IRON FINANCIAL LLC

Form ADV Part 2A: Firm Brochure October 2025 Item 1 – Cover Page IRON Financial, LLC IRON Wealth Holdings, LLC 630 Dundee Road Suite 300 Northbrook, IL 60062 Telephone: 847-715-3200 Contact email: tim.ziemba@ironfinancial.com Website: www.ironfinancial.com This brochure provides information about the qualifications and business practices of IRON Financial, LLC and IRON Wealth Holdings, LLC. If you have any questions about the contents of this brochure, please contact us at 847-715-3200 or tim.ziemba@ironfinancial.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority and registration with the United States Securities and Exchange Commission and does not imply a certain level of skill or training. Additional information about IRON Financial, LLC and IRON Wealth Holdings, LLC is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The CRD number for IRON Financial, LLC is 106682, and the CRD number for IRON Wealth Holdings, LLC is 332402. 1  Item 2 – Material Changes October 2025 Update The “IRON Equity Income 40” strategy has been renamed “IRON Equity Income Portfolio”. IRON now offers Private Investment Advisory services. Please see Items 4 and 5 for additional details. March 2025 Update IRON’s office has moved from Suite 200 to Suite 300. Our building has not changed. Item 4 and Item 5 now contain information on Vanguard Personalized Indexing, a service that can be employed to better manage capital gains taxes when indexing with equity securities. IRON has discontinued the IRON Income & Growth Portfolio. July 2024 Update In addition to IRON Financial, LLC, this disclosure brochure now also includes information on IRON Wealth Holdings, LLC, which will issue private funds to offer accredited investors opportunities to invest in nonpublic securities. In late June 2024, IRON Wealth Holdings, LLC issued its first private fund: IRON Private Series LLC. IRON Financial, LLC now offers strategy “IRON Equity Income 40”. Please see Item 4 for more details. February 2024 Update Financial planning services are now being offered. Please see Items 4 and 5 for additional details. The IRON S&P 500 Equity Plus Strategy was discontinued. 2  Item 3 – Table of Contents Item 3 – Table of Contents Item 1 – Cover Page ................................................................................................................................................................. 1 Item 2 – Material Changes ....................................................................................................................................................... 2 Item 3 – Table of Contents ...................................................................................................................................................... 3 Item 4 – Advisory Business ...................................................................................................................................................... 4 Item 5 – Fees and Compensation ............................................................................................................................................ 6 Item 6 – Performance-Based Fees and Side-By-Side Management ......................................................................................... 9 Item 7 – Types of Clients .......................................................................................................................................................... 9 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................................................... 9 Item 9 – Disciplinary Information .......................................................................................................................................... 12 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................................ 12 Item 11 – Code of Ethics, Participation or Interest in Client Transactions & Personal Trading .............................................. 12 Item 12 – Brokerage Practices ............................................................................................................................................... 13 Item 13 – Review of Accounts ................................................................................................................................................ 14 Item 14 – Client Referrals and Other Compensation ............................................................................................................. 15 Item 15 – Custody .................................................................................................................................................................. 16 Item 16 – Investment Discretion ............................................................................................................................................ 16 Item 17 – Voting Client Securities .......................................................................................................................................... 17 Item 18 – Financial Information ............................................................................................................................................. 17 Part 2B of Form ADV: Brochure Supplement ........................................................................................................................ 18 Aaron Bruce Izenstark ....................................................................................................................................................... 18 Part 2B of Form ADV: Brochure Supplement ........................................................................................................................ 20 Timothy Robert Ziemba ..................................................................................................................................................... 20 Part 2B of Form ADV: Brochure Supplement ........................................................................................................................ 23 Richard Louis Lakin ............................................................................................................................................................ 