GALLOWAY ASSET MANAGEMENT LLC

Registered Investment Advisor Disclosure Brochure Form ADV Part 2A Public Safety Financial/Galloway 1138 N Alma School Rd, Suite 201 Mesa, AZ 85201 480.325.8668 1.877.778.2351 (Toll Free) 480.325.1664 (Fax) www.Galloway911.com April 07, 2025 This brochure provides information about the qualifications and business practices of Galloway Asset Management, LLC DBA Public Safety Financial/Galloway (PSF/Galloway) and Galloway Asset Management, LLC DBA Galloway (Galloway). If you have any questions about the contents of this brochure, please contact us at 480-325-8668 or Mike.Galloway@Galloway911.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. Public Safety Financial/Galloway (“PSF/Galloway”, “Advisor” or “Firm”) is an investment advisor registered with the Securities and Exchange Commission (SEC). Registration does not imply any level of skill or training. Additional information about Public Safety Financial/Galloway also is available on the SEC’s website at www.adviserinfo.sec.gov. 1  Item 2 - Material Changes This Form ADV Part 2A Firm Brochure has been created to comply with new requirements adopted by the SEC on July 28, 2010. Each update of the brochure must now include a summary of all material changes since the last annual update. The following material changes since Public Safety Financial/Galloway’s last annual brochure update on March 25, 2024. • Item 4 – Financial Advisors Employed with a Public Safety Organization – Some of PSF/Galloway financial advisors work part-time PSF/Galloway and are full-time public safety employees. • The Firm’s Chief Compliance Officer changed from Cindy Lance to Michael Galloway. • Item 12 – Brokerage Practices – Any reference of TD Ameritrade was removed due to the conversion to Schwab completed on September 5, 2023. Items 4 & 5 The firm has added a third-party money manager. • 2  Item 3 - Table of Contents Contents 1 Item 1 – Cover Page ..................................................................................................... not defined. 2 Item 2 - Material Changes ............................................................................................................... 1 3 Item 3 - Table of Contents ............................................................................................................... 3 4 Item 4 - Advisory Business ............................................................................................................. 4 6 Item 5 - Fees and Compensation ..................................................................................................... 6 10 Item 6 - Performance-Based Fees and Side-By-Side Management ................................................ 9 11 Item 7 - Types of Clients ............................................................................................................... 10 12 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ........................................ 11 14 Item 9 - Disciplinary Information .................................................................................................. 13 15 Item 10 - Other Financial Industry Activities and Affiliations ..................................................... 14 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................................................................................................................ 15 16 Item 12 - Broker/Custodian Practices ............................................................................................ 16 17 Item 13 - Review of Accounts ....................................................................................................... 19 20 Item 14 - Client Referrals and Other Compensation ..................................................................... 20 21 Item 15 - Custody .......................................................................................................................... 21 22 Item 16 - Investment Discretion .................................................................................................... 22 23 Item 17 - Voting Client Securities ................................................................................................. 23 24 Item 18 - Financial Information ..................................................................................................... 