GW FINANCIAL

Item 1 Cover Page GW Financial, Inc. Mailing Address: 18124 Wedge Parkway #453 Reno, NV 89511 Phone: 714-850-0534 Main Office Location: 5470 Kietzke Lane, Suite 300 Reno, NV 89511 Phone: 714-850-0534 www.planretire.com www.planhighereducation.com Firm Brochure (Part 2A of Form ADV) March 31, 2026 This brochure provides information about the qualifications and business practices of GW Financial, Inc. If you have any questions about the contents of this brochure, please contact us at 714-850-0534. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about GW Financial, Inc. is available on the SEC's website at www.adviserinfo.sec.gov. The firm's CRD# is 110478. GW Financial, Inc. is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training.  Item 2 Summary of Material Changes Material Changes since the Last Annual Updating Amendment Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since the filing of our last annual updating amendment, dated February 7, 2023, we do not have any material changes to report. 1  Item 3 Table of Contents Item 1 Cover Page Item 2 Summary of Material Changes Item 3 Table of Contents Item 4 Advisory Business Item 5 Fees and Compensation Item 6 Performance-Based Fees and Side-By-Side Management Item 7 Types of Clients Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Item 9 Disciplinary Information Item 10 Other Financial Industry Activities and Affiliations Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 12 Brokerage Practices Item 13 Review of Accounts Item 14 Client Referrals and Other Compensation Item 15 Custody Item 16 Investment Discretion Item 17 Voting Client Securities Item 18 Financial Information 0 1 2 3 6 9 9 9 10 11 11 11 12 13 13 13 14 14 2  Item 4 Advisory Business Firm Description and Overview GW Financial, Inc. ("GWF") was founded in 1981 by Glenn D. Woody. In June 2014, Julie Anderson Bray and Scott K. Anderson, Jr. purchased GWF from Mr. Woody. Ms. Bray is now the President of GW Financial, Inc.. GWF is organized as a corporation under the laws of the State of Nevada. GWF offers personalized confidential financial planning, tax strategy and investment management services to individuals, pension and profit sharing plans, trusts, estates, charitable and fraternal organizations and small businesses. The investment strategies used to implement any investment advice given to clients include long term purchases, securities held at least a year, and short term purchases, securities sold within a year. GWF does not act as a custodian of client assets. The client always maintains asset control. GWF places trades for clients under a limited power of attorney. Assets are invested in no-load mutual funds or exchange-traded funds, through the discount brokerage firm, Charles Schwab and Co. Inc. ("Schwab"). Fund companies charge each fund shareholder an investment management fee that is disclosed in the fund prospectus. Schwab charges a transaction fee to buy and sell some of these securities. This transaction fee is paid by the client. GWF additionally furnishes advice to clients on matters not involving securities. Advice is provided through consultation with the client and may include: determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning. As of December 31, 2025, GWF managed approximately $133,836,602 in assets (approximately $117,425,653 discretionary and $16,410,949 non-discretionary). Portfolios that are actively managed by GWF are done so on a discretionary basis. Types of Advisory Services GWF provides comprehensive advisory services, including personalized financial planning, tax planning, and investment management. Clients who have engaged GWF for financial planning and maintain an investment management relationship may access ongoing services such as modular planning updates, tax-related inquiries, and consultation on assets not managed by GWF as part of their investment management fee. GWF is a strictly fee-only firm, offering financial planning, tax strategies, and investment management services. GWF does not prepare income tax, gift tax, or estate tax returns, nor does it draft legal documents such as wills or trusts. GWF does not sell annuities, insurance, limited partnerships, or other commissioned products. It is not affiliated with any entities that sell financial products or securities, and it does not accept commissions, finder’s fees, or other forms of compensation from third parties. GWF is not registered as a securities broker-dealer, futures commission merchant, commodity pool operator, or commodity trading advisor. It does not have any material advisory arrangements with other investment advisors. Additionally, GWF does not manage accounts within a wrap or bundled fee program. Initial public offerings (IPOs) are not available through GWF. 3  Distinct Advisory Services Wealth Management Services Wealth Management combines Personal Financial Planning and Investment Management into a comprehensive, ongoing advisory service. GWF helps clients establish a net worth statement, analyze cash flow, and set up and integrate accounts into financial