23 3  Item 4 – Advisory Business IRON Financial, LLC (or “IRON Financial”) and IRON Wealth Holdings, LLC (or “IRON Wealth Holdings”, and collectively “IRON”, “we”, “us”) are investment advisory firms with their principal place of business located in Illinois. IRON began conducting business in 1994. Listed below, are the firm's principal owners: • Howard Lee Nixon • Aaron Bruce Izenstark We offer the following advisory services to our clients: PORTFOLIO MANAGEMENT IRON Financial is dedicated to providing high quality strategies in fixed income, equity, and alternative investment marketplaces. Leveraging our expertise in the primary and secondary capital markets and quantitative and qualitative proprietary processes, IRON strives to deliver strategies and managed solutions that meet the needs and exceed the expectations of sophisticated investors. We provide the following discretionary investment management services: Fixed Income Portfolios: IRON’s fixed income portfolios are designed either for short term cash management or for strategic and diversified allocation to the fixed income asset class on a long term basis. Our portfolio managers use their experience and expertise in the fixed income money and capital markets to build and manage portfolios that match clients’ individual goals and objectives. To provide complete transparency, IRON uses a fee-only pricing model and, unlike many broker-dealers, is never the counterparty for client trades. IRON Incertus Portfolio: The IRON Incertus Portfolio offers an actively managed diversified asset-class exposure to global equities, bonds, commodities, and inflation-protected securities. The strategy’s objective is to outperform a moderate target risk index, while delivering lower drawdown. IRON runs two variants of the strategy. To comprise the equity allocation, one variant utilizes individual stock positions while the other utilizes exchange traded funds (ETFs). The variant utilizing individual stock positions is more actively managed while the ETF variant is more passively managed. IRON High-Quality Equity Portfolio: The IRON High-Quality Equity Portfolio (“High-Q”) is a large capitalization, actively managed, minimum variance equity strategy that seeks to generate capital growth with minimum volatility in every market environment. It strives to maintain a broadly diversified, optimally weighted exposure to mid and large market-cap stocks, with the potential for capital growth. This is pursued by identifying high quality firms with improving operating and long-term earnings potential characteristics. The overall goal of the strategy is to generate S&P 500 Index like returns, but with lower volatility and greater consistency in both up and down markets. IRON Core Plus Portfolios: The IRON Core Plus Portfolios offer diversified exposure to global equities and fixed income in varying proportions in an attempt to maintain varying levels of correlation to the S&P 500. These provide investors with choices representing different amounts of risk, price volatility, and potential return. The target weights of the portfolios are as follows. 4  • Conservative Portfolio: 20% Equity, 80% Fixed Income • Moderately Conservative Portfolio: 35% Equity, 65% Fixed Income • Moderate Portfolio: 50% Equity, 50% Fixed Income • Moderately Aggressive Portfolio: 65% Equity, 35% Fixed Income • Aggressive Portfolio: 80% Equity, 20% Fixed Income IRON Equity Income Portfolio: The IRON Equity Income Portfolio is an actively managed "All-Cap" portfolio (i.e. may include small, medium, and large size companies). The strategy invests in stocks of well-capitalized firms with great cash flow, a long history of increasing dividends, and the ability to continue increasing dividends in the future. The primary objective of the strategy is to provide growth while also increasing investor income over time. Personalized Indexing: IRON’s Personalized Indexing service partners with Vanguard Personalized Indexing (“VPI”) as a subadvisor to manage for a mutual client a separate account of equity securities such that its allocation mimics that of a target index. How closely or loosely the account follows the constitution of the target index is customizable and determined with a client prior to implementation of the strategy. VPI will then effect trades in the account in an attempt to accumulate capital losses and/or minimize capital gains taxes while maintaining the account’s asset allocation / exposure at a predefined proximity to the target index. Alternatively, if none of the above-listed strategies managed by IRON Financial fits how a client would like to invest, IRON may customize a portfolio for a client using any number of publicly traded or private investments. PRIVATE FUNDS IRON – through IRON Wealth Holdings – offers private funds that, in turn, invest in opportunistic nonpublic and unaffiliated debt and equity offerings. Generally, these private funds are only available to “accredited investors” – investors whose net worth excluding equity in their primary residence is over one million dollars or whose income individually has been over $200,000 ($300,000 with spouse or partner) for the prior two years with expectation for the income threshold to be met for the current year as well. These private funds are not available at all times; private funds are issued a few times per year, but that is dependent on market conditions and opportunities available. PRIVATE INVESTMENT ADVISORY For clients who meet certain requirements imposed by private security issuers, such as the “accredited investor” requirement listed above, IRON Financial offers services to facilitate the acquisition and ongoing monitoring of direct investment in non-public securities on a non-discretionary basis and outside of IRON’s private funds described above. This includes identifying, analyzing, and conducting due diligence on private investment opportunities, determining whether a private investment fits into a client’s total portfolio given the client’s risk tolerance and already existing sources and types of risk, working with a client’s tax professionals to understand how any specific private investment opportunity will affect the client’s state and federal taxes, negotiating pricing of private securities on a client’s behalf, monitoring the health of any purchased private securities, reporting on at least a quarterly basis to the client data on private investment performance, and relaying tax forms to the client on an annual basis. FINANCIAL PLANNING 5  IRON Financial offers various financial planning services. This may include: • Reviewing Client’s personal and financial goals • Reviewing Client’s net worth • Cash flow analysis and/or budgeting • Education planning • Retirement planning, including projections and simulations • Advising the Client on any corporate benefits • Tax planning • Reviewing the Client’s insurance needs • Reviewing the Client’s estate plan • General financial advice on any personal matter on which Client has questions Financial planning services are offered as ongoing services to be reviewed with the client periodically. IRON does not currently offer one-time financial planning services. AMOUNT OF MANAGED ASSETS As of December 31, 2024, IRON had the following amount of assets under management: Discretionary Non-Discretionary Managed Assets Total Assets Under Management $463,724,750 $8,412,325 $472,137,075 Item 5 – Fees and Compensation PORTFOLIO MANAGEMENT FEES Fees for portfolio management services will be a percentage of assets under management. Fixed Income Portfolios are charged a maximum annual fee of 0.35% of assets under management. These accounts have a minimum fee of $50 per quarter. An initial minimum of $300,000 is required for accounts utilizing traditional fixed income issues. The initial minimum for accounts utilizing fixed income ETF securities is $10,000. IRON Incertus Portfolios are charged a maximum annual fee of 0.59% of assets under management. These accounts have a minimum fee of $50 per quarter. An initial minimum of $250,000 is required for accounts utilizing individual stocks to comprise the equity allocation. For accounts utilizing ETF securities to comprise the equity allocation, the initial minimum is $10,000. IRON High-Quality Equity Portfolios are charged a maximum annual fee of 0.59% of assets under management. These accounts have a minimum fee of $50 per quarter. An initial minimum of $250,000 is required for this service. IRON Core Plus Portfolios are charged a maximum annual fee of 0.50% of assets under management. These accounts have a minimum fee of $50 per quarter. An initial minimum of $10,000 is required for this service. IRON Equity Income Portfolios are charged a maximum annual fee of 0.59% of assets under management. These accounts have a minimum fee of $50 per quarter. An initial minimum of $200,000 is required for this service. 