Gudorf Financial Group, LLC

Gudorf Financial Group, LLC Form ADV Part 2A – Disclosure Brochure Effective: May 29, 2026 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Gudorf Financial Group, LLC (“Gudorf Financial” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (937) 898-5430 or by email at admin@gudorffinancial.com. Gudorf Financial is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Gudorf Financial to assist you in determining whether to retain the Advisor. Additional information about Gudorf Financial and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 339836. Gudorf Financial Group, LLC 8145 North Main Street, Dayton, OH 45415 Phone: (937) 898-5430 https://gudorffinancial.com  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Gudorf Financial. For convenience, the Advisor has combined these documents into a single disclosure document. Gudorf Financial believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Gudorf Financial encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes There have been no material changes to this Disclosure Brochure since the initial amendment filing on December 18, 2025. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 339836. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (937) 898-5430 or by email at admin@gudorffinancial.com. Gudorf Financial Group, LLC 8145 North Main Street, Dayton, OH 45415 Phone: (937) 898-5430 https://gudorffinancial.com Page 2  Item 3 – Table of Contents Item 1 – Cover Page ............................................................................................................................................... 1 Item 2 – Material Changes ..................................................................................................................................... 2 Item 3 – Table of Contents ..................................................................................................................................... 3 Item 4 – Advisory Services .................................................................................................................................... 4 A. Firm Information .............................................................................................................................................................. 4 B. Advisory Services Offered ............................................................................................................................................... 4 C. Client Account Management ........................................................................................................................................... 6 D. Wrap Fee Programs ........................................................................................................................................................ 6 E. Assets Under Management ............................................................................................................................................. 6 Item 5 – Fees and Compensation ......................................................................................................................... 6 A. Fees for Advisory Services.............................................................................................................................................. 6 B. Fee Billing........................................................................................................................................................................ 7 C. Other Fees and Expenses .............................................................................................................................................. 7 D. Advance Payment of Fees and Termination ................................................................................................................... 7 E. Compensation for Sales of Securities ............................................................................................................................. 8 Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 8 Item 7 – Types of Clients ....................................................................................................................................... 8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 8 A. Methods of Analysis ........................................................................................................................................................ 8 B. Risk of Loss ..................................................................................................................................................................... 9 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 ............... 11 A. Code of Ethics ............................................................................................................................................................... 11 B. Personal Trading with Material Interest ......................................................................................................................... 11 C. Personal Trading in Same Securities as Clients ........................................................................................................... 11 D. Personal Trading at Same Time as Client .................................................................................................................... 11 Item 12 – Brokerage Practices ............................................................................................................................ 11 A. Recommendation of Custodian[s] ................................................................................................................................. 11 B. Aggregating and Allocating Trades ............................................................................................................................... 12 Item 13 – Review of Accounts ............................................................................................................................. 