24 25 3  Item 4 - Advisory Business Galloway Asset Management, LLC, DBA Public Safety Financial/Galloway (PSF/Galloway) is an investment advisor registered with the Securities and Exchange Commission (SEC) and has been in business since June 26, 2006. The principal owner of PSF/Galloway is Public Safety Financial, LLC. PSF/Galloway is a registered investment advisor firm providing investment advice and portfolio management. in accordance with PSF/Galloway offers asset allocation services known as PSF/Galloway Portfolios. PSF/Galloway Portfolios are model portfolios designed to meet differing investment objectives. Upon assessment of the client’s risk tolerance and consideration of the client’s investment objectives and financial information, PSF/Galloway may recommend a model portfolio or customized strategy that is appropriate for the client. PSF/Galloway shall be granted discretionary authority by the client to select and invest the client’s portfolio in specific investments the model portfolio or customized portfolio. Part of PSF/Galloway’s services involve elements of financial planning in which there is no charge. Client has the ability to place reasonable limitations and restrictions on the types of investments made on its behalf by PSF/Galloway. Client must request those reasonable restrictions in writing, if any, to PSF/Galloway. PSF/Galloway’s Clients are advised to promptly notify PSF/Galloway if there are any changes to all relevant information, including financial condition, net worth, or investment objections. PSF/Galloway may provide services to the participants of municipal deferred compensation plans. PSF/Galloway, upon participant’s request, offers investment allocation advice within the plan, may provide advisory services with participant’s investments thru a Self-Directed Brokerage Option, enrollment and education services. PSF/Galloway may provide a recommendation as to whether a client should engage in a rollover transaction, the Firm is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (ERISA) and /or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. Services to Municipal Government Defined Contribution Plans and Participants PSF/Galloway may provide education and training services to the participants of government defined contribution plans with an emphasis on public safety personnel. PSF/Galloway, upon participant’s request, offers investment allocation advice within the plan, may provide advisory services with participant’s investments thru a Self-Directed Brokerage Option, enrollment and education services, and PSF/Galloway portfolios are offered to members in various municipal governmental defined contribution plans. 4  Contracts with Public Safety Organizations PSF/Galloway contracts with various public safety organizations to provide financial education and training programs to members. PSF/Galloway has a contract with Public Safety Personnel Retirement System of the State of Arizona to provide education and advisory services to members. Partners with Various Plan Providers PSF/Galloway partners with various plan providers in responses to requests for proposals to provide services in municipal plans. Partners with Credit Unions PSF/Galloway has an agreement with Firefighters First Credit Union to provide financial education and investment services to entities and employees with the fire services industry. Financial Advisors Employed with a Public Safety Organization Some PSF/Galloway financial advisors work part-time for PSF/Galloway and are full-time public safety employees. PSF/Galloway advisors are required to follow their respective agency’s secondary employment policies and procedures. As public safety employees they may have supervisory responsibilities with their public safety employer. These PSF/Galloway financial advisors may enter into an Investment Advisory Agreement with a client employed at the same agency; however, there is a potential conflict if the financial advisor is a supervisor of the client. For this reason, financial advisors are prohibited from entering into an Investment Advisory Agreement with any person they have a Supervisory Relationship with at their agency. PSF/Galloway financial advisors that are full-time public safety employees will be required to acknowledge annually on the PSF/Galloway Annual Compliance Acknowledgement and Questionnaire Form, that a Supervisory Relationship has not been established with any PSF/Galloway clients. Selection of Other Advisers PSF/Galloway may direct clients to third-party investment advisers. Before selecting other advisers for clients, PSF/Galloway will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where PSF/Galloway is recommending the adviser to clients. Client Assets Managed The amount of client assets PSF/Galloway manages as of December 31, 2024 on a discretionary basis is $ 930,393,755 and on a non-discretionary basis is $ 11,841,985 . 5  Item 5 - Fees and Compensation PSF/Galloway Portfolios The annual asset-based fee for advisory services is charged as a percentage of assets under management. For directly managed accounts: • PSF/Galloway Venture Portfolios - Fee is a standard 1.25% per year, paid quarterly, in arrears for the initial quarter and in advance for subsequent quarters • PSF/Galloway All Inclusive Portfolios - Fee is a standard 1.25% per year, paid quarterly, in arrears for the initial quarter and in advance for subsequent quarters • PSF/Galloway ETF Active Portfolios - Fee is 0.75% per year, paid quarterly, in arrears for the initial quarter and in advance for subsequent quarters • PSF/Galloway ETF Passive Portfolios - Fee is 0.35% to 0.75% per year, paid quarterly, in