SECURA FINANCIAL, LLC

Firm Brochure (Part 2A of Form ADV) Secura Financial, LLC 333 City Boulevard West, Suite 2050 Orange, CA 92868-2944 PHONE: 714-704-6616 FAX: 714-704-1513 WEBSITE: www.securawm.com EMAIL: Richard@securawm.com This brochure provides information about the qualifications and business practices Secura Financial, LLC. Being registered as an investment adviser does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at 714-704-6616, or by email at richard@securawm.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about Secura Financial, LLC (CRD #137324) is available on the SEC’s website at www.adviserinfo.sec.gov April 30, 2025 Secura Financial, LLC  Item 2: Material Changes Annual Update Material Changes since the Last Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. • This update is in accordance with the annual filing requirements for Investment Advisors. Since the last filing of this brochure on March 21, 2024, the following has been updated: Full Brochure Available Item 4 has been updated with the firm’s current assets under management. This Firm Brochure being delivered is the complete brochure for the Firm. i Secura Financial, LLC  Item 3: Table of Contents Form ADV – Part 2A – Firm Brochure Item 1: Cover Page Firm Brochure .......................................................................................................................................... i Item 2: Material Changes ...................................................................................................................... i Annual Update .................................................................................................................................................. i Material Changes since the Last Update ................................................................................................ i Item 3: Table of Contents .................................................................................................................... ii Full Brochure Available ................................................................................................................................ i Item 4: Advisory Business .................................................................................................................. 6 Firm Description ............................................................................................................................................ 6 Types of Advisory Services ........................................................................................................................ 6 Client Tailored Services and Client Imposed Restrictions ............................................................. 7 Wrap Fee Programs ...................................................................................................................................... 8 Item 5: Fees and Compensation ....................................................................................................... 8 Client Assets under Management ............................................................................................................ 8 Method of Compensation and Fee Schedule........................................................................................ 8 Client Payment of Fees ...............................................................................................................................10 Additional Client Fees Charged ..............................................................................................................10 Prepayment of Client Fees ........................................................................................................................10 Item 6: Performance-Based Fees ................................................................................................... 10 External Compensation for the Sale of Securities to Clients .......................................................10 Item 7: Types of Clients ..................................................................................................................... 11 Sharing of Capital Gains .............................................................................................................................10 Description .....................................................................................................................................................11 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .............................. 11 Account Minimums .....................................................................................................................................11 Methods of Analysis ....................................................................................................................................11 Investment Strategy ....................................................................................................................................11 ii Secura Financial, LLC  Item 9: Disciplinary Information ................................................................................................... 13 Security Specific Material Risks .............................................................................................................11 Criminal or Civil Actions ...........................................................................................................................13 Administrative Enforcement Proceedings .........................................................................................13 Item 10: Other Financial Industry Activities and Affiliations ............................................. 13 Self-Regulatory Organization Enforcement Proceedings .............................................................13 Broker-Dealer or Representative Registration ................................................................................13 Futures or Commodity Registration .....................................................................................................14 Material Relationships Maintained by this Advisory Business and Conflicts of Interest 14 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Recommendations or Selections of Other Investment Advisors and Conflicts of Interest14 Trading ................................................................................................................................................... 