planning software. Clients receive tailored investment and financial planning strategies along with ongoing guidance. Wealth Management services are available at two levels: Wealth Management Silver (WM-Silver), designed for clients with less than $2 million in assets under management, providing full financial planning and investment management services without a minimum investment, and Wealth Management Advanced (WM-Advanced), which includes enhanced services for clients requiring more complex planning. Personalized Financial Planning GWF provides comprehensive financial planning services tailored to each client's unique situation. This process involves gathering detailed financial information, including net worth, income, expenses, taxes, investments, retirement plans, life insurance, health and medical insurance, business arrangements, and divorce agreements. Based on this information and the client's financial goals, GWF develops a personalized financial plan with specific recommendations across all applicable areas. Investment Management Services GWF offers active portfolio management and monitoring services separate from financial planning. Investment management services focus on structuring portfolios to align with client risk tolerance and investment objectives while ensuring broad diversification across multiple asset classes using exchange-traded funds (ETFs) and mutual funds. All mutual fund selections are commission-free, and GWF does not receive compensation from any investment providers. Each portfolio is individually managed, considering asset allocation, risk management, and long-term investment goals. In addition to GWF’s advisory fee, clients will pay a proportional share of internal fund expenses. Financial Consulting Services GWF occasionally offers standalone financial consulting services for clients seeking guidance on specific financial issues. These 90-minute sessions focus on analyzing a client’s current financial situation, goals, and objectives. Topics covered may include retirement planning, estate planning, education funding strategies, personal tax planning, real estate analysis, mortgage and debt strategies, and insurance analysis. Financial consultations provide general recommendations but do not include investment advice. Implementation of recommendations is at the client’s discretion. These consultations are typically verbal, without a formal written summary, and rely on the documents and information provided at the time of the meeting. Selection of Other Advisers We may recommend that you use the services of a third party money manager ("TPMM") to manage all, or a portion of, your investment portfolio. After gathering information about your financial situation and objectives, we may recommend that you engage in a specific TPMM or investment program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the TPMM's performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will monitor the TPMM(s)' performance to ensure its management and investment style remains aligned with your investment goals and objectives. 4  The TPMM(s) will actively manage your portfolio and will assume discretionary investment authority over your account. We will assume discretionary authority to hire and fire TPMM(s) and/or reallocate your assets to other TPMM(s) where we deem such action appropriate. Retirement Rollovers-No Obligation/Conflict of Interest Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. A client leaving an employer typically has four options (and may engage in a combination of these options): 1) leave the money in his former employer's plan, if permitted, 2) roll over the assets to his/her new employer's plan, if one is available and rollovers are permitted, 3) rollover to an Individual Retirement Account (IRA), or 4) cash out the account value (which could, depending upon the client's age, result in adverse tax consequences). GWF may recommend an investor roll over plan assets to an IRA managed by GWF. As a result, GWF may earn an asset-based fee; however, a recommendation that a client or prospective client leave their plan assets with their old employer will result in no compensation. GWF has an economic incentive to encourage an investor to roll plan assets into an IRA that GWF will manage. There are various factors that GWF may consider before recommending a rollover, including but not limited to: i) the investment options available in the plan versus the investment options available in an IRA, ii) fees and expenses in the plan versus the fees and expenses in an IRA, iii) the services and responsiveness of the plan's investment professionals versus those of GWF, iv) required minimum distributions and age considerations, and vi) employer stock tax consequences, if any. No client is under any obligation to roll over plan assets to an IRA managed by GWF. Imposed Restrictions GWF manages client investment accounts on an individual basis based on each client's individual circumstances and financial situation. Investment decisions for clients are made based on information the client supplies about their