors. Clients that receive financial planning services may use any broker or dealer of their choice. Item 13 – Review of Accounts Reviews Investment Management Services Account assets are supervised continuously and formally reviewed at least annually by an investment advisor representative of Friday Financial. The review process contains each of the following elements: a. assessing Client goals and objectives; b. evaluating the employed strategy(ies); c. monitoring the portfolio(s); and d. addressing the need to rebalance. Additional account reviews may be triggered by any of the following events: a. a specific Client request; b. a change in Client goals and objectives; c. an imbalance in a portfolio asset allocation; and d. market/economic conditions. For accounts on the FPAS platform, certain account review responsibilities are delegated to FPAS as described above in Item 4. Employee Benefit Retirement Plan Services Plan assets are reviewed on a quarterly basis or as otherwise agreed between the parties, and according to the standards and situations described above for investment management accounts. 13  Reports Investment Management Services: All Clients will receive written quarterly performance reports from Friday Financial that summarize the Client's account and asset allocation. Clients will also receive at least quarterly statements from their account custodian, which will outline the Client's current positions and current market value. Employee Benefit Retirement Plan Services Plan sponsors are provided with quarterly information and annual performance reviews from Friday Financial. In addition, plan participant education information may also be provided to the Plan Sponsor or Administrator for distribution to the participants of the plan. Item 14 – Client Referrals and Other Compensation As indicated under the disclosure for Item 12, Schwab and Fidelity provide Friday Financial with access to services which are not available to retail investors. These services generally are available to independent investment advisors on an unsolicited basis at no charge to them. These services benefit Friday Financial but may not benefit its Clients' accounts. Many of the products and services assist Friday Financial in managing and administering Clients' accounts. These include software and other technology that provide access to Client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple Client accounts), provide research, pricing information and other market data, facilitate payment of Friday Financial's fees from its Clients' accounts, and assist with back-office functions, recordkeeping and Client reporting. Many of these services generally may be used to service all or a substantial number of Friday Financial's accounts. Schwab and Fidelity also make available to Friday Financial other services intended to help Friday Financial manage and further develop its business enterprise. These services may include consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, and marketing. Friday Financial does not, however, enter into any commitments with Schwab or Fidelity for transaction levels in exchange for any services or products from brokers. While as a fiduciary, Friday Financial endeavors to act in its Clients' best interests, Friday Financial's requirement that Clients maintain their assets in accounts at Schwab or Fidelity may be based in part on the benefit to Friday Financial of the availability of some of the foregoing products and services and not solely on the nature, cost or quality of custody and brokerage services provided by the brokers, which may create a potential conflict of interest. Friday Financial also receives software from DFA, which Friday Financial utilizes in forming asset allocation strategies and producing performance reports. DFA also provides continuing education for Friday Financial personnel. These services are designed to assist Friday Financial plan and design its services for business growth. As previously disclosed, employees of Friday Financial, in their individual capacities, are licensed insurance agents. As such, these individuals are able to receive separate, yet customary commission compensation resulting from implementing insurance product transactions on behalf of advisory Clients. Clients, however, are not under any obligation to engage these individuals when considering 14  implementation of recommendations. The implementation of any or all recommendations is solely at the discretion of the Client. Friday Financial does not engage in any referral arrangements. Item 15 – Custody Friday Financial is considered to have limited custody due to automatic fee deduction. In order to prevent Friday Financial from being deemed as maintaining custody of portfolio management Client assets, we will ensure the following: a) Clients provide written authorization for Friday Financial to deduct advisory fees from the custodial accounts in the Client’ advisory agreement; and b) Friday Financial has a reasonable belief that the account custodian sends at least quarterly statements directly to the Client showing all disbursements from the custodial account, including Friday Financial’s advisory fee. Clients should receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains Client’s investment assets. Friday Financial urges you to carefully review such statements and compare such official custodial records to the account statements that we may provide to you. Our statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Item 16 – Investment Discretion Friday Financial requests that it be provided with written authority to determine which securities and the amounts of securities that are bought or sold. For sub-advisory services, this authority will include the discretion to retain a third-party independent manager. Any limitations on this discretionary authority shall be included in this written authority statement. Clients may change/amend these limitations as required. Such amendments shall be submitted in writing. When selecting securities and determining amounts, Friday Financial observes the investment policies, limitations and restrictions of the Clients for which it advises. Investment guidelines and restrictions must be provided to Friday Financial in writing. Item 17 – Voting Client Securities Proxy Voting As a matter of firm policy and practice, Friday Financial does not accept the authority to and does not vote proxies on behalf of advisory Client. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in Client portfolios. Clients will receive applicable proxies directly from the issuer of securities held in Clients’ investment portfolios. Friday Financial, however, may provide advice to Clients regarding the Clients' voting of proxies. Class Actions, Bankruptcies and Other Legal Proceedings 15  Clients should note that Friday Financial will neither advise nor act on behalf of the Client in legal proceedings involving companies whose securities are held or previously were held in the Client’s account(s), including, but not limited to, the filing of “Proofs of Claim” in class action settlements. If desired, Clients may direct Friday Financial to transmit copies of class action notices to the Client or a third party. Upon such direction, Friday Financial will make commercially reasonable efforts to forward such notices in a timely manner. Item 18 – Financial Information Registered investment advisors are required in this Item to provide you with certain financial information or disclosures about Friday Financial’s financial condition. Friday Financial does not require or solicit prepayment of more than $500 in fees per Client, six (6) months or more in advance. Friday Financial 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. 16