6  Personalized indexing accounts may be charged a maximum annual fee of 0.65% by IRON. These accounts will also be charged fees by Vanguard Personalized Indexing (“VPI”). Clients utilizing personalized indexing will be provided by IRON prior to the start of services and annually thereafter a copy of VPI’s Form ADV Part 2A Firm Brochure, which will include further details on the services, including VPI’s fees. Fully customized portfolios may be charged a maximum annual fee of 1.00% of assets under management depending upon the complexity and the due diligence and resources required. Generally, an initial minimum of $300,000 is required for this service. This minimum investment may be higher in some circumstances, e.g. if a client wishes to invest in illiquid private securities that in turn have relatively high minimum investment requirements. PRIVATE FUND FEES On private funds, IRON will generally assess a management fee on called/invested capital (not committed capital) and a carried interest (performance-based) fee. Depending on the terms of the private fund, the carried interest fee might only be assessable if investors have met a Preferred Capital Achievement Hurdle (“Hurdle”) – a minimum annualized return on investment. If a Hurdle is defined, once that Hurdle is met, the carried interest fee may be calculated from total profit or from only the profit in excess of the Hurdle. Management fees are typically between 0.50% and 2.00% of invested capital per year, and carried interest fees are typically between 5% and 20% of total investment profits and assessed if a Preferred Capital Achievement Hurdle is met. Fees are debited from the private fund investor’s balance in the private fund. Additional details on private fund fees are described in each private fund’s agreement. PRIVATE INVESTMENT ADVISORY FEES For private investment advisory services, IRON will generally assess two fee types. IRON will assess a nominal fee of $3,000 to $5,000 payable when a client purchases a non-public security through the program. This fee is designed to cover work performed and expenses incurred prior to and concurrent with the purchase. IRON will also assess an ongoing management fee, generally 1.00% to 2.00% of invested capital per year. FINANCIAL PLANNING FEES Like for portfolio management, fees for ongoing financial planning services will be a percentage of assets under management. Ongoing financial planning services can take many different forms. The fee rate may vary widely depending on the scope of work required. The maximum annual financial planning fee is 1.00% of assets under management. FEE CALCULATION AND PROCESSING Our fees are billed in arrears at the end of each calendar quarter based upon the value (market value or fair market value in the absence of market value), of the client's account at the end of the previous quarter. Quarterly fees are calculated by taking the annual billing percent, multiplying it by the month ending balance at the end of the billing period and dividing the total by 4. All fees are prorated for contributions and withdrawals during the billing period. Fees will be debited from the client’s custodial account unless otherwise agreed to in writing. Sub Advised accounts may be billed in a different manner. We may group certain related client accounts for the purposes of achieving the minimum account size and determining the annualized fee. LIMITED NEGOTIABILITY OF ADVISORY FEES 7  We retain the discretion to negotiate alternative fees and minimums on a client-by-client basis. We may offer discounts to family members and friends of associated persons of our firm. TERMINATION OF THE ADVISORY RELATIONSHIP A client agreement may be canceled at any time, by either party, for any reason upon receipt of 5 days written notice. Upon termination of any account, any earned but unpaid fees will be due and payable to IRON. MUTUAL FUND AND ETF FEES All fees clients pay us for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and/or ETFs to their shareholders. These fees and expenses are described in each fund's prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or ETF directly, without our services. In that case, the client would not receive the services provided by our firm which are designed, among other things, to assist the client in determining which mutual fund or funds are most appropriate to each client's financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and our fees to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. WRAP FEE PROGRAMS AND SEPARATELY MANAGED ACCOUNT FEES Clients participating in separately managed account programs may be charged various program fees in addition to the advisory fee charged by our firm. Such fees may include the investment advisory fees of the independent advisors, which may be charged as part of a wrap fee arrangement. In a wrap fee arrangement, clients pay a single fee for advisory, brokerage, and custodial services. Client’s portfolio transactions may be executed without commission charge in a wrap fee arrangement. In evaluating such an arrangement, the client should also consider that, depending upon the level of the wrap fee charged by the broker-dealer, the amount of portfolio activity in the client’s account, and other factors, the wrap fee may or may not exceed the aggregate cost of such services if they were to be provided separately. We will review with clients any separate program fees that may be charged to clients. Discretionary Manager for Wrap Programs (Wrap Clients): IRON may serve as a Portfolio Manager in wrap fee programs. While we attempt to manage the Wrap Clients similarly to our other clients, the presence of the Wrap Sponsor effectively limits our control in doing so. Wrap Programs are arrangements in which investment advisory services, brokerage execution services, and custody are provided by a sponsor for a single predetermined wrap fee (regardless of the number of trades completed by a Wrap Client). Generally, clients participating in a wrap program pay a single, all-inclusive fee to the Program Sponsor, based on the assets under management. IRON receives from the Program Sponsor a portion of the wrap fee for the portfolio management services it provides. The Wrap Sponsor has prepared a brochure which contains detailed information about its wrap program, including the wrap fee charged. Copies of the brochure are available from