financial situation, goals, and risk tolerance. GWF recommendations may be limited if the client does not provide them with accurate and complete information. It is the client's responsibility to keep GWF informed of any changes to their investment objectives or restrictions. Clients may also request other restrictions on the account, such as when a client needs to keep a minimum level of cash in the account or does not want GWF to buy or sell certain specific securities or security types in the account. GWF reserves the right to not accept and/or to terminate management of a client's account if we feel that the client-imposed restrictions would limit or prevent us from meeting or maintaining the client's investment strategy. Termination of Agreement A client may terminate any of the aforementioned agreements at any time by notifying GWF In writing and paying the fee for the time spent on the engagement prior to notification of termination. GWF may terminate any of the aforementioned agreements at any time by notifying the client in writing. 5  Item 5 Fees and Compensation Overview GWF bases its fees on a percentage of assets under management (AUM) or fixed fees for advisory and consulting services. Fees are determined based on the complexity of the client’s financial situation and the scope of services provided. GWF does not aim to offer the lowest-cost financial advice but instead focuses on providing high-value, fee-only financial planning and investment management. Clients may find similar services at a lower cost from other firms or institutions. GWF encourages the use of discount brokers and no-load funds but does not determine the lowest- cost provider for transactions. Currently, GWF uses Charles Schwab & Co., Inc. as its preferred custodian and does not accept commissions, kickbacks, rebates, soft-dollar reimbursements, or any third-party compensation. All services are provided on a transparent, fee-only basis, with clients paying GWF directly. The initial consultation is offered free of charge and serves as an exploratory session to determine whether financial planning or investment management services would be beneficial to the client. Fee Schedules Wealth Management (WM) GWF offers Wealth Management Silver (WM-Silver) and Wealth Management Advanced (WM-Advanced) as comprehensive advisory services that include both financial planning and investment management. All new clients must engage under one of these service levels. For WM-Silver, clients with less than $2 million in assets under management (AUM) receive ongoing financial planning and investment management without a minimum investment requirement. For WM-Advanced, clients with more complex needs receive enhanced planning services, including multi- generational wealth transfer, philanthropic strategies, and estate coordination. Clients in both service tiers receive quarterly financial planning meetings, personalized financial plan updates, investment management, tax planning, Required Minimum Distribution (RMD) strategies, beneficiary reviews, and coordination with estate attorneys and tax professionals as needed. All new clients fall under either WM-Silver or WM-Advanced. Investment Management (IM) – Closed to New Clients Investment Management as a standalone service is only available to existing clients who have been with the firm prior to 2020. New clients must engage in Wealth Management services. Standalone IM clients who wish to receive ongoing financial planning services must transition to WM-Silver or WM- Advanced. All clients, fees follow a tiered structure: Assets Under Management (AUM) Annual Fee First $2,000,000 Next $2,000,000 Next $2,000,000 Next $4,000,000 Above $10,000,000 1.00% 0.80% 0.40% 0.20% Negotiated 6  Financial Consulting Services For clients seeking financial guidance on specific topics without an ongoing advisory relationship, GWF offers standalone financial consulting sessions. Flat Fee: $500 per session Session Duration: 90 minutes These consultations provide recommendations on retirement planning, estate planning, tax strategies, real estate, mortgages, debt, and insurance but do not include investment advice. Sessions are verbal and do not include a formal written summary. Consulting is based solely on the documents and information provided at the time of the meeting. Additional Considerations GWF, at its sole discretion, may waive minimum fees or adjust investment advisory fees for certain legacy clients. Clients who engage GWF for multiple services may see their total fees adjusted accordingly. All fees are agreed upon before engagement and are exclusive of transaction costs, mutual fund expenses, and any custodial fees charged by third parties. GWF does not share in any of these costs and remains fully independent in its recommendations. Selection of Other Advisers We do not charge you a separate fee for the selection of other advisers. We will share in the advisory fee you pay directly to the TPMM. The advisory fee you pay to the TPMM is established and payable in accordance with the brochure provided by each TPMM to whom you are