arrears for the initial quarter and in advance for subsequent quarters All fees due are established in each client’s Investment Advisory Agreement. Clients should be aware that portfolios with different management fees creates a conflict of interest as the IAR has an incentive to recommend portfolios with the highest management fee as some of the firm’s IARs are paid a percentage of the advisory fee revenues received by the firm for clients they service. In rare circumstances, all fees may be negotiable. In addition, certain affiliated persons of PSF/Galloway and family members and personal acquaintances of PSF/Galloway’s affiliated persons may receive advisory services at a discounted rate which is not available to advisory clients generally. Advisory fees will be directly debited from a client account, with the client’s prior required written authorization. The account is held by an independent custodian and the custodian agrees to disburse these fees quarterly. The authorization will be made in writing in the form of a limited power of attorney provided by the client’s custodian. The client will receive a statement from PSF/Galloway, as well as reports from the account’s custodian. PSF/Galloway will liquidate money market shares to pay the fee and, if money market shares or cash value are not available, other investments will be liquidated. The initial assets deposited into a new account after the beginning of a quarter will result in a prorated fee (prorated and calculated in arrears and subsequent fees shall be payable in advance). Fee payment will be based on the gross value of your account(s) at the end of the calendar quarter. PSF/Galloway considers cash, including sweep money fund, to be an asset class and cash is included in the fee calculation. Quarterly billing adjustments are made for any deposits or withdrawals, including cash, made during the quarter in an account. These adjustments will result in a prorated fee for assets which were deposited or withdrew from account during the applicable quarter. 6  Clients may terminate at any time by providing a signed PSF/Galloway Termination of Advisory Services Form to PSF/Galloway. The Client may request form by contacting their IAR (Financial Advisor) or a Client Relationship Specialist at PSF/Galloway. If a client terminates, prepaid fees will be refunded on a pro-rated basis, upon client signing a PSF/Galloway Termination of Advisory Services Form. A PSF/Galloway Termination of Advisory Services Form signed by client is required to liquidate client’s account. Clients must also call PSF/Galloway to verify over the phone that they are in fact the person submitting the form. Spouses, relatives or other persons may not process the form on behalf of the client. The client is required to sign a termination agreement to receive a prorated fee refund of any unused fees. Unused fees will be prorated as of the date a PSF/Galloway Termination of Advisory Services form is received in good order. Refunds of less than $10 (ten dollars) will not be processed. In cases where clients were not provided this disclosure brochure at least 48 hours prior to entering into an advisory agreement with PSF/Galloway, the client shall have the right to terminate their agreement within five business days after entering into the agreement with a full refund of advisory fees paid (if any). Implementation of Recommendations Outside of PSF/Galloway Portfolios While PSF/Galloway’s services are provided with the intention of the client implementing recommendations within the PSF/Galloway Portfolios, clients are not obligated to do so. If clients elect to have an IAR implement the client’s recommendations outside of the PSF/Galloway Portfolios, implementation will be made through the IAR in the IAR’s capacity as a registered representative or insurance agent of Purshe Kaplan Sterling Investments (PKS). When clients implement recommendations through the IAR in one these separate capacities, the IAR will receive commissions and related compensation, such as 12b-1 or trail fees, resulting from the client’s purchase of recommended securities or insurance products (Note: PSF/Galloway’s IARs do not receive 12b-1 or trail fees for PSF/Galloway RIA business,). While PSF/Galloway has procedures in place that endeavor to at all time to put the interest of the clients first as a part of the PSF/Galloway’s fiduciary duty, clients should be aware that the receipt of commissions and additional compensation itself creates a conflict of interest and gives the IAR an incentive to recommend investment and insurance products based on the compensation received rather than on the client’s needs. Investment advisory clients are under no obligation to purchase from their PSF/Galloway IAR any securities or insurance products that he or she recommends and may purchase recommended products from the broker-dealer or insurance company of their choice. PSF/Galloway may waive or reduce the amount of the investment advisory fee as a result of the additional fees and/or commissions being earned. Any adjustment to the investment advisory fee is at the discretion of PSF/Galloway and will be disclosed to the client prior to implementing transactions. Commissions may be higher or lower at PKS than at other broker/dealers. Registered representatives are restricted to only offering those products and services that have been reviewed and approved for offering to the public by PKS and for which PKS has obtained a selling agreement. 