the Program Sponsor upon request. Wrap Clients should be aware that IRON will not be provided with sufficient information to perform an assessment as to the suitability of services for the Wrap Client. IRON relies on the Wrap Sponsor to determine not only the suitability of the services for the client but also the suitability of the wrap fee programs for the client. IRON does not serve as a sponsor to any wrap or similar managed account programs. Fees and Compensation – Wrap Clients: 8  For its portfolio management services, IRON receives from the Wrap Sponsor a portion of the wrap fee paid by the Wrap Client to the Wrap Sponsor. Please see the Wrap Sponsor’s ADV Part 2 for a description of total fees paid by the Wrap Client to the Wrap Sponsor. ADDITIONAL FEES AND EXPENSES In addition to our advisory fees, clients are also responsible for the fees and expenses charged by custodians and imposed by broker-dealers, including, but not limited to, any transaction charges imposed by a broker- dealer with which an independent investment manager effects transactions for the client's account(s). Please refer to the Brokerage Practices (Item 12) of this brochure for additional information. ADVISORY FEES IN GENERAL Clients should note that similar advisory services may (or may not) be available from other registered (or unregistered) investment advisors for similar or lower fees. Item 6 – Performance-Based Fees and Side-By-Side Management Performance-based fees are assessed only on investments in IRON’s private funds. Please see Item 5 for additional detail. For investors in private funds that also receive Portfolio Management services from IRON, as described in Item 5, an asset-based fee will be utilized for Portfolio Management accounts, and both a management fee and a performance-based fee will be utilized for the private fund(s). This creates a potential conflict of interest, as IRON may receive greater compensation for investments in IRON’s private funds. Despite its offering of private funds, IRON remains a fiduciary and will not advise investors to participate in a private fund if it is not appropriate given the investor’s circumstances. For example, if investing in the private fund, which is generally very illiquid, would leave an investor with too little liquidity or overexpose the investor to market risks, IRON will advise against investment in a private fund. Item 7 – Types of Clients We provide advisory services to the following types of clients: 1. Individuals (other than high net worth individuals) 2. High net worth individuals 3. Trusts 4. Charitable organizations 5. Corporations or other businesses not listed above 6. Private funds (IRON Wealth Holdings only) As previously disclosed in Fees and Compensation (Item 5), we have established certain initial minimum account requirements based on the nature of the service(s) being provided. For a more detailed understanding of those requirements, please review the disclosures provided for each applicable service. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss METHODS OF ANALYSIS We use the following methods of analysis -- often jointly -- in formulating our investment advice and managing clients’ assets: Fundamental Analysis: We attempt to measure the intrinsic or relative value of a security or group of securities by looking at a wide 9  variety of economic and financial factors (including macroeconomic data on employment, housing, manufacturing, retail sales, GDP, inflation, etc., industry conditions, the financial condition and management of the companies, consumer sentiment, position and shape of the yield curve, bond credit spreads, commodity prices, etc.) to determine if a stock, bond, collection of stocks and/or bonds, or other asset is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell else exclude from a portfolio). There are two primary risks that result from this type of analysis. First, any unusual pricing relationship that we attempt to exploit may persist, widen, or, in some cases become the new normal as market participants evolve how they value assets. Second, the underlying data that suggested the unusual pricing relationship may adjust over time such that the pricing relationship is no longer unusual, in which case there may no longer be a profit opportunity. Technical Analysis: We analyze past market movements and apply that analysis to the present to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company, economic data, or other covariables; it merely looks at history of trading prices and volumes. Used in isolation, the risk of technical analysis is that it is blind to other variables that may help explain an asset’s price history or how that asset might be priced in the future. Quantitative Analysis: Quantitative analysis looks at large datasets of assets, their price histories, and various historical metrics in an attempt to algorithmically achieve via a multivariate model a desired outcome, such as higher average returns or less volatility or lower drawdowns versus a benchmark. This presents risks similar to those for fundamental analysis. When relationships among variables diverge, a quantitative model may position a portfolio such that it profits when the relationships among the variables revert back to their historical norms. However, if the long-term relationships among those variables are changing, that mean reversion may never happen, which could lead to underperformance and/or losses. Risks for all forms of analysis: Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, contracted data providers, and publicly available sources of information about these securities are providing accurate data. While we are alert to indications that data may be incorrect or inconsistent, there is risk that our analysis may be compromised by inaccurate or misleading information. INVESTMENT STRATEGIES We use the following strategy(ies) in managing clients’ accounts, provided that such strategy(ies) are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: Long-term purchases: We purchase securities with the idea of holding them in the client's account for a year or longer or until the security’s maturity if it has one. Typically, we employ this strategy when: 1. We believe the securities to be currently undervalued, and/or 10  2. We want exposure to a particular asset class over time, regardless of the short-term projection for this class. A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantage of short-term opportunities that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline in value before we make the decision to sell. Short-term purchases: When utilizing this strategy, we purchase securities with the idea of selling them or, if they are fixed income securities, having them mature within a relatively short time (typically a year or less). We might do this to take advantage of conditions that we believe will soon result in an upward price swing in the securities we purchase or a downward price swing in other securities with good long-term potential into which we intend to rotate. Within fixed income, we might utilize short-term securities to mitigate risk. A short-term purchase