referred. These fees may or may not be negotiable. Our compensation may differ depending upon the individual agreement we have with each TPMM. As such, a conflict of interest exists where our firm or persons associated with our firm has an incentive to recommend one TPMM over another TPMM with whom we have more favorable compensation arrangements or other advisory programs offered by TPMMs with whom we have less or no compensation arrangements. You may be required to sign an agreement directly with the recommended TPMM(s). You may terminate your advisory relationship with the TPMM according to the terms of your agreement with the TPMM. You should review each TPMM's brochure for specific information on how you may terminate your advisory relationship with the TPMM and how you may receive a refund, if applicable. You should contact the TPMM directly for questions regarding your advisory agreement with the TPMM. Fee Billing Methods In the Wealth Management services described above, fees may be paid monthly or quarterly. The client may cancel the service within the first five (5) days for a full refund of all fees paid. If the client cancels the service after five (5) days, fees will be prorated through the date of termination, and any unearned fees paid in advance will be refunded to the client. Fees may be negotiated at the discretion of the firm. Investment Management fees are collected quarterly, in advance. If the investment management relationship is terminated during a billing period, fees will be prorated through the date of termination, and any unearned fees will be refunded. For Investment Management Services, fees are typically deducted from a designated client account. The client must provide written authorization in advance to permit direct debiting of their investment account. 7  For financial consulting services, fees are payable upfront via credit card or PayPal at the time of booking. Clients may cancel their consultation and receive a full refund if cancellation occurs prior to the scheduled service. Other Fees Custodians may charge transaction fees on purchases or sales of certain mutual funds and exchange-traded funds. These transaction charges are usually small and incidental to the purchase or sale of a security. The selection of the security is more important than the nominal fee that the custodian charges to buy or sell the security. Item 12 further describes the factors that the firm considers in selecting or recommending broker- dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). Expense Ratios Exchange-traded funds and mutual funds generally charge a management fee for their services as investment managers. The management fee is called an expense ratio. For example, an expense ratio of 0.50 means that the mutual fund company charges 0.50% for their services. These fees are in addition to the fees paid by the client to GWF. Performance figures quoted by mutual fund companies in various publications are after their fees have been deducted. Past Due Accounts and Termination of Agreement GWF reserves the right to stop work on any account that is more than 30 days overdue. In addition, GWF reserves the right to terminate any financial planning engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in GWF's judgment, to provide proper financial advice. Any unused portion of fees collected in advance will be refunded. To terminate our Investment Management services a written notice should be submitted at least 30 days prior to the actual termination date, which provides clear instruction on what the client wants done with their account (i.e., liquidate the account, finalize all transactions and/or cease all investment activity). Once the termination notice has been received and we have implemented the final instructions from the client, we are no longer responsible for the management of client assets. From the date that the termination goes into effect, it becomes the clients' responsibility to make their own investment decisions. GWF does not refund fees for accounts terminated in the middle of the quarter. Item 6 Performance-Based Fees and Side-By-Side Management Fees are not based on a share of the capital gains or capital appreciation of managed securities. GWF does not use a performance-based fee structure because of the potential conflict of interest. Performance-based compensation may create an incentive for the adviser to recommend an investment that may carry a higher degree of risk to the client. As described above, GWF provides its services for a fixed fee, hourly charges and/or based upon a percentage of assets under management. Item 7 Types of Clients Overview GWF generally offers investment advice to individuals, pension and profit-sharing plans, trusts, estates, or charitable organizations, corporations, or business entities. In addition, GWF has among its clientele several non-profit organizations. Account Minimums 8  In general, GWF requires a minimum investment of $1,000,000 to open and maintain an Investment Management advisory account. At our discretion, we may waive this minimum account size. For example, we may waive the minimum if you appear to have significant potential for increasing your assets under our management. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis GWF employs an evidence-based investment approach grounded in academic research and empirical data. Our methodology aligns with the principles of Dimensional Fund Advisors (DFA) and is informed by financial science, market efficiency theories, and historical data. We prioritize factors such as market efficiency, diversification, and risk-adjusted returns in portfolio construction. Our primary sources of information include peer-reviewed financial research, corporate filings, prospectuses, financial newspapers and magazines, corporate rating services, and economic reports. We analyze market trends through fundamental and economic analysis, evaluating factors such as corporate earnings, valuation metrics, and macroeconomic conditions. We also consider long-term market cycles to mitigate the impact of short-term volatility. Investment Strategies Our investment philosophy is rooted in strategic asset allocation and factor-based investing, which emphasizes broad market diversification, risk management, and cost efficiency. GWF constructs globally diversified portfolios that incorporate exposure to key dimensions of higher expected returns identified by academic research, including size (small-cap premium), value (high book-to-market ratio), and profitability. Rather than attempting to time markets or pick individual stocks, we utilize low-cost, tax-efficient investment vehicles such as passively managed index funds, exchange-traded funds (ETFs), and Dimensional-style factor- based funds. While our approach is primarily strategic, meaning long-term in nature, we incorporate disciplined rebalancing to maintain target asset allocations and optimize risk-adjusted returns. Client portfolios are tailored based on individual objectives, time horizon, risk tolerance, and tax considerations. GWF collaborates with clients to establish these parameters during consultations, and portfolios are adjusted as necessary to reflect changing financial circumstances. Third-Party Money Managers (TPMMs): While GWF primarily manages client assets directly, we may, in certain circumstances, recommend the use of third-party money managers (TPMMs) to provide specialized investment strategies. GWF does not receive compensation from TPMMs for referrals, ensuring that our recommendations remain in the best interest of the client. Clients are not required to use any TPMM we recommend. Risk of Loss All investments carry inherent risks, and while our approach emphasizes risk management, there is no guarantee against market declines. The primary risks investors may face include: Market Risk: Securities prices can fluctuate due to broader economic conditions, political events, and investor sentiment. Even a well-diversified portfolio is subject to market downturns. Interest-Rate Risk: Fixed-income securities may decline in value if interest rates rise, impacting bondholders and income-focused investors. 9  Inflation Risk: The purchasing power of investments may erode over time if returns do not outpace inflation. Liquidity Risk: Some assets, such as real estate or private equity investments, may be difficult to sell quickly without incurring a loss. Currency Risk: International investments are subject to fluctuations in exchange rates, which can impact the value of holdings denominated in foreign currencies. Reinvestment Risk: The potential for reinvested funds to earn lower returns, particularly relevant to fixed-income securities. Business and Financial Risk: Companies and industries face unique operational risks, including regulatory changes, economic downturns, and excessive debt levels that may impact profitability. While market risk cannot be eliminated, GWF’s globally diversified, evidence-based investment approach seeks to mitigate unnecessary risks and enhance long-term financial outcomes for clients. Our disciplined rebalancing and long-term investment philosophy help maintain alignment with client objectives while reducing exposure to avoidable speculation and market timing. Item 9 Disciplinary Information Registered Investment Advisers such as GWF are required to disclose all material facts regarding any legal or disciplinary event that would be material to a client's or prospective client's evaluation of GWF or the integrity of its management. Neither GWF nor any of its employees have any such events to report. Item 10 Other Financial Industry Activities and Affiliations GWF does not offer any other services or have any affiliates in the financial industry. GWF does not have any affiliation with any related person who is a broker-dealer, investment company, other investment advisor, financial planning firm, commodity pool operator, commodity trading adviser or futures commission merchant, banking or thrift institution, accounting firm, law firm, insurance company or agency, pension consultant, real estate broker or dealer, or an entity that creates or packages limited partnerships. Scott Anderson is an investment adviser representative with Scott Anderson Financial, Inc., an unaffiliated state-registered investment adviser. Having the ability to offer advisory services creates a conflict of interest because it creates a financial incentive to recommend certain advisory products that result in advisory fees. You are under no obligation, contractually or otherwise, to engage in advisory services through Mr. Anderson. GWF occasionally refers clients to Scott Anderson Financial Inc. for tax preparation services. In no way are clients obligated to maintain the services of Scott Anderson Financial Inc. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics GWF has established a Code of Ethics (the "Code") pursuant to Rule 204A-1 of the Investment Advisers Act of 1940, as amended (the "Advisers Act''). As an investment adviser, GWF has an undivided duty of loyalty to act solely in the best interests of its clients, an obligation which includes the responsibility to make full and fair disclosure of all material facts, especially where GWF's interest may conflict with those of its clients. In carrying on its daily affairs, GWF and all its employees, shall act in a fair, lawful and ethical manner, in accordance with the rules and regulations imposed by GWF's governing regulatory authority (e.g., United 10  States Securities and Exchange Commission, California Department of Financial Protection & Innovation, etc.) The employees at GWF have committed to adhering to the Certified Financial Planner Board of Standards, Inc. Code of Ethics and Professional Responsibility. A copy of the Code of Ethics is available for review by clients and prospective clients upon request. Participation or Interest in Client Transactions GWF and its employees buy or sell securities that are also held by clients. Employees will not trade their own securities ahead of client trades. GWF makes no purchases or sales of recommended securities for its own account. Employees are prohibited from effecting any securities transactions for themselves without full disclosure to GWF. Should an employee make a transaction in a security in which the price fluctuates during a day, for both his or her own account and that of a client, the higher price on a purchase and the lower price on a sale is always assigned to the employee. Personal Trading The Chief Compliance Officer of GWF is Julie Bray, CFP®. She reviews all employee transactions each quarter. The review ensures that the personal trading of employees does not affect the markets, and that clients of GWF receive preferential treatment over employee transactions. Since most employee transactions are small mutual fund trades or exchange-traded fund trades, the trades do not affect the securities markets. Item 12 Brokerage Practices Selecting Brokerage Firms Clients must maintain assets in an account at a "qualified custodian", generally a broker-dealer or bank. We recommend that a client in need of brokerage and custodial services use Charles Schwab & Co., Inc. ("Schwab"). GWF does not have any affiliation with product sales firms. Specific custodian recommendations are made to Clients based on their need for such services. GWF usually encourages the use of discount-type brokers and/or no-load funds. GWF does not attempt to determine who might be the lowest-cost provider (for any transactions.) GWF does not receive fees or commissions from any of these arrangements. Best Execution GWF reviews the execution of trades from time to time. GWF does not receive any portion of the trading fees. Soft Dollars GWF receives no soft dollar reimbursements from any broker or referral institutions. However, GWF does receive products and services from Schwab that may be used to service all or a substantial number of our clients' accounts. Schwab may waive or discount fees for these products and services at its discretion. Schwab makes available other services intended to help GWF manage and further develop their business enterprise, including consulting, publications, practice management conferences, information technology, business succession planning, regulatory compliance, and marketing. In addition, Schwab may make available, arrange and/or pay for these types of services by independent third parties. Schwab Institutional 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 GWF. As a fiduciary, we endeavor to act in our clients' best interests at all times. Our recommendation that clients maintain their assets in accounts at Schwab are based solely on the nature, cost or quality of custody and brokerage services provided by Schwab regardless of any other products or services which may be provided to GWF. We are aware, however, that the 11  availability of some of the foregoing products and services may create a potential conflict of interest. Directed Brokerage Clients may direct us to use a particular broker for custodial or transaction services on behalf of the client's portfolio. In directed brokerage arrangements, the client is responsible for negotiating the commission rates and other fees