12 A. Frequency of Reviews ................................................................................................................................................... 12 B. Causes for Reviews ...................................................................................................................................................... 12 C. Review Reports ............................................................................................................................................................. 13 Item 14 – Client Referrals and Other Compensation ........................................................................................ 13 A. Compensation Received by Gudorf Financial ............................................................................................................... 13 B. Compensation for Client Referrals ................................................................................................................................ 13 Item 15 – Custody ................................................................................................................................................. 14 Item 16 – Investment Discretion ......................................................................................................................... 14 Item 17 – Voting Client Securities ....................................................................................................................... 14 Item 18 – Financial Information ........................................................................................................................... 14 Form ADV Part 2B – Brochure Supplements ..................................................................................................... 15 Privacy Policy ....................................................................................................................................................... 22 Gudorf Financial Group, LLC 8145 North Main Street, Dayton, OH 45415 Phone: (937) 898-5430 https://gudorffinancial.com Page 3  Item 4 – Advisory Services A. Firm Information Gudorf Financial Group, LLC (“Gudorf Financial” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission. The Advisor is organized as a Limited Liability Company (LLC) under the laws of the State of Ohio. Gudorf Financial was founded in January 2021 and is owned and operated by Daniel M. Gudorf (Founder, Chief Exeuctive Officer, and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Gudorf Financial. B. Advisory Services Offered Gudorf Financial offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, and retirement plans (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Gudorf Financial's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services Gudorf Financial provides customized wealth management services for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management services and a broad range of comprehensive financial planning. Investment Management Services – The Advisor provides discretionary investment management services. Gudorf Financial works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Gudorf Financial will then construct an investment portfolio primarily consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds, and/or other types of investments, as appropriate to meet the needs of the Client. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Gudorf Financial’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Gudorf Financial will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Gudorf Financial evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Gudorf Financial may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Gudorf Financial may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Gudorf Financial may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Gudorf Financial accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Gudorf Financial Group, LLC 8145 North Main Street, Dayton, OH 45415 Phone: (937) 898-5430 https://gudorffinancial.com Page 4  Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Financial Planning Services – The Advisor provides a variety of financial planning and consulting services to Clients as part of its wealth management services. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, tax planning, retirement planning, personal savings, education savings, insurance needs and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Gudorf Financial may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Retirement Plan Advisory Services The Advisor provides 3(21) or 3(38) retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: Investment Policy Statement (“IPS”) Design and Monitoring • Vendor Analysis • Plan Participant Enrollment and Education Tracking • • Ongoing Investment Recommendation and Assistance • Performance Reports • ERISA 404(c) Assistance • Benchmarking Services These services are provided by the Advisor serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of the Advisor’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Gudorf Financial Group, LLC 8145 North Main Street, Dayton, OH 45415 Phone: (937) 898-5430 https://gudorffinancial.com Page 5  C. Client Account Management Prior to engaging Gudorf Financial to provide investment advisory services, each Client is required to enter into a written agreement with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – Gudorf Financial, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – Gudorf Financial will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. • Portfolio Construction – Gudorf Financial will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Gudorf Financial will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Gudorf Financial does not manage or place Client assets into a wrap fee program. E. Assets Under Management As of May 18, 2026, Gudorf Financial manages $121,130,421 in Client assets, $120,919,653 of which are managed on a discretionary basis and $210,768 of which are managed on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written agreement with the Advisor. A. Fees for Advisory Services Wealth Management Services Wealth management fees are paid in arrears of each month, pursuant to the terms of the wealth management agreement. Wealth management fees are based on the market value of assets under management at the end of the month. Wealth management fees are based on the following linear, tiered schedule: Assets Under Management ($) Up to $500,000 $500,001 to $1,000,000 $1,000,001 to $3,000,000 $3,000,001 to $5,000,000 Over $5,000,000 Annual Rate (%) 1.50% 1.35% 1.00% 0.75% Negotiable The wealth management fee in the first month of service is prorated from the inception date of the account[s] to the end of the first month. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Gudorf Financial will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Gudorf Financial Group, LLC 8145 North Main Street, Dayton, OH 45415 Phone: (937) 898-5430 https://gudorffinancial.com Page 6  Retirement Plan Advisory Services Retirement plan advisory fees are charged an annual asset-based fee of up to 1.50%. Fees may be billed monthly or quarterly (“Billing Period”) in advance or arrears pursuant to the terms of the retirement plan advisory agreement. Retirement plan fees are based on the market value of assets under management at the end of the Billing Period. Fees may be negotiable depending on the size and complexity of the Plan but shall not exceed the fee range stated above. B. Fee Billing Wealth Management Services Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the respective month end date. The amount due is calculated by applying the monthly rate (annual rate divided by 12) to the total assets under management with Gudorf Financial at the end of each month. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the wealth management fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting wealth management fees to be deducted by Gudorf Financial to be paid directly from their account[s] held by the Custodian as part of the wealth management agreement and separate account forms provided by the Custodian. Retirement Plan Advisory Services Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Gudorf Financial, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The fees charged by Gudorf Financial are separate and distinct from these custody and execution fees. In addition, all fees paid to Gudorf Financial for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Gudorf Financial, but would not receive the services provided by Gudorf Financial which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Gudorf Financial to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Wealth Management Services Gudorf Financial may be compensated for its wealth management services at the end of the month after services are rendered. Either party may terminate the wealth management agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the wealth management agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. The Client’s wealth management agreement with the Advisor is non-transferable without the Client’s prior consent. Gudorf Financial Group, LLC 8145 North Main Street, Dayton, OH 45415 Phone: (937) 898-5430 https://gudorffinancial.com Page 7  Retirement Plan Advisory Services The Advisor may be compensated for its services at the beginning of the Billing Period before services are rendered pursuant to the terms of the retirement plan advisory agreement. Either party may request to terminate a retirement plan advisory agreement, at any time, by providing advance written notice to the other party. The Client shall be responsible for fees up to and including the effective date of termination. If the fees are billed in advance, the Advisor will refund any unearned, prepaid retirement plan advisory fees from the effective date of termination to the end of the Billing Period. The Client’s retirement plan advisory agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities Gudorf Financial does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Wealth Counselors, LLC Certain Advisory Persons are licensed as independent insurance professionals through Wealth Counselors, LLC (“Wealth Counselors”), an affiliated entity under common control and ownership as Gudorf Financial. As an independent insurance professional, an Advisory Person may earn commission-based compensation for selling insurance products, including insurance products offered to Clients. Insurance commissions earned by the Advisory Person are separate and in addition to investment advisory fees. This practice presents a conflict of interest as an Advisory Person who is also an insurance professional will have an incentive to recommend insurance products to the Client for the purpose of generating commissions rather than solely based on the Client’s needs. Clients are under no obligation, contractual or otherwise, to purchase insurance products through Wealth Counselors or any Advisory Person affiliated with the Advisor. Please see Item 10 below. Item 6 – Performance-Based Fees and Side-By-Side Management Gudorf Financial does not charge performance-based fees for its investment advisory services. The fees charged by Gudorf Financial are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Gudorf Financial does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Gudorf Financial offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, and retirement plans. Gudorf Financial generally requires a minimum relationship size of $750,000 to effectively implement its investment process. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Gudorf Financial employs Modern Portfolio Theory in developing investment strategies for its Clients. Research and analysis from Gudorf Financial are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Modern Portfolio Theory (“MPT”) is a Nobel Prize-winning approach that is utilized as a formal process for investment selection. By comparing historical return, historical volatility, and historical correlation, MPT finds the most efficient portfolio for a given level of risk. The sensitive process of gathering suitable inputs and constructing constraints to create marketable portfolios requires the infusion of opinion, experience, and importantly, a deep understanding of financial theory and markets. An inherent risk in applying MPT is the understanding that the historical characteristics of an investment or index do not necessarily indicate future outcomes. The Advisor employs various measures to Gudorf Financial Group, LLC 8145 North Main Street, Dayton, OH 45415 Phone: (937) 898-5430 https://gudorffinancial.com Page 8  mitigate this risk, including, but not limited to: continuously challenging all assumptions, applying practical constraints to the portfolio models, and considering alternative courses of history. As noted above, Gudorf Financial generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Gudorf Financial will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Gudorf Financial may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Gudorf Financial will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment strategies: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating Gudorf Financial Group, LLC 8145 North Main Street, Dayton, OH 45415 Phone: (937) 898-5430 https://gudorffinancial.com Page 9  which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Stocks Risks Stocks provide investors with an opportunity for capital appreciation and growth. The stocks of smaller companies tend to have the greatest potential for growth, but also the highest levels of risk or volatility. Larger company stocks have more moderate potential for both return and risk. Stocks have a variety of risks, including specific risk which is related to individual company developments, industry/sector risk, which is a function of broader economic factors affecting a company’s business, and market/systematic risk, which affects all stocks in a market and is the result of general investor sentiment and growth of the broader economy. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving Gudorf Financial or its owner. Gudorf Financial values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 339836. Item 10 – Other Financial Industry Activities and Affiliations Gudorf Tax Group, LLC The Advisor will recommend that Clients utilize the services of Gudorf Tax Group, LLC (“Gudorf Tax”), a tax and accounting entity. Gudorf Tax offers tax and accounting services which are separate and distinct from the investment advisory services offered by Gudorf Financial. Clients who engage Gudorf Financial may receive reduced or waived fees for services to be provided by Gudorf Tax. This affiliation presents a conflict of interest as the Advisor is incentivized to recommend that Clients engage Gudorf Tax for tax and accounting services, rather than solely based on the Client’s needs. Clients are under no obligation, contractually or otherwise, to utilize the services of Gudorf Tax. Gudorf Law Group, LLC The Advisor is affiliated through common control with Gudorf Law Group, LLC (“Gudorf Law”), a law firm providing legal and trustee services. Gudorf Law offers legal and trustee services which are separate and distinct from the investment advisory services offered by Gudorf Financial. Clients who engage Gudorf Financial may receive reduced or waived fees for services to be provided by Gudorf Law. This affiliation presents a conflict of interest as management persons of the Advisor have a financial incentive to recommend that Clients engage Gudorf Law for legal and trustee services, rather than solely based on the Client’s needs. Clients are under no obligation, contractually or otherwise, to utilize the services of Gudorf Law. Wealth Counselors, LLC As noted in Item 5, Wealth Counselors is affiliated and under common control as Gudorf Financial. Certain Advisory Persons are also licensed as insurance professionals with Wealth Counselors. Implementations of insurance recommendations are separate and apart from one’s role with the Advisor. As an insurance professional, the Advisory Person will receive customary commissions and other related revenues from insurance products sold to Clients. Commissions generated by insurance sales do not offset investment advisory fees. This presents a conflict of interest Gudorf Financial Group, LLC 8145 North Main Street, Dayton, OH 45415 Phone: (937) 898-5430 https://gudorffinancial.com Page 10  in recommending insurance products to Clients. Clients are under no obligation to implement any recommendations made by the Advisor or Advisory Persons. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Gudorf Financial has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Gudorf Financial (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Gudorf Financial and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Gudorf Financial’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (937) 898- 5430 or via email at admin@gudorffinancial.com. B. Personal Trading with Material Interest Gudorf Financial allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Gudorf Financial does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Gudorf Financial does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Gudorf Financial allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Gudorf Financial requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While Gudorf Financial allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will Gudorf Financial, or any Supervised Person of Gudorf Financial, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Gudorf Financial does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Gudorf Financial to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, Gudorf Financial does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where Gudorf Financial does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by Gudorf Financial. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not Gudorf Financial Group, LLC 8145 North Main Street, Dayton, OH 45415 Phone: (937) 898-5430 https://gudorffinancial.com Page 11  engaged. Gudorf Financial may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. The Advisor will generally recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified custodian”. The Advisor maintains an institutional relationship with Schwab, whereby the Advisor receives economic benefits. Please see Item 14 – Client Referrals and Other Compensation below. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Gudorf Financial does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals - Gudorf Financial does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Gudorf Financial will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Gudorf Financial will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Gudorf Financial will execute its transactions through the Custodian as authorized by the Client. Gudorf Financial may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Daniel M. Gudorf, Chief Compliance Officer of Gudorf Financial. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Gudorf Financial if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. Gudorf Financial Group, LLC 8145 North Main Street, Dayton, OH 45415 Phone: (937) 898-5430 https://gudorffinancial.com Page 12  C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Gudorf Financial Gudorf Financial is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product. Gudorf Financial does not receive commissions or other compensation from product sponsors, broker-dealers or any un-related third party. Gudorf Financial may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Gudorf Financial may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform The Advisor has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like the Advisor. As a registered investment advisor participating on the Schwab Advisor Services platform, the Advisor receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a conflict of interest since these benefits can influence the Advisor's recommendation of Schwab over a custodian that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services to the Advisor that may not benefit the Client, including: educational conferences and events, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest. The Advisor believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. B. Compensation for Client Referrals The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Gudorf Financial Group, LLC 8145 North Main Street, Dayton, OH 45415 Phone: (937) 898-5430 https://gudorffinancial.com Page 13  Item 15 – Custody Gudorf Financial does not accept or maintain custody of any Client accounts, except for the authorized deduction of the Advisor’s fees. All Clients must place their assets with a “qualified custodian”. Clients are required to engage the Custodian to retain their funds and securities and direct Gudorf Financial to utilize that Custodian for the Client’s security transactions. Clients should review statements provided by the Custodian and compare to any reports provided by Gudorf Financial to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions. Item 16 – Investment Discretion Gudorf Financial generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Gudorf Financial. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by Gudorf Financial will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities Gudorf Financial does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither Gudorf Financial, nor its management, have any adverse financial situations that would reasonably impair the ability of Gudorf Financial to meet all obligations to its Clients. Neither Gudorf Financial, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Gudorf Financial is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Gudorf Financial Group, LLC 8145 North Main Street, Dayton, OH 45415 Phone: (937) 898-5430 https://gudorffinancial.com Page 14  Form ADV Part 2B – Brochure Supplement for Daniel M. Gudorf Founder, Chief Executive Officer, and Chief Compliance Officer Effective: May 29, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Daniel M. Gudorf (CRD# 6011685) in addition to the information contained in the Gudorf Financial Group, LLC (“Gudorf Financial” or the “Advisor”, CRD# (339836) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Gudorf Financial Disclosure Brochure or this Brochure Supplement, please contact us at (937) 898-5430 or by email at admin@gudorffinancial.com. Additional information about Mr. Gudorf is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 6011685. Gudorf Financial Group, LLC 8145 North Main Street, Dayton, OH 45415 Phone: (937) 898-5430 https://gudorffinancial.com Page 15  Item 2 – Educational Background and Business Experience Daniel M. Gudorf, born in 1987, is dedicated to advising Clients of Gudorf Financial as its Founder, Chief Executive Officer, and Chief Compliance Officer. Mr. Gudorf earned his Bachelor of Science in Economics from Miami University of Ohio in 2012. Additional information regarding Mr. Gudorf’s employment history is included below. Employment History: 02/2026 to Present 07/2012 to Present 06/2011 to Present 01/2018 to 02/2026 Founder, Chief Executive Officer, and Chief Compliance Officer, Gudorf Financial Group, LLC Chief Strategy Officer, Gudorf Law Group, LLC Licensed Insurance Agent, Wealth Counselors, LLC Investment Advisor Representative, Cambridge Investment Research Advisors, Inc. Investment Advisor Representative, CSSC Investment Advisory Services, Inc. 04/2012 to 06/2018 Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Gudorf. Mr. Gudorf has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Gudorf. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Gudorf. However, we do encourage you to independently view the background of Mr. Gudorf on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 6011685. Item 4 – Other Business Activities Gudorf Law Group, LLC Mr. Gudorf is also the Chief Strategy Officer for Gudorf Law, an affiliated entity under common control with the Advisor. Gudorf Law offers legal and trustee services which are separate and distinct from the investment advisory services offered by Gudorf Financial. In this capacity, Mr. Gudorf oversees the financial statements, and assists with strategy and marketing efforts for Gudorf Law. This affiliation presents a conflict of interest as Mr. Gudorf has a financial incentive to recommend that Clients engage Gudorf Law for legal and trustee services, rather than solely based on the Client’s needs. Clients are under no obligation, contractually or otherwise, to utilize the services of Gudorf Law. Mr. Gudorf spends approximately 10% of his time per month in this capacity. Wealth Counselors, LLC Mr. Gudorf is also a licensed insurance professional with Wealth Counselors, LLC (“Wealth Counselors”), an affiliated entity under common ownership and control as the Advisor. Implementations of insurance recommendations are separate and apart from Mr. Gudorf’s role with Gudorf Financial. As an insurance professional, Mr. Gudorf will receive customary commissions and other related revenues from insurance products sold to Clients. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending insurance products through Wealth Counselors. Clients are under no obligation to implement any recommendations made by Mr. Gudorf or the Advisor. Mr. Gudorf spends less than 5% of his time per month in this capacity. Meraki Development, LLC Mr. Gudorf is also the Owner of Meraki Development, LLC, a real estate development company. In this capacity, Mr. Gudorf manages and approves new real estate projects and developments of properties. Mr. Gudorf spends less than 5% of his time per month in this capacity. Gudorf Financial Group, LLC 8145 North Main Street, Dayton, OH 45415 Phone: (937) 898-5430 https://gudorffinancial.com Page 16  Redhawk Capital Management, LLC Mr. Gudorf is also the Owner of Redhawk Capital Management, LLC. In this capacity, Mr. Gudorf oversees the purchase and rehabilitation of properties for the purpose of resale. Mr. Gudorf spends less than 5% of his time per month in this capacity. Redhawk Property Management, LLC Mr. Gudorf is also the Owner and Chief Executive Officer of Redhawk Property Management, LLC, (“Redhawk property”) a property management firm. In this capacity, Mr. Gudorf oversees the collection of payments related to the management of properties owned by Redhawk Property. Mr. Gudorf spends less than 5% of his time per month in this capacity. Item 5 – Additional Compensation Mr. Gudorf has additional business activities where compensation is received that are detailed in Item 4 above. Item 6 – Supervision Mr. Gudorf serves as the Founder, Chief Executive Officer, and Chief Compliance Officer of Gudorf Financial. Mr. Gudorf can be reached at (937) 898-5430. Gudorf Financial has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Gudorf Financial. Further, Gudorf Financial is subject to regulatory oversight by various agencies. These agencies require registration by Gudorf Financial and its Supervised Persons. As a registered entity, Gudorf Financial is subject to examinations by regulators, which may be announced or unannounced. Gudorf Financial is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Gudorf Financial Group, LLC 8145 North Main Street, Dayton, OH 45415 Phone: (937) 898-5430 https://gudorffinancial.com Page 17  Form ADV Part 2B – Brochure Supplement for Allison M. Szkody, CFP® Financial Planner Effective: May 29, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Allison M. Szkody, CFP® (CRD# 7326281) in addition to the information contained in the Gudorf Financial Group, LLC (“Gudorf Financial” or the “Advisor”, CRD# 339836) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Gudorf Financial Disclosure Brochure or this Brochure Supplement, please contact us at (937) 898-5430 or by email at admin@gudorffinancial.com. Additional information about Mrs. Szkody is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 7326281. Gudorf Financial Group, LLC 8145 North Main Street, Dayton, OH 45415 Phone: (937) 898-5430 https://gudorffinancial.com Page 18  Item 2 – Educational Background and Business Experience Allison M. Szkody, CFP®, born in 1986, is dedicated to advising Clients of Gudorf Financial as a Financial Planner. Mrs. Szkody earned her Bachelor’s Degree in Accounting and Finance from Wright State University in 2009. Additional information regarding Mrs. Szkody’s employment history is included below. Employment History: 02/2026 to Present 01/2021 to 02/2026 Financial Planner, Gudorf Financial Group, LLC Investment Advisor Representative, Cambridge Investment Research Advisors, Inc. Associate Portfolio Manager, Fifth Third Bank 06/2014 to 12/2020 CERTIFIED FINANCIAL PLANNER® Professional I am certified for financial planning services in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER® professional or a CFP® professional, and I may use these and the other certification marks (the “CFP Board Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning, Inc. has licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state law or regulation requires financial planners to hold the CFP® certification. You may find more information about the CFP® certification at www.cfp.net. CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics. To become a CFP® professional, an individual must fulfill the following requirements: ● Education – Earn a bachelor’s degree or higher from an accredited college or university and complete CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The