strategy poses risks should the anticipated price swing not materialize. It is possible that securities bought for the short-term – whether intending to reap a short-term profit or mitigate market risks – underperform securities that may have higher return in the long run. In addition, this strategy involves more frequent trading than does a longer-term strategy and may result in increased brokerage or other transaction-related costs and less favorable tax treatment of capital gains. Margin transactions: Though rare, and with your permission, we may purchase securities for your portfolio with money borrowed from your brokerage account. Margin allows you to either (1) purchase more stock than you would be able to with your available cash and without selling other holdings or (2) take a cash withdrawal in excess of your current cash balance. A risk in using margin is that, in volatile markets, security prices can fall very quickly. If the value of the securities in your account minus what you owe the broker falls below a certain level defined by the Federal Reserve Board, the broker will issue a “margin call,” and you will be required to sell your position in the security purchased on margin or add more cash to the account. It is possible, then, to lose more money than you originally invested. Option writing: We may use options within an investment strategy. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a specific price on or before a certain date. An option, just like a stock or bond, is a security. An option is also a derivative because it derives its value from an underlying asset. The two types of options are calls and puts. 1. A call gives the holder the right to buy an asset at a certain price within a specific period of time. We may buy a call if we believe that the stock will increase substantially before the option expires. 2. A put gives the holder the right to sell an asset at a certain price within a specific period of time. We may buy a put if we believe that the price of the stock will fall before the option expires. We may use “covered calls”, which involves selling call options when you simultaneously own the underlying securities. In this strategy, you receive a fee (a “premium”) for granting to the purchaser of the options for a limited period of time a right to buy the underlying securities from you at a price specified in the option contract. 11  There are two main risks of covered calls. First, during the life of the option contract, the value of the underlying could decrease more than the amount of fee/premium collected from the option buyer, which, when netted together, will result in a loss. Second, the value of the underlying could increase substantially above and beyond the price at which the option purchaser may buy the underlying via the terms of the option contract. When this happens, the strategy’s performance will be worse than it would have been if only the underlying were owned and no option contract were sold. Risk of Loss: Securities investments are not guaranteed, and you may lose money on your investments. We ask that you work with us both at the onset of an advisory relationship and as your needs or circumstances change to help us understand your tolerance for risk. Item 9 – Disciplinary Information We are required to disclose any legal or disciplinary events that are material to a client's or prospective client's evaluation of our advisory business or the integrity of our management. Our firm and our management personnel have no reportable disciplinary events to disclose. Item 10 – Other Financial Industry Activities and Affiliations Whereas IRON Financial manages assets for clients utilizing publicly traded securities or independent private equity or debt, IRON Wealth Holdings – an affiliate of IRON Financial – manages private funds of equity and/or debt securities for our clients. As noted in Item 6, this creates a potential conflict of interest, as we may receive greater compensation for investments in private funds managed by IRON Wealth Holdings. Despite its offering of private funds, IRON and all of its personnel remain fiduciaries and will not advise investors to participate in a private fund if it is not appropriate given the investor’s circumstances. Item 11 – Code of Ethics, Participation or Interest in Client Transactions & Personal Trading Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that we require of our employees, including compliance with applicable federal securities laws. Our firm and our personnel owe a duty of loyalty, fairness, and good faith towards our clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code. Our Code of Ethics includes policies and procedures for the review of securities transactions reports, as well as initial and annual securities holdings reports that must be submitted by the firm’s access persons. Among other things, our Code of Ethics also requires the prior approval of any acquisition of securities in a limited offering (e.g., private placement) or an initial public offering (“IPO”). Our Code of Ethics also provides for oversight, enforcement, and recordkeeping provisions. Our Code of Ethics further includes the firm's policy prohibiting the use of material non-public information. While we do not believe that we have any access to non-public information, all employees are reminded 12  that such information may not be used in a personal or professional capacity. A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by email sent to tim.ziemba@ironfinancial.com or by calling us at 847-715-3200. Our firm and individuals associated with our firm are prohibited from engaging in principal transactions and agency-cross transactions. Our Code of Ethics is designed to assure that the personal securities transactions, activities, and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Our firm and/or individuals associated with our firm may buy or sell for their personal accounts securities identical to or different from those recommended to our clients. In addition, any related person(s) may have an interest or position in securities which may also be recommended to a client. It is the express policy of our firm that no person with visibility of IRON’s investment process may purchase or sell any security prior to any execution of purchases or sales of that security for an advisory client account. This policy exists to prevent IRON personnel from benefiting from transactions placed on behalf of advisory accounts, which is known as “frontrunning”. IRON may aggregate our employee trades with client transactions where possible and when compliant with our duty to seek best execution for our clients. In these instances, participating clients and employees will receive an average share price and transaction costs will be shared equally. In the instances where there is a partial fill of a particular batched order, we will allocate all purchases pro-rata, with each account paying the average price. In that scenario, IRON’s employee accounts would be included in the pro-rata allocation. As these situations represent actual or potential conflicts of interest to our clients, we have established the following policies and procedures for implementing our firm’s Code of Ethics, to ensure our firm complies with its regulatory obligations and provides our clients and potential clients with full and fair disclosure of such conflicts of interest: 1. No principal or employee of our firm may put his or her own interest above the interest of an advisory client. 