7  Services to Municipal Government Defined Contribution Plans and Participants For services as described in Item 4 – Advisory Business, agreed upon compensation to PSF/Galloway for these services varies and is set forth through contracts with PSF/Galloway and the government entity. Contracts with Public Safety Organizations For services as described in Item 4 – Advisory Business, agreed upon compensation to PSF/Galloway for these services varies and is set forth through contracts with PSF/Galloway and public safety organizations. Partners with Various Plan Providers For services as described in Item 4 – Advisory Business, agreed upon compensation to PSF/Galloway for these services varies and is set forth through contracts and the plan providers. Additional Fees and Expenses Mutual Fund and Other Internal Investment Charges When PSF/Galloway recommends mutual funds in its PSF/Galloway Portfolios, PSF/Galloway generally recommends only no-load or load-waived mutual funds. However, all mutual funds, exchange traded funds and other investment company securities (Funds) incur certain types of charges and expenses, which are paid from the value of the mutual funds’ shares. These charges and expenses include investment management, transaction, administrative, distribution, transfer agent, custodial, legal, audit and other customary fees. If your account holds any such Fund shares, you will be indirectly paying these expenses of the respective Funds, which are in addition to your PSF/Galloway investment advisory fee. You are encouraged to read the prospectuses of any Funds which are purchased in your account for a more complete explanation of these fees and expenses. Investments Available without PSF/Galloway’s Services Clients may invest in mutual funds or other investments without the services of PSF/Galloway. In that case, the client would not receive the services provided by PSF/Galloway which are designed, among other things, to assist the client in determining which fund or funds are most appropriate to the client’s financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and the fees charged by PSF/Galloway to fully understand the total amount of fees to be paid by the client and be able to evaluate the value of the advisory services being provided. While PSF/Galloway believes its fees are competitive with fees charged by other investment advisors for comparable services, comparable services may be available from other sources for lower fees than those charged by PSF/Galloway. Tax Consequences of Transactions - No Legal or Tax Advice PSF/Galloway does not hold itself to be and is not an estate planning attorney, a certified public accountant (CPA) or a tax consultant. Referrals to other professionals may be given to clients 8  seeking answers to questions relating to such matters. in the clients Portfolio Management and Review account might have Clients are advised that any redemptions and exchanges between Funds and other securities transactions tax consequences, which clients should discuss with their independent tax advisor. Brokerage and Custodial Charges In addition to PSF/Galloway’s Advisory and Management Service fee, clients will also pay any Brokerage or custodial costs associated with their account. For more information about PSF/Galloway’s Brokerage recommendations and arrangements, please refer to Item 12 - Brokerage Practices, of this brochure. Selection of Other Advisers Fees PSF/Galloway may direct clients to third-party investment advisers under the Turn-Key Asset Management program (TAMP). PSF/Galloway will be compensated via a fee share from the advisers to which it directs those clients. PSF/Galloway’s fee is 1% with no scaling for account size. Combining separate investment strategies or adding sleeves adds an additional platform fee of 0.05% or $50/year, whichever is greater. The fees shared are negotiable and will not exceed any limit imposed by any regulatory agency. The notice of termination requirement and payment of fees for third-party investment advisers will depend on the specific third-party adviser selected. Fees are paid quarterly and in advance. The total annual fee for the Davidson Multi-Cap Equity is 1.45% which includes a management fee of 0.40% and a platform fee of 0.05%. Davidson Multi-Cap Equity is an aggressive, all-stocks strategy with a minimum investment of $50,000. The total annual fee for the Envestnet Active Passive PMC ETF is 1.00% with a minimum investment of $12,000.00. There is no management or platform fee for the Active Passive PMC ETF strategy unless two or more models or managers are selected, in which case the platform fee will be 0.05% or $50/year, whichever is greater. Envestnet Active Passive PMC ETF offers the benefits of active and passive portfolio management strategies. 