15 Code of Ethics Description .......................................................................................................................15 Investment Recommendations Involving a Material Financial Interest and Conflict of Interest .............................................................................................................................................................15 Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest .............................................................................................................................................................15 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Item 12: Brokerage Practices ......................................................................................................... 16 Transactions and Conflicts of Interest .................................................................................................16 Factors Used to Select Broker-Dealers for Client Transactions .................................................16 Item 13: Review of Accounts ........................................................................................................... 17 Aggregating Securities Transactions for Client Accounts ............................................................17 Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved ..........................................................................................................................................17 Review of Client Accounts on Non-Periodic Basis ..........................................................................17 Item 14: Client Referrals and Other Compensation ................................................................ 17 Content of Client Provided Reports and Frequency .......................................................................17 Economic benefits provided to the Advisory Firm from External Sources and Conflicts of Interest .............................................................................................................................................................17 Item 15: Custody .................................................................................................................................. 18 Advisory Firm Payments for Client Referrals ...................................................................................18 Account Statements ....................................................................................................................................18 iii Secura Financial, LLC  Item 16: Investment Discretion ..................................................................................................... 18 Item 17: Voting Client Securities ................................................................................................... 19 Discretionary Authority for Trading ....................................................................................................18 Item 18: Financial Information ...................................................................................................... 19 Proxy Votes ....................................................................................................................................................19 Balance Sheet .................................................................................................................................................19 Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients ............................................................................................................................19 Brochure Supplement (Part 2B of Form ADV) .......................................................................... 20 Bankruptcy Petitions during the Past Ten Years .............................................................................19 Supervisor/Management Person Brochure ............................................................................... 20 Harry M. Barth, CLU, CFP®, ChFC, CAPP™ ................................................................................... 20 Brochure Supplement (Part 2B of Form ADV) .......................................................................... 21 Principal Executive Officer .......................................................................................................................21 Harry M. Barth, CLU, CFP®, ChFC, CAPP™ .........................................................................................21 Educational Background and Business Experience .......................................................................21 Professional Certifications .......................................................................................................................21 Other Business Activities Engaged In ..................................................................................................23 Additional Compensation .........................................................................................................................23 Supervisor/Management Person Brochure ............................................................................... 24 Supervision .....................................................................................................................................................23 Richard W. Jackman, CFP®, CRPS®, CAS®, CFS®, CTS®, BCE ............................................. 24 Principal Executive Officers and Management Persons ...............................................................25 Educational Background and Business Experience .......................................................................25 Professional Certifications .......................................................................................................................25 Disciplinary Information ...........................................................................................................................27 Other Business Activities ..........................................................................................................................27 Additional Compensation .........................................................................................................................27 Supervision .....................................................................................................................................................27 iv Secura Financial, LLC  Supervised Person Brochure .......................................................................................................... 