2. No principal or employee of our firm may buy or sell securities for their personal portfolio(s) where their decision is a result of information received as a result of his or her employment unless IRON’s clients have had the opportunity to participate first or concurrently. Our firm requires prior approval for any IPO or private placement investments by IRON personnel. All of our principals and employees must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. IRON delivers its Code of Ethics to all IRON personnel annually. IRON then requires all personnel to sign an affirmation that they have read it and agree to comply with its guidelines. IRON has established policies requiring the reporting of Code of Ethics violations to our senior management team. Any individual who violates any of our established policies may be subject to termination. Item 12 – Brokerage Practices We will block trades where possible and when advantageous to clients. The blocking of trades permits the 13  trading of aggregate blocks of securities composed of assets from multiple client accounts, so long as transaction costs are shared equally and on a pro-rated basis between all accounts included in any such block. Block trading may allow us to execute equity trades in a more timely and equitable manner and at an average share price. We will typically aggregate trades among clients whose accounts can be traded at a given broker, and generally will rotate or vary the order of brokers through which we place trades for clients on any particular day. If we are unable to aggregate trades due to the fact that client accounts are on different platforms, we will seek to execute the trades in a manner so that one platform is not favored over another. We may recommend that clients establish brokerage accounts with the Schwab Institutional division of Charles Schwab & Co., Inc. (“Schwab”), a FINRA registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. Although we may recommend that clients establish accounts at Schwab, it is the client’s decision to custody assets with Schwab. We are independently owned and operated and not affiliated with Schwab. Schwab provides us with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as the advisor maintains sufficient client assets in accounts at Schwab Institutional. These services are not contingent upon our committing to Schwab any specific amount of business (assets in custody or trading commissions). Schwab’s brokerage services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. Schwab Institutional also makes available to us other products and services that benefit us but may not directly benefit clients’ accounts. Many of these products and services may be used to service our accounts, which potentially may include accounts not maintained at Schwab. Schwab’s products and services that assist us in managing and administering clients’ accounts include software and other technology that: (i) provide access to client account data (such as trade confirmations and account statements): (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of our fees from clients’ accounts; and (v) assist with back-office functions, recordkeeping, and client reporting. Schwab Institutional also offers other services intended to help us manage and further develop its business enterprise. These services may include: (i) compliance, legal and business consulting; (ii) publications and conferences on practice management and business succession; (iii) access to employee benefits providers, human capital consultants, and insurance providers; and (iv) educational material qualifying for continuing education credit toward various professional credentials. 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 us. Schwab Institutional may also provide occasional business entertainment for our personnel. In evaluating whether to recommend a client custody their assets at Schwab, we may take into account the availability of some of the foregoing products and services and other arrangements as part of the total mix of factors we consider and not solely on the nature, cost, or quality of custody and brokerage services provided by Schwab, which may create a potential conflict of interest. Item 13 – Review of Accounts REVIEWS While the underlying securities within individual Portfolio Management Services accounts are monitored more frequently, accounts are reviewed at least annually. Accounts are reviewed in the context of each client's stated investment objectives and guidelines. Accounts will generally be rebalanced as asset allocation drifts from the target determined by the client’s risk tolerance, stated wishes, and agreed upon investment strategy, 14  though this may be subject to client approval where rebalancing would trigger material tax consequences. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, or the market, geopolitical, or economic environment. REPORTS In addition to the monthly statements and confirmations of transactions that clients receive from their custodian, we provide reports that summarize performance, holdings, bond exposure and maturity schedule, external cash flows, and asset allocation on a monthly or quarterly basis to clients that elect to utilize this additional tool. These reports are relayed electronically to all clients who have an email address and via mail for clients who do not have an email address. Clients are encouraged to compare the information within reports generated by IRON to the statements they receive from their custodian(s). Item 14 – Client Referrals and Other Compensation CLIENT REFERRALS Our firm may pay referral fees to independent persons or firms ("Solicitors") for introducing clients to us. When we pay a referral fee, either the Solicitor, if required under the Solicitor agreement, or we provide the prospective client with a copy of this brochure and a separate disclosure statement that includes the following information: 1. The Solicitor's name and relationship with our firm; 2. The fact that the Solicitor is being paid a referral fee; 3. The amount of the referral fee; 4. Whether the fee paid to us by the client will be increased above our normal fees in order to compensate the Solicitor; and 5. A description of any conflicts of interest The compensation we pay to those persons who may solicit or refer clients to us may be either a one- time referral or a percentage of the advisory fees we earn for the management of the referred client's account. The ongoing compensation may range from 15% to 50% of the advisory fees earned depending on the particular circumstances of the relationship. The ongoing compensation will continue to be paid as long as the referred client remains our advisory client. IRON received client referrals from TD Ameritrade, which is now part of