9  Item 6 - Performance-Based Fees and Side-By-Side Management PSF/Galloway does not charge any performance-based fees. Performance based fees are those based on a share of capital gains on or capital appreciation of the assets of a client. All fees charged by PSF/Galloway are disclosed in Item 5 - Fees and Compensation. 10  Item 7 - Types of Clients PSF/Galloway provides services to individuals (including trusts and estates) and high net worth individuals. There is no minimum investment required to invest in PSF/Galloway Portfolios, however, it is recommended based on PSF/Galloway Portfolio strategies to invest: • Venture: $100,000 • All Inclusive: $50,000 • ETF Active and ETF Passive: $50,000 11  Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis In advising clients investing in PSF/Galloway Portfolios, PSF/Galloway develops model portfolio investment recommendations using reports from third-party sources, including Morningstar. The investments will be selected on the basis of any or all of the following criteria: the investment's performance history; the industry sector; the track record of the fund; the fund's investment objectives; the fund's management style; and the fund's management fee structure. The client's individual needs, goals and objectives, and risk tolerance are considered to determine the client’s strategy and portfolio model. Investment Strategies • The following PSF/Galloway Portfolios are currently available: PSF/Galloway Venture Portfolios -Aggressive PSF/Galloway All-Inclusive Portfolios -Aggressive -Moderately Aggressive -Moderate -Moderately Conservative -Conservative PSF/Galloway ETF Active Portfolios -Aggressive -Moderately Aggressive -Moderate PSF/Galloway ETF Passive Portfolios -Aggressive -Moderately Aggressive -Moderate • PSF/Galloway offers risk-based model portfolios in various municipal governmental defined contribution plans. • Model portfolios in an employer or deferred compensation plans is a core fund lineup and consists of allocations from funds selected by the plan. 12  Risk of Loss A risk of loss applies to all PSF/Galloway strategies. All investments, including mutual funds, exchange traded funds (ETFs), and annuity and life insurance sub-accounts involve investment risk and may lose value. Clients should note that if the firm effects short-term transactions on behalf of client accounts, such transactions may result in short term gains or losses for federal and state tax purposes. Clients should review the treatment of such tax consequences with their accountant or tax counsel. All investments and investment programs have certain risks that are associated with them and which the investor must bear. Following are the types of risk that may arise to clients due to the types of securities that are recommended to or purchased for clients or that relate to the firm’s investment strategies: Business Risk – the risk that the price of an investment will change due to factors unique to that company, investment or market segment and not the market in general. Liquidity Risk – the risk associated with the ease of being able to quickly convert the value of a security into an equivalent amount of cash. For example, money market funds are readily convertible (liquid) while certain limited partnership units or real estate are not. Financial Risk – the risk to specific companies’ future earnings due to their use of debt. Companies that borrow money must pay it back at some future date, plus the interest charges. This increases the uncertainty about the company because it must have enough income to pay back this amount at some time in the future. Exchange Rate (Currency) Risk – the risk that investors in foreign investments may be subject to different exchange rates at the time they wish to convert investment proceeds back to their home currency. If exchange rate risk is high, even though substantial profits may have been made in the foreign markets, a less favorable exchange rate may reduce or eliminate these profits. Country (Political) Risk – the risk that a major change in the political or economic environment of a foreign country may devalue investments made in that country. This risk is usually restricted to emerging or developing countries that do not have stable economic or political environments. Market Risk – the risk that the price of a particular investment will change as a result of overall market conditions that are not specific to that particular company or investment. Interest Rate Risk – the risk that interest rate changes will affect the price of a particular investment. For example, when interest rates rise, the price of bonds generally fall. Global Risk – the risk that events in one part of the world can affect investments across the globe. 