28 Part 2B of Form ADV .......................................................................................................................... 28 Brochure Supplement (Part 2B of Form ADV) .......................................................................... 29 Jason Douglas Stone CFP® .......................................................................................................................28 Additional Investment Advisor Representative Item 2 Educational Background and Business Experience .......................................................................29 .................................................29 Professional Certifications .......................................................................................................................29 Item 3 Disciplinary Information ............................................................................................................30 Item 4 Other Business Activities ............................................................................................................30 Item 5 Additional Compensation ...........................................................................................................31 Item 6 Supervision ......................................................................................................................................31 v Secura Financial, LLC  Item 4: Advisory Business Firm Description Secura Financial, LLC, (“Advisor”) was founded in 1997. The ownership of the business is as follows: Harry M. Barth 40%; Richard W. Jackman 30%; Jason Stone 25%; and Casey Hatcher 5%. Advisor provides fee based personalized financial planning and confidential portfolio management to individuals, pension and profit sharing plans, banks or thrift institutions, trusts, estates, and charitable organizations and other business entities. 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. While Advisor does not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products, Investment Advisor Representatives associated with Advisor may be affiliated with entities that sell insurance and securities products. Advisor does not act as a custodian of client assets. An evaluation of each client's initial situation is provided to the client, often in the form of a net worth statement or risk analysis. Periodic reviews are also communicated to provide reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended. Types of Advisory Services Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. Under CCR Section 260.238(k), Advisor, its representatives or any of its employees will disclose to the clients all material conflicts of interest. Advisor provides investment supervisory services, also known as asset management services and furnishes investment advice through consultations. Approximately 50% of the advice provided does not involve securities and is related to financial planning. Advisor may provide financial advice and recommend use of alternative investments, such as managed futures, structured notes, hedge funds and etc. which are organized as a partnership or LLC interest. ASSET MANAGEMENT Advisor offers discretionary direct asset management services to advisory clients. Advisor will offer clients ongoing portfolio management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The client will authorize Advisor 6 Secura Financial, LLC  discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement through a limited power of attorney or trading authorization. FINANCIAL PLANNING General financial planning inclusive of all disciplines (Review Cash Flow; Capital Needs Planning; Long Term Care Planning; Review Disability Needs; Retirement Planning; Review Education Cost; Estate Planning) required to produce comprehensive financial plan. The fee for the financial plan, general financial advice and/or research regarding a specific product or other financial matter not related to preparation of a written financial plan is due and payable upon signing of the Financial Planning and Investment Advisory Services Agreement. Under California Code of Regulations, 10 CCR Section 260.235.2 requires that the conflict of interest which exists between the interests of the investment advisor and the interests of the client when offering financial planning services is disclosed. The client is under no obligation to act upon the investment advisor’s recommendation. If the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through Advisor. REFERRAL ARRANGEMENTS Advisor uses the services of third party money managers to manage client accounts. In such circumstances, Advisor receives referral fees from the third party money manager. Advisor acts as the liaison between the client and the third party money manager in return for an ongoing portion of the advisory fees charged by the third party money manager. Advisor helps the client complete the necessary paperwork of the third party money manager, provides ongoing services to the client, will provide the third party money manager with any changes in client status as provided to Advisor by the client and review the quarterly statements provided by the third party money manager. Advisor will deliver the Form ADV Part 2, Privacy Notice and Referral Disclosure Statement of the third party money manager. Client Tailored Services and Client Imposed Restrictions Clients placed with third party money managers will be billed in accordance with the third party money manager’s fee schedule which will be disclosed to the client prior to signing an agreement. This is detailed in Item 10 of this brochure. The goals and objectives for each client are documented in our client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written client consent. 