to be paid to the broker. When a client directs brokerage we may be unable to achieve most favorable execution of client transactions, and this practice may cost clients more money and result in a certain degree of delay in executing trades for their account(s) and otherwise adversely impact management of their account(s). Thus, when directing brokerage business, you should consider whether the commission expenses, execution, clearance, and settlement capabilities that you will obtain through your broker are adequately favorable in comparison to those that we would otherwise obtain for you. Order Aggregation Most trades are mutual funds where trade aggregation does not garner any client benefit. When purchasing exchange-traded funds or individual securities, GWF may aggregate trades through block trading. GWF has authority to determine, without obtaining specific client consent, the securities to be bought or sold and/or the amount of the securities to be bought or sold. Neither GWF nor any of its employees has authority to determine the broker or dealer used or the commission rates paid. Item 13 Review of Accounts Investment Management portfolios are reviewed at least quarterly by Julie Bray. More frequent reviews are triggered by market or economic conditions or by events related to the client's personal financial life. Other conditions that may trigger a review are changes in the tax laws, new investment information and changes in a client's own situation. Both types of plans, Financial Planning and Investment Management, may be reviewed as fundamental factors advice, and at the client's complete discretion. Account reviews are performed more frequently when market conditions dictate. For Institutional-Style and Professional-Style Investment Management clients, reports are furnished quarterly or more often as occasionally requested by the client. Each report contains the beginning date and amount of the portfolio, the amounts of net contributions to and withdrawals from the portfolio, the ending value of the portfolio and the time-weighted annualized return that data represents. Standard Portfolio Management clients will be furnished such reports at the client request, for which an hourly charge may be applied. Full updates for Financial Planning clients are done as contracted for by the client and include the value of each investment and the on-going suitability of each. Item 14 Client Referrals and Other Compensation GWF does not pay referral fees for client referrals. Refer to the Brokerage Practices section above for disclosures on research and other benefits we may receive resulting from our relationship with your account custodian. 12  Item 15 Custody Withdrawal of Fees With a client's consent, GWF is provided with the authority to seek deduct of fees from a client's account maintained with a qualified custodian. Account statements All assets are held at qualified custodians, which mean the custodians provide account statements directly to clients at their address of record at least quarterly. If you are not receiving at least quarterly custodial account statements, please contact us at the number on the cover page of this brochure. Performance Reports Upon receipt of the performance report statements provided by GWF, clients are urged to compare these reports with the account statements received directly from their custodians. Item 16 Investment Discretion Discretionary Authority for Trading Within GWF's services discussed above under Investment Management, the client signs a Limited Power of Attorney giving GWF the authority to direct the placement of the client's funds in such a program as mutual funds and other investment vehicles selected by GWF and in amounts determined by GWF. These funds are placed into accounts registered directly to the client. The only access to the client's funds by GWF is the debiting of fees from the client's account(s). GWF has no authority to move the funds outside of such accounts except on the authority of the client and then only by mail, wire or other direct transmission to the client. Likewise, GWF has no authority to add client's funds to such a program; such additions may be made only on the client's authority. GWF does not receive any portion of the transaction fees paid by the client to the custodian on certain trades. Limited Power of Attorney A limited power of attorney is a trading authorization for this purpose. The client signs a limited power of attorney so that GWF may execute the trades in the client's portfolio. Item 17 Voting Client Securities GWF does not vote proxies on securities. Clients are expected to vote their own proxies. When assistance on voting proxies is requested, GWF will provide recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client. Item 18 Financial Information GWF does not have any financial impairment that will preclude its meeting contractual commitments to clients. A balance sheet is not required to be provided because GWF does not serve as a custodian for client funds or securities, and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 13