13  Item 9 - Disciplinary Information PSF/Galloway is required to disclose the facts of any legal or disciplinary events that are material to a client’s evaluation of its advisory business or the integrity of management. At this time, PSF/Galloway does not have any disciplinary information to report. 14  Item 10 - Other Financial Industry Activities and Affiliations PSF/Galloway’s management, Michael Galloway is also a Registered Representatives with a broker/dealer, Purshe Kaplan Sterling Investments (PKS). When placing securities transactions through PKS, they earn normal and customary commissions. Please refer to Item 5 - Fees and Compensation, Implementation of Recommendations Outside of PSF/Galloway Portfolios. PSF/Galloway’s management, Michael Galloway is also an officer of Public Safety Financial Insurance agency registered with the State of Arizona Department of Insurance, AZ license # 1800014987 (National Producer # 17917174). At this time, there are five PSF/Galloway IARs licensed insurance agents under Public Safety Financial Insurance agency. PSF/Galloway IARs may be licensed life insurance agents with various insurance companies and may sell insurance products to PSF/Galloway advisory clients. IARs as a licensed life agent, may be able to implement insurance recommendations for advisory clients. In this event, the IAR will receive customary commissions for insurance sales. Clients of PSF/Galloway are not obligated in any manner to use the insurance services provided by PSF/Galloway IARs. 15  Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics PSF/Galloway’s Code of Ethics (Code) establishes that no person employed by the Firm shall prefer their own interests to those of advisory clients and, among other things, prohibits the use of material non-public information. Further, the Code requires that certain associated persons submit annual securities holdings reports and quarterly securities transaction reports to the firm’s designated officer who is responsible for reviewing them for compliance with the Code. Additionally, the Firm’s Code also requires the pre-approval of any acquisition of securities in a limited offering or initial public offering. Clients and prospective clients may obtain a copy of the Firm’s Code upon request by contacting Michael Galloway, CCO, at the Firm’s principal office address. Participation or Interest in Client Transactions and Personal Trading On occasion, representatives of PSF/Galloway may buy or sell for their own accounts securities that they recommend to clients. As these situations may present a conflict of interest, the Firm’s Code sets forth standards of business conduct, including compliance with applicable state and federal securities laws that it requires of its associated persons. 16  Item 12 - Brokerage Practices Investments for Commission-based Recommendation of Purshe Kaplan Sterling Transactions Two of PSF/Galloway IARs are also registered representatives (RRs) of Purshe Kaplan Sterling Investments (PKS), these services effect less than 1% of PSF/Galloway clients. The RRs are required by PKS to place any commissionable transactions through PKS. Therefore, If commission clients want PSF/Galloway to implement the advice outside of the PSF/Galloway Portfolios, PKS will be recommended to the clients. As registered representatives of PKS, the IARs of PSF/Galloway will also receive sales commissions and other related compensation, such as 12B-1 service fees or trail fees, on any products purchased, including insurance policies. PKS has a wide range of approved securities products for which PKS performs due diligence prior to selection. PKS’s RRs are required to adhere to these products when implementing securities transactions through PKS. Commissions charged for these products may be higher or lower than commissions clients may be able to obtain if transactions were implemented through another broker/dealer. In addition, certain back-office, operational, technology and other administrative support that PKS provides PSF/Galloway’s IARs also benefit PSF/Galloway. Additionally, product sponsors such as variable and investment companies and limited partnerships which are recommended to clients may provide support to PSF/Galloway. Such support includes research, educational information, and monetary support for due diligence trips and client events. There are two additional PSF/Galloway associates that are registered with PSF/Galloway and are also registered with PKS in an administrative capacity only. recommendations; and if the client elects to follow any of NOTE: Purshe Kaplan Sterling Investments and Public Safety Financial/Galloway are not affiliated companies. The value of products, research and services given to PSF/Galloway is not a factor in determining the selection of broker/dealers or the reasonableness of their commissions. Clients should be aware that a conflict exists between the interests of PSF/Galloway and the interests of the clients; and the client is