7 Secura Financial, LLC  Wrap Fee Programs Advisor is the sponsor of the Private Wealth Management II Program (“PWM”). Advisor has prepared a Wrap Fee Program Brochure (Form ADV Part 2A Appendix 1) which will be given to all clients placed in PWM. Client Assets under Management Advisor may utilize the Wrap Fee Programs sponsored by unaffiliated investment advisory firms whereas Advisor may acts as a co-advisor. More details will be described in the Sponsor’s Appendix 1 which will be provided to the clients if the client is placed in a wrap fee program. Advisor has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: $261,784,000 $0 Date Calculated: December 31, 2024 Item 5: Fees and Compensation Method of Compensation and Fee Schedule Advisor bases its fees on a percentage of assets under management. ASSET MANAGEMENT Advisor offers discretionary direct asset management services to advisory clients. The fee Equity and Balanced Accounts* schedules for these services are as follows: Market Value of Portfolio Max. Client Fee Max. Quarterly Fee On the first $1,000,000 On the next $1,500,000 1.99% 1.0% 0.4975% 0.25% On next $2,500,000 0.75% 0.1875% On the next $5,000,000 In excess of $10,000,000 0.50% 0.40% 0.125% 0.10% *With a minimum fee of $1,250 per quarter Fixed Income Accounts** Market Value of Portfolio Max. Client Fee Max. Quarterly Fee On the first $1,000,000 1.99% 0.4975% On the next $1,500,000 0.50% 0.125% On the next $2,500,000 0.40% 0.10% On the next $5,000,000 0.30% 0.075% In excess of $10,000,000 0.25% 0.0625% **With a minimum fee of $1,250 per quarter 8 Secura Financial, LLC  Equity and Balanced Accounts with Financial Planning and Consulting*** Market Value of Portfolio Max. Client Fee Max. Quarterly Fee On the first $1,000,000 2.25% 0.5625% On the next $1,500,000 1.10% 0.275% On the next $2,500,000 0.85% 0.2125% On the next $5,000,000 0.60% 0.15% In excess of $10,000,000 0.50% 0.125% ***With a minimum fee of $1,625 per quarter Advisor’s annual investment advisory fee shall include investment advisory services. Should the client be enrolled in the combined investment advisory and financial planning service, financial planning and consulting services are limited to those planning and consulting services offered by Advisor and specifically requested by the client. In the event that the client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of Advisor), Advisor may determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written notice to the client. Fees are billed quarterly in advance based on the amount of assets managed as of the close of business on the last business day of prior quarter. Quarterly advisory fees deducted from the clients' account by the custodian will be reflected in a provided fee invoice as fees are withdrawn. If margin is utilized, the fees will be billed based on the net asset value of the account. Lower fees for comparable services may be available from other sources. FINANCIAL PLANNING FEES Fees are negotiable and are usually based on a flat fee. However, in certain circumstances hourly fee may be charged. The maximum hourly rate is $500.00 per hour and a maximum fixed fee of $20,000.00 as fixed fees are agreed upon by contract between each client and advisor. This agreement may be terminated at any time upon written notice of Secura Financial, LLC or Client. A refund of any unearned fees will be based on the time and effort expended by Secura Financial, LLC before termination with the exception that a full refund of any fees paid will be made if the contract is terminated within five business days of its effective date. Secura Financial, LLC will not assign this agreement without the written consent of Client. Client shall be given thirty (30) days prior written notice of any increase in fees. REFERRAL FEES 9 Secura Financial, LLC  Client Payment of Fees Advisor at times will utilize the services of third party money managers and receive a referral fee for referring clients. The client will not pay additional advisory fees to the third party money manager for these services. This is detailed in Item 10 of this brochure. Additional Client Fees Charged Investment management fees are billed quarterly, in advance. Payment in full is expected upon invoice presentation. Fees are usually deducted from a designated client account to facilitate billing. The client must consent in advance to direct debiting of their investment account. Custodians may charge transaction fees on purchases or sales of certain mutual funds, equities and exchange-traded funds. These charges may include mutual fund transactions fees, postage and handling and miscellaneous fees (fee levied to recover costs associated with fees assessed by self-regulatory organizations). The selection of the security is more important than the nominal fee that the custodian charges to buy or sell the security. Margin interest may also apply for Client electing to utilize margin on their account(s). Advisor, in its sole discretion, may waive its minimum fee and/or charge a lesser investment advisory fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with clients, etc.). Prepayment of Client Fees For more details on the brokerage practices, see Item 12 of this brochure. Client may cancel within five (5) business days of signing the Investment Advisory Agreement for a full refund. If cancellation occurs after five (5) business days, client will External Compensation for the Sale of Securities to Clients be entitled to a pro-rata refund based on work completed. While Advisor does not receive any external compensation for the sale of securities to clients, Investment Advisor Representatives associated with Advisor will receive external compensation as registered representatives of a broker/dealer. Registered assistants of the broker/dealer do not receive any commissions for the sale of securities. Item 6: Performance-Based Fees Sharing of Capital Gains Fees are not based on a share of the capital gains or capital appreciation of managed securities. Advisor does not use a performance-based fee structure because of the 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. 10 Secura Financial, LLC  Item 7: Types of Clients Description Advisor generally provides investment advice to individuals, pension and profit sharing plans, banks or thrift institutions, trusts, estates, and charitable organizations and other business entities. Account Minimums Client relationships vary in scope and length of service. Advisor requires a minimum of $250,000 to open an account, but maybe waived at the Managing Member’s discretion. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include fundamental and cyclical analysis. Investing in securities involves risk of loss that clients should be prepared to bear. Past performance is not a guarantee of future returns. Fundamental analysis involves evaluating a stock using real data such as company revenues, earnings, return on equity, and profits margins to determine underlying value and potential growth. Cyclical analysis involves analyzing the cycles of the market. Investment Strategy The main sources of information include financial media, corporate rating services, research prepared by others, inspections of corporate activities, company press releases, annual reports, prospectuses, and filings with the Securities and Exchange Commission. The investment strategy for a specific client is based upon the objectives stated by the client during consultations. The client may change these objectives at any time. Each client executes an Investment Policy Statement, Risk Tolerance or similar form that documents their objectives and their desired investment strategy. Security Specific Material Risks Other strategies may include long-term purchases, short-term purchases, trading (securities sold within a year), margin transactions, and option writing (including covered options, uncovered options or spreading strategies). All investment programs have certain risks that are borne by the investor. Fundamental analysis may involve interest rate risk, market risk, business risk, and financial risk. Cyclical analysis involves inflation risk, market risk, and currency risk. Interest-rate Risk • Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks and should discuss these risks with Advisor: : Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. 11 Secura Financial, LLC  • Market Risk • : The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic and social conditions may trigger market Inflation Risk events. : When any type of inflation is present, a dollar today will buy more than a dollar next year, because purchasing power is eroding at the rate of • Currency Risk inflation. • Reinvestment Risk : Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Business Risk : This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Liquidity Risk : These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. • Financial Risk : Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Derivatives Risk: : Excessive borrowing to finance a business’ operations increases the risk to profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Funds in a client’s portfolio may use derivative instruments. The value of these derivative instruments derives from the value of an underlying asset, currency or index. Investments by a fund in such underlying funds may involve the risk that the value of the underlying fund’s derivatives may rise or fall more rapidly than other investments, and the risk that an underlying fund may lose more than the amount that it invested in the derivative instrument in the first place. Derivative instruments also involve the risk that other parties to the derivative contract may fail to meet their obligations, which could cause losses. 12 Secura Financial, LLC  • Options Trading • Trading on Margin: : The risks involved with trading options are that they are very time sensitive investments. An options contract is generally a few months. Clients should be aware that the use of options involves additional risks. The risks of covered call writing include the potential for the market to rise sharply. In such case, the security may be called away and the account will no longer hold the security. When purchasing options there is the risk that the entire premium paid for the option can be lost if the option is not exercised or otherwise sold prior to the option’s expiration date. When selling (“writing”) options, the risk of loss can be much greater if the options are written uncovered (“naked”). The risk of loss can far exceed the amount of the premium received for an uncovered option and in the case of an uncovered call option the potential loss is unlimited. In a cash account, the risk is limited to the amount of money that has been invested. In a margin account, risk includes the amount of money invested plus the amount that has been loaned. As market conditions fluctuate, the value of marginable securities will also fluctuate, causing a change in the overall account balance and debt ratio. As a result, if the value of the securities held in a margin account depreciates, the client will be required to deposit additional cash or make full payment of the margin loan to bring account back up to maintenance levels. Clients who cannot comply with such a margin call may be sold out or bought in by the brokerage firm. Item 9: Disciplinary Information Criminal or Civil Actions Administrative Enforcement Proceedings The firm and its management have not been involved in any criminal or civil action. Self-Regulatory Organization Enforcement Proceedings The firm and its management have not been involved in administrative enforcement proceedings. The firm and its management have not been involved in legal or disciplinary events related to past or present investment clients. Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration Harry M. Barth, Richard W. Jackman, and several IARs of Advisor are Registered Representatives/Assistants of Arkadios Capital. In the capacity of a registered representative, they offer securities and receive normal and customary compensation as a result of the transactions. Individuals registered as registered assistants of the broker/dealer do not receive any commission from the sale of securities These practices represent conflicts of interest because it gives them an incentive to recommend products based on the commission amount received. This conflict is 13 Secura Financial, LLC  mitigated by disclosures, procedures, and the firm’s fiduciary obligation to place the best interest of the client first and the clients are not required to purchase any products. Clients have the option to purchase these products through another registered Futures or Commodity Registration representative of their choosing. Richard W. Jackman is an associate person with the U.S. Commodity Futures Trading Material Relationships Maintained by this Advisory Business and Conflicts of Interest Commission (“CFTC”) and holds a Series 31 license. Harry M. Barth, Richard W. Jackman and other IARs of Advisor have financial industry affiliated businesses as licensed insurance agents. Harry M. Barth (real estate broker) is also affiliated with Fortress Equity Mortgage. Richard W. Jackman, Jason D. Stone and Brent Honea