Charles Schwab & Co., Inc. (“Schwab”), through its past participation in TD Ameritrade’s AdvisorDirect referral program. TD Ameritrade was and Schwab is a broker-dealer independent of and unaffiliated with IRON, and there has been no employee or agency relationship between them. TD Ameritrade established AdvisorDirect as a means of referring its brokerage customers and other investors seeking fee-based personal investment management services or financial planning services to independent investment advisors. Neither TD Ameritrade in the past nor Charles Schwab in current state supervises IRON and has no responsibility for IRON’s management of client portfolios or IRON’s other advice or services. IRON paid TD Ameritrade and now pays Schwab an ongoing fee for each successful client referral. The Solicitation Fee is tiered. The tiers are dependent on the amount of referred client assets and does not exceed 0.25% of managed assets annually. If an account belonging to a referred client is self-directed or has a concentrated equity position, or if the client’s household is deemed small, Schwab will waive the fee charged to IRON. IRON will also pay Schwab the Solicitation Fee on any assets managed by IRON for any of a referred client’s family members, including a spouse, child, or any immediate family member who resides with the referred client and hired Advisor on the recommendation of such referred client. IRON will not charge clients referred via AdvisorDirect any fees or costs higher than its standard fee schedule offered to its clients or otherwise pass through to its clients Solicitation Fees paid to Schwab. For additional information regarding 15  TD Ameritrade’s legacy AdvisorDirect program, please refer to the TD Ameritrade AdvisorDirect Disclosure and Acknowledgement Form, which is available upon request to tim.ziemba@ironfinancial.com. IRON’s participation in AdvisorDirect raises potential conflicts of interest. With respect to clients referred to IRON via AdvisorDirect, IRON has agreed not to transfer their accounts from Schwab or to establish brokerage or custody accounts at other custodians except when IRON’s fiduciary duties require doing so. IRON’s participation in AdvisorDirect does not diminish its duty to seek best execution of trades for client accounts. As a matter of firm practice, advisory fees paid to IRON by clients referred by Solicitors are not increased as a result of any referral. To minimize conflicts of interest and because we feel it is the right thing to do, it is IRON’s policy not to accept or allow our related persons to accept any form of compensation, including cash, sales awards, or other prizes, from a non-client in conjunction with the advisory services we provide to our clients. Item 15 – Custody We previously disclosed in the Fees and Compensation section (Item 5) of this brochure that our firm directly debits fees from client accounts. For all clients who do not participate in IRON’s private fund offerings, we will not have possession of client’s cash or securities. Clients will receive confirmations for each transaction, as they occur, from the custodian of the accounts. Clients will also receive a monthly statement from the custodian summarizing all activities in their accounts. As part of the billing process, the client's custodian is advised of the amount of the fee to be deducted from that client's account. On at least a quarterly basis, the custodian is required to send to the client a statement showing all transactions within the account during the reporting period. Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review their custodial statements to verify the accuracy of the calculation. If Portfolio Management clients receive statements of account from IRON in addition to statements produced by the custodian(s) of the assets, we strongly recommend that clients compare the statements. One known potential source of difference is the treatment of accrued income from fixed income securities. Whereas IRON’s statements will reflect accrued income as an asset due to its use of accrual accounting, custodians may omit accrued income until it is actually paid due to their use of cash accounting. Additionally, IRON will report transactions and holdings according to the date they were initiated (money transfers, trades) whereas custodians may not report transactions and holdings until they are settled, which can often be a day or two following the initiation/trade date. Clients are encouraged to contact IRON where unexplained discrepancies between statements or potential errors are detected. For clients who invest in the Private Fund offerings of IRON Wealth Holdings, IRON Wealth Holdings has custody of client funds invested into the securities. IRON Wealth Holdings will deliver to Private Fund investors statements on a quarterly basis. For each private fund, IRON Wealth Holdings will have the fund’s financial statements audited annually by an independent public accountant registered with and subject to inspection by the Public Company Accounting Oversight Board. The audited financial statements will then be delivered by IRON Wealth Holdings to every investor in the fund. Item 16 – Investment Discretion 16  Clients utilizing Portfolio Management services retain us to provide discretionary asset management services, in which case we place trades in a client's account without contacting the client prior to each trade to obtain the client's permission. Our discretionary authority includes the ability to do the following without contacting the client: 1. Determine the security to buy or sell. 2. Determine the amount of the security to buy or sell. 3. Determine the time to buy or sell. Clients give us discretionary authority when they sign a discretionary agreement with our firm and may limit this authority by giving us written instructions. Clients may also change/amend such limitations by providing us with written instructions. Clients may have non-discretionary assets in their accounts. Item 17 – Voting Client Securities We do not vote proxies on behalf of clients. Although our firm may provide investment advisory services relative to client investment assets, clients maintain exclusive responsibility for (1) directing the manner in which proxies solicited by issuers of securities owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, bankruptcy proceedings, or other corporate events pertaining to the client’s investment assets with the exception of tender offers from bond issuers. IRON will make decisions on behalf of clients when tender offers are provided by bond issuers. We may provide clients with consulting assistance regarding proxy issues if they contact us with questions at our principal place of business. Item 18 – Financial Information We have no additional financial circumstances to report. Under no circumstances do we require or solicit payment of fees in excess of $1,200 per client six months or more in advance of services rendered. We have not been the subject of a bankruptcy petition at any time during the past ten years. 