under no obligation to act upon the PSF/Galloway’s recommendations, the client is under no obligation to effect the transaction through PSF/Galloway or its associated persons in their individual capacities. Recommendation of Broker/Custodians for PSF/Galloway Portfolios For the majority of PSF/Galloway clients, a custodian has already been selected by their employer and that custodian must be used for self-directed brokerage services on deferred compensation accounts and defined contribution accounts. PSF/Galloway may act as an authorized agent for employer sponsored retirement plans utilizing Empower Brokerage for self- directed brokerage accounts. Empower Brokerage custodies with Pershing LLC. 17  For the clients that may select a custodian, PSF/Galloway participates in Charles Schwab’s (Schwab) institutional customer programs and requires clients who wish to use PSF/Galloway Portfolios to direct us to use Schwab. Because Michael Galloway is a RR with PKS, he (and, therefore, PSF/Galloway) is subject to certain PKS restrictions concerning his use of other custodians and broker-dealers. To fulfill certain FINRA requirements, PKS has established a list of custodian and brokerage firms which may be utilized for custody and trade execution in client accounts by its registered representatives who are also affiliated with an investment advisor. Schwab is on the list of broker-dealer/custodians that are acceptable to PKS. Clients should be aware of the following important facts regarding PSF/Galloway’s exclusive use of Schwab: • This limitation on the use of Broker/Custodians/custodian may affect PSF/Galloway’s ability to achieve most favorable execution of client transactions, and therefore may cost clients more money; and • Not all investment advisors require clients to use specified Brokers/Custodians. typically not available to Recommended Brokers/Custodians provide PSF/Galloway with access to its institutional trading the Recommended and custody services, which are Brokers/Custodians retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them for Schwab accounts, there is no charge so long as a total of at least $10 million of the advisor’s clients’ assets is maintained in accounts at Schwab and is not otherwise contingent upon PSF/Galloway committing to Schwab any specific amount of business (assets in custody or trading)]. Recommended Brokers/Custodians’ services include brokerage, custody, research and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. in For PSF/Galloway clients’ accounts maintained their custody, Recommended Brokers/Custodians generally do not charge separately for custody but are compensated by the account holder through commissions or other transaction-related fees for securities trades that are executed through the Recommended Brokers/Custodians or that settle into Recommended Broker/Custodians’ accounts. Recommended Brokers/Custodians may also receive SEC Rule 12-(b)-1 and/or other fees from mutual fund companies (Note: PSF/Galloway’s IARs do not receive 12b-1 or trail fees for PSF/Galloway RIA business,). including accounts not maintained at Recommended Brokers/Custodians also make available to PSF/Galloway other products and services that benefit PSF/Galloway but may not benefit its clients’ accounts. Some of these other products and services assist PSF/Galloway in managing and administering clients’ accounts. For example, these may 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 PSF/Galloway’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 the Recommended of PSF/Galloway accounts, Brokers/Custodians. 18  Schwab also makes available to PSF/Galloway other services intended to help PSF/Galloway 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. In addition, Schwab may make available, arrange and/or pay for these types of services rendered to PSF/Galloway by independent third parties. Schwab may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third party providing these services to PSF/Galloway. PSF/Galloway’s recommendation that clients maintain their assets in accounts at Schwab may be based in part on the benefit to PSF/Galloway 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 Schwab, which may create a potential conflict of interest. The benefits received from Schwab do not depend upon the amount of transactions directed to Schwab. As part of its fiduciary duties to clients, PSF/Galloway endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by PSF/Galloway or its related persons in and of itself creates a potential conflict of interest. Clients are advised there is an incentive for PSF/Galloway and its IARs to recommend a Broker/Custodian over another based on the products and services that will be received rather than the client’s best interest. 