are also Registered Representatives with Arkadios Capital. In addition, Harry M. Barth is also a Registered Representative of Arkadios Capital. From time to time, they will offer clients advice or products from those activities and are compensated for their services. Harry M. Barth is an attorney and Senior Partner at the law firm of BarthCalderon, LLP (“BBC”), Brent Honea is a practicing attorney with BBC and Phillip Napper and Kraig Strom are legal assistants at the firm. These practices represent conflicts of interest because it gives them an incentive to recommend products or services based on the commission/fees received. This conflict is mitigated by disclosures, procedures, and the firm’s fiduciary obligation to place the best interest of the client first and the clients are not required to purchase any products or services. Clients have the option to purchase these products or services through another Recommendations or Selections of Other Investment Advisors and Conflicts of person of their choosing. Interest Advisor may at times utilize the services of Third Party Money Managers to manage client accounts. In such circumstances, Advisor will share in the Third Party asset management fee. This situation creates a conflict of interest. However, when referring clients to a third party money manager, the client’s best interest will be the main determining factor of Advisor. These fees do not include brokerage fees that may be assessed by the custodial broker dealer. Fees for these services will be based on a percentage of assets under management not to exceed any limit imposed by any regulatory agency. The final fee schedule will be attached to Exhibit D in Advisor's Investment Advisory Agreement. Prior to referring any clients to third party advisors, Advisor will make sure they are properly licensed, or notice filed with the Department of Business Oversight. 14 Secura Financial, LLC  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Description The employees of Advisor have committed to a Code of Ethics. The purpose of our Code of Ethics is to set forth standards of conduct expected of Advisor employees and addresses conflicts that may arise. The Code defines acceptable behavior for employees of Advisor. The Code reflects Advisor and its supervised persons’ responsibility to act in the best interest of their client. One area which the Code addresses is when employees buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our clients. We do not allow any employees to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our clients. Advisor’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other employee, officer or director of Advisor may recommend any transaction in a security or its derivative to advisory clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. Advisor’s Code is based on the guiding principle that the interests of the client are our top priority. Advisor’s officers, directors, advisors, and other employees have a fiduciary duty to our clients and must diligently perform that duty to maintain the complete trust and confidence of our clients. When a conflict arises, it is our obligation to put the client’s interests over the interests of either employees or the company. to clients, or who have access The Code applies to “access” persons. “Access” persons are employees who have access to non-public information regarding any clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to such recommendations that are non-public. The firm will provide a copy of the Code of Ethics to any client or prospective client upon Investment Recommendations Involving a Material Financial Interest and Conflict of request. Interest Advisor and its employees do not recommend to clients, securities in which we have a Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of material financial interest. Interest Advisor and its employees may buy or sell securities that are also held by clients. In order to mitigate conflicts of interest such as front running, employees are required to disclose all reportable securities transactions as well as provide Advisor with copies of their brokerage statements. 15 Secura Financial, LLC  The Chief Compliance Officer of Advisor is Harry M. Barth. He reviews all employee trades each quarter. The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the firm receive preferential treatment over Client Securities Recommendations or Trades and Concurrent Advisory Firm employee transactions. Securities Transactions and Conflicts of Interest Advisor does not maintain a firm proprietary trading account and does not have a material financial interest in any securities being recommended and therefore no conflicts of interest exist. Item 12: Brokerage Practices Factors Used to Select Broker-Dealers for Client Transactions • Directed Brokerage Advisor does recommend the use of a particular broker-dealer or may utilize a broker- dealer of the client's choosing. Advisor will only recommend broker-dealers who are registered in the state in which the client resides. Advisor will select appropriate brokers based on a number of factors including but not limited to their relatively low transaction fees and reporting ability. Advisor relies on its broker to provide its execution services at the best prices available. Lower fees for comparable services may be available from other sources. Clients pay for any and all custodial fees in addition to the advisory fee charged by Advisor. • Best Execution In circumstances where a client directs Advisor to use a certain broker-dealer, Advisor still has a fiduciary duty to its clients. The following may apply with Directed Brokerage: Advisor's inability to negotiate commissions, to obtain volume discounts, there may be a disparity in commission charges among clients, and conflicts of interest arising from brokerage firm referrals. • Soft Dollar Arrangements Investment advisors who manage or supervise client portfolios on a discretionary basis have a fiduciary obligation of best execution. The determination of what may constitute best execution and price in the execution of a securities transaction by a broker involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is effected, the ability to effect the transaction where a large block is involved, the operational facilities of the broker- dealer, the value of an ongoing relationship with such broker and the financial strength and