17  Part 2B of Form ADV: Brochure Supplement Aaron Bruce Izenstark IRON Financial, LLC 630 Dundee Road Suite 300 Northbrook, IL 60062 847-715-3200 October 2025 This brochure supplement provides information about Aaron Bruce Izenstark that supplements the IRON Financial, LLC brochure. You should have received a copy of that brochure. Please contact Timothy Ziemba at 847-715-3200 or tim.ziemba@ironfinancial.com if you did not receive IRON Financial, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Aaron Bruce Izenstark is available on the SEC’s website at www.adviserinfo.sec.gov. 18  Item 2 Educational, Background and Business Experience Full Legal Name: Aaron Bruce Izenstark Born: 1964 Education • Indiana University; BA, Business; 1986 Business Experience • IRON Wealth Holdings: President and Chief Executive Officer, 2024 to Present • IRON Financial: Co-Founder, President and Chief Investment Officer, 1994 to Present Item 3 Disciplinary Information Aaron Bruce Izenstark has no reportable disciplinary history. Item 4 Other Business Activities A. Investment-Related Activities 1. Aaron Bruce Izenstark is not engaged in any other investment-related activities. 2. Aaron Bruce Izenstark does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non Investment-Related Activities Aaron Bruce Izenstark is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Item 5 Additional Compensation Aaron Bruce Izenstark does not receive any economic benefit from anyone other than IRON’s clients for the provision of advisory services. Item 6 Supervision Supervisor: Not Applicable Please contact Chief Compliance Officer Timothy Ziemba if there are any questions or concerns. Email: tim.ziemba@ironfinancial.com Phone: 847-715-3200 19  Part 2B of Form ADV: Brochure Supplement Timothy Robert Ziemba IRON Financial, LLC 630 Dundee Road Suite 300 Northbrook, IL 60062 847-715-3200 October 2025 This brochure supplement provides information about Timothy Robert Ziemba that supplements the IRON Financial, LLC brochure. You should have received a copy of that brochure. Please contact Timothy Ziemba at 847-715-3200 or tim.ziemba@ironfinancial.com if you did not receive IRON Financial, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Timothy Robert Ziemba is available on the SEC’s website at www.adviserinfo.sec.gov. 20  Item 2 Educational, Background and Business Experience Full Legal Name: Timothy Robert Ziemba Born: 1983 Education • University of Illinois at Urbana-Champaign; BA, Economics & Statistics; 2006 Professional Designations Timothy Robert Ziemba is a CFA® charterholder. The Chartered Financial Analyst® designation is a professional credential offered by CFA Institute to investment and financial professionals. Its obtainment requires the fulfilment of education and work experience standards as well as a passing score on each of its three examinations, each of which, according to CFA Institute, typically demand over 300 hours of study by successful candidates. Topics in which charterholders must display proficiency are as follows: • Ethics • Quantitative methods • Economics • Corporate finance • Financial reporting and analysis • Security analysis • Portfolio management Maintenance of the CFA® charter requires an annual pledge to comply with the CFA Institute Code of Ethics and Standards of Professional Conduct. Timothy Robert Ziemba is also a CFP® (CERTIFIED FINANCIAL PLANNER™) professional. The CFP® certification is a professional certification mark for financial planners conferred in the United States by the Certified Financial Planner Board of Standards. Its obtainment requires the fulfilment of education and work experience standards as well as a passing score on its 6-hour certification examination. Its retention requires continuing education and adherence to the CFP Board’s Standards of Professional Conduct, which prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. Topics in which designation holders must display proficiency are as follows: • General principles of finance • Insurance planning • Employee benefits planning • Investment and securities planning • State and federal income tax planning • Estate tax, gift tax, and transfer tax planning • Asset protection planning • Retirement planning • Estate planning 21  • Financial planning and consulting Business Experience • IRON Wealth Holdings: Chief Compliance Officer, 06/2024 to Present • IRON Financial: Chief Compliance Officer, 08/2021 to Present • IRON Financial: Director of Private Client, 01/2019 to Present • Life Line Wealth Management LLC: Wealth Manager, 07/2014 to 01/2019 • Life Line Financial Group LLC: Consultant, 07/2014 to 01/2019 • Aon Corporation: Finance Manager, 04/2014 to 07/2014 • Aon Corporation: Senior Financial Analyst, 08/2011 to 03/2014 Item 3 Disciplinary Information Timothy Robert Ziemba has no reportable disciplinary history. Item 4 Other Business Activities A. Investment-Related Activities 1. Timothy Robert Ziemba is not engaged in any other investment-related activities. 2. Timothy Robert Ziemba does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non Investment-Related Activities Timothy Robert Ziemba is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Item 5 Additional Compensation Timothy Robert Ziemba does not receive any direct monetary benefit from any source other than clients for the provision of advisory services. However, Charles Schwab provides Timothy with educational opportunities via seminars and conferences. Therefore, IRON Financial’s relationship with Charles Schwab provides Timothy with an economic benefit. Item 6 Supervision Supervisor: Aaron Izenstark Title: President and CIO Phone Number: 847-715-3200 22  Part 2B of Form ADV: Brochure Supplement Richard Louis Lakin IRON Financial, LLC 630 Dundee Road Suite 300 Northbrook, IL 60062 847-715-3200 October 2025 This brochure supplement provides information about Richard Louis Lakin that supplements the IRON Financial, LLC brochure. You should have received a copy of that brochure. Please contact Timothy Ziemba at 847-715-3200 or tim.ziemba@ironfinancial.com if you did not receive IRON Financial, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Richard Louis Lakin is available on the SEC’s website at www.adviserinfo.sec.gov. 23  Item 2 Educational, Background and Business Experience Full Legal Name: Richard Louis Lakin Born: 1961 Education • University of Illinois; BA; 1983 • Kent College of Law; JD; 1986 Business Experience • IRON Financial: Investment Advisor, 08/2021 to Present • IRON Financial: Chief Compliance Officer, 06/1996 to 07/2021 Item 3 Disciplinary Information Richard Louis Lakin has no reportable disciplinary history. Item 4 Other Business Activities A. Investment-Related Activities 1. Richard Louis Lakin is not engaged in any other investment-related activities. 2. Richard Louis Lakin does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non Investment-Related Activities Richard Louis Lakin is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. Item 5 Additional Compensation Richard Louis Lakin does not receive any economic benefit from anyone other than IRON’s clients for the provision of advisory services. Item 6 Supervision Supervisor: Aaron Izenstark Title: President and CIO Phone Number: 847-715-3200 24