19  Item 13 - Review of Accounts PSF/Galloway Portfolios Reviews: The Public Safety Financial/Galloway Investment Oversight Committee (“IOC") and Pierre Brachet, Portfolio Manager of PSF/Galloway, regularly monitors the underlying securities within the portfolios which is reviewed at least annually. Clients are contacted at least annually and given the opportunity to meet either in person or by telephone at least annually with their PSF/Galloway representative to review their accounts. The client may request additional meetings at any time. Accounts are reviewed in the context of each client's stated investment objectives and guidelines. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic environment. Reports: Portfolio Management clients will receive statements at least quarterly and confirmations of transactions from their Broker/Custodian. PSF/Galloway provides an additional quarterly statement during the advisory relationship. Financial Planning Reviews: While reviews may occur at different stages depending on the nature and terms, typically no formal financial plan reviews are conducted, unless a client completes a comprehensive financial planning process in which a report will be provided to client. 20  Item 14 - Client Referrals and Other Compensation PSF/Galloway has an arrangement with Cambridge Investment Research Advisors, Inc. (CIRA) where certain investment advisor representatives (IARs) of Cambridge Investment Research Advisors, Inc. refer business to PSF/Galloway. CIRA is paid a percentage of the advisory fee by PSF/Galloway on the accounts the IARs refer to PSF/Galloway and service accounts on behalf of PSF/Galloway. PSF Galloway has an arrangement with CIRA where certain Investment advisor representatives (IARs) of CIRA that refer accounts to PSF/Galloway for management services. CIRA is paid a promoter fee for each referred account. The promoter fee is included in PSF/Galloway’s management services fee. PSF/Galloway has an arrangement with CUSO Financial Services, L.P. (CUSO) which includes PSF/Galloway as an approved RIA provider for certain Investment advisor representatives (IARs) of CUSO that refer accounts to PSF/Galloway for management services. CUSO is paid a promoter fee for each referred account. The promoter fee is included in PSF/Galloway’s management services fee. PSF/Galloway has an arrangement with promoters, Public Safety Representatives, that refer clients to the Firm for management services. The Public Safety Representative is paid a promoter fee for each referred account accordance with the promoter arrangement. The promoter fee is included in PSF/Galloway’s management services fee. The details of such payments are described to clients as required, and acknowledged and accepted by those clients, in a signed disclosure document. 21  Item 15 - Custody Except for the direct billing of account fees (as authorized by clients in writing), PSF/Galloway does not accept or maintain custody of client funds or securities. Client funds and securities are always held with a qualified custodian, such as Schwab, who will provide the client with an account statement at least each calendar quarter. The account statement shows the amount of PSF/Galloway’s management fees that are deducted from the client’s account during the period covered by the statement. Clients should review the account statements provided by their custodian carefully for accuracy. The SEC issued a no-action letter (“Letter”) with respect to the Rule 206(4)-2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguards in conjunction with the account custodian: • The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. • The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. • The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization and provides a transfer of funds notice to the client promptly after each transfer. • The client has the ability to terminate or change the instruction to the client’s qualified custodian. • The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. • The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. • The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. PSF/Galloway maintains records showing third party standing letter of instructions (SLOAs) are not a related party of PSF/Galloway or located at the same address as PSF/Galloway. 22  Item 16 - Investment Discretion PSF/Galloway manages client accounts on a discretionary basis in which the client grants PSF/Galloway authority in the Investment Advisory Agreement. PSF/Galloway takes discretion over the following activities: the securities to be purchased or sold, the amount of securities to be purchased or sold, and when transactions are made. 23  Item 17 - Voting Client Securities As a matter of firm policy and practice, PSF/Galloway does not have any authority to and does not vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. However, upon Client’s request, PSF/Galloway may provide advice to clients regarding the Client’s voting of proxies. 24  Item 18 - Financial Information PSF/Galloway does not require or solicit the prepayment of more than $1,200 in fees, six months or more in advance. In addition, PSF/Galloway does not have any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. 25