stability of the broker. The firm does not receive any portion of the trading fees. Advisor utilizes the services of custodial broker dealers. Economic benefits are received by Advisor which would not be received if Advisor did not give investment advice to clients. These benefits include: A dedicated trading desk, a dedicated 16 Secura Financial, LLC  service group and an account services manager dedicated to Advisor's accounts, ability to conduct "block" client trades, electronic download of trades, balances and positions, duplicate and batched client statements, and the ability to have advisory fees directly deducted from client accounts. Aggregating Securities Transactions for Client Accounts A conflict of interest exists when the firm receives soft dollars. This conflict is mitigated by disclosures, procedures, and the firm’s fiduciary obligation to act in the best interest of his clients and the services received are beneficial to all clients. Advisor is authorized in its discretion to aggregate purchases and sales and other transactions made for the account with purchases and sales and transactions in the same securities for other Clients of Advisor. All clients participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rated basis. Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Review of Client Accounts on Non-Periodic Basis Account reviews are performed monthly or quarterly depending on the nature of the account and client relationship. All reviews are conducted by Harry M. Barth, Senior Manager and Richard W. Jackman, CFP, MSFS on a portfolio analysis basis. Account reviews are performed more frequently when market conditions dictate. Financial Plans are considered complete when recommendations are delivered to the client and a review is done only upon request of client. Content of Client Provided Reports and Frequency Other conditions that may trigger a review of clients’ accounts are changes in the tax laws, new investment information, and changes in a client's own situation. Clients receive account statements usually on a monthly basis, but no less than quarterly for managed accounts. Account performance reports are issued on a quarterly basis. Item 14: Client Referrals and Other Compensation Economic benefits provided to the Advisory Firm from External Sources and Conflicts of Interest Advisor receives a portion of the annual management fees collected by the Third Party Money Managers to whom Advisor refers clients. This situation creates a conflict of interest because the firm and/or its Investment Advisor Representative have an incentive to decide what Third Party Money Managers to use because of the higher referral fees to be received by the firm. However, when referring clients to a third party money manager, the client’s best interest will be the main determining factor of the firm and its representatives. 17 Secura Financial, LLC  Advisory Firm Payments for Client Referrals Advisor does compensate for employees and outside referring parties for client referrals. The fees charged to the clients are not increased because of the referral fees paid. Advisor may enter into referring party relationships. These individual referring parties refer clients to Advisor for services. Advisor pays a referral fee to the referring party based on its advisory fee and written agreement. Referring Parties will also be appropriately registered under federal and state securities laws where applicable. Client receives all related agreements and disclosures prior to or at the time of entering into an Investment Advisory Agreement. Item 15: Custody Account Statements All assets are held at qualified custodians, which means the custodians provide account statements directly to clients at their address of record at least quarterly. Clients are urged to compare the account statements received directly from their custodians to the performance report statements prepared by Advisor. Clients executed a limited power of attorney limiting Advisor the ability to only make withdrawals from the account solely for the purpose of deducting the agreed upon investment advisory fees. Advisor will send an invoice to the client disclosing the amount of the fee and how it was calculated including include the value of the assets upon which the fee was based. Advisor is deemed to have constructive custody solely because advisory fees are directly deducted from client’s account by the custodian on behalf of Advisor. Item 16: Investment Discretion Discretionary Authority for Trading Advisor accepts discretionary authority to manage securities accounts on behalf of clients. Advisor has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. Advisor limits its authority by prohibiting the withdrawing of funds and securities from the client’s accounts without direction from the client. The client approves the custodian to be used and the commission rates paid to the custodian. Advisor does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Discretionary trading authority facilitates placing trades in your accounts on your behalf so that we may promptly implement the investment policy that you have approved in writing. 18 Secura Financial, LLC  Item 17: Voting Client Securities Proxy Votes Advisor does not vote proxies on securities. Clients are expected to vote their own proxies. The client will receive their proxies directly from the custodian of their account or from a transfer agent. When assistance on voting proxies is requested, Advisor will provide recommendations to the client. If a conflict of interest exists, it will be disclosed to the client. Item 18: Financial Information Balance Sheet A balance sheet is not required to be provided because Advisor does not serve as a custodian for client funds or securities and Advisor does not require prepayment of fees Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet of more than $1200 per client and six months or more in advance. Commitments to Clients Bankruptcy Petitions during the Past Ten Years Advisor has no condition that is reasonably likely to impair our ability to meet contractual commitments to our clients. Neither Advisor nor its management has had any bankruptcy petitions in the last ten years. 19 Secura Financial, LLC  Brochure Supplement (Part 2B of Form ADV) Supervisor/Management Person Brochure Harry M. Barth, CLU, CFP®, ChFC, CAPP™ Secura Financial, LLC 333 City Boulevard West, Suite 2050 