coursework covers the financial planning subject areas CFP Board has determined are necessary for the competent and professional delivery of financial planning services, as well as a comprehensive financial plan development capstone course. A candidate may satisfy some of the coursework requirement through other qualifying credentials. CFP Board implemented the bachelor’s degree or higher requirement in 2007 and the financial planning development capstone course requirement in March 2012. Therefore, a CFP® professional who first became certified before those dates may not have earned a bachelor’s or higher degree or completed a financial planning development capstone course. ● Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the context of real-life financial planning situations. ● Experience – Complete 6,000 hours of professional experience related to the personal financial planning process, or 4,000 hours of apprenticeship experience that meets additional requirements. ● Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements to remain certified and maintain the right to continue to use the CFP Board Certification Marks: ● Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the client, at all times when providing financial advice and financial planning. CFP Board may sanction a CFP® professional who does not abide by this commitment, but CFP Board does not guarantee a CFP® professional's services. A client who seeks a similar commitment should obtain a written engagement that includes a fiduciary obligation to the client. Gudorf Financial Group, LLC 8145 North Main Street, Dayton, OH 45415 Phone: (937) 898-5430 https://gudorffinancial.com Page 19  ● Continuing Education – Complete 30 hours of continuing education every two years to maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with developments in financial planning. Two of the hours must address the Code and Standards. Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mrs. Szkody. Mrs. Szkody has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mrs. Szkody. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mrs. Szkody. However, we do encourage you to independently view the background of Mrs. Szkody on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 7326281. Item 4 – Other Business Activities Gudorf Law Group, LLC Mrs. Szkody is also a Consultant for Gudorf Law, an affiliated entity under common control with the Advisor. Gudorf Law offers legal and trustee services which are separate and distinct from the investment advisory services offered by Gudorf Financial. In this capacity, Mrs. Szkody assists with general questions concerning clients of Gudorf Law’s financial matters. This affiliation presents a conflict of interest as Mrs. Szkody has a financial incentive to recommend that Clients engage Gudorf Law for legal and trustee services, rather than solely based on the Client’s needs. Clients are under no obligation, contractually or otherwise, to utilize the services of Gudorf Law. Mrs. Szkody spends less than 5% of her time per month in this capacity. Wealth Counselors, LLC Mrs. Szkody is also a licensed insurance professional with Wealth Counselors, LLC (“Wealth Counselors”), an affiliated entity under common ownership and control as the Advisor. Implementations of insurance recommendations are separate and apart from Mrs. Szkody’s role with Gudorf Financial. As an insurance professional, Mrs. Szkody will receive customary commissions and other related revenues from insurance products sold to Clients. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending insurance products through Wealth Counselors. Clients are under no obligation to implement any recommendations made by Mrs. Szkody or the Advisor. Mrs. Szkody spends less than 5% of her time per month in this capacity. Item 5 – Additional Compensation Mrs. Szkody has additional business activities where compensation is received that are detailed in Item 4 above. Item 6 – Supervision Mrs. Szkody serves as a Financial Planner of Gudorf Financial and is supervised by Daniel Gudorf, the Chief Compliance Officer. Mr. Gudorf can be reached at (937) 898-5430. Gudorf Financial has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Gudorf Financial. Further, Gudorf Financial is subject to regulatory oversight by various agencies. These agencies require registration by Gudorf Financial and its Supervised Persons. As a registered entity, Gudorf Financial is subject to examinations by regulators, which may be announced Gudorf Financial Group, LLC 8145 North Main Street, Dayton, OH 45415 Phone: (937) 898-5430 https://gudorffinancial.com Page 20  or unannounced. Gudorf Financial is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Gudorf Financial Group, LLC 8145 North Main Street, Dayton, OH 45415 Phone: (937) 898-5430 https://gudorffinancial.com Page 21  Privacy Policy Effective: May 29, 2026 Our Commitment to You Gudorf Financial Group, LLC (“Gudorf Financial” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Gudorf Financial (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Gudorf Financial does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Gudorf Financial Group, LLC 8145 North Main Street, Dayton, OH 45415 Phone: (937) 898-5430 https://gudorffinancial.com Page 22  How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No to: processing No Not Shared Yes Yes Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. Marketing Purposes Gudorf Financial does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Gudorf Financial or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. No Not Shared Information About Former Clients Gudorf Financial does not disclose and does not intend to disclose, non- public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (937) 898-5430 or via email at admin@gudorffinancial.com. Gudorf Financial Group, LLC 8145 North Main Street, Dayton, OH 45415 Phone: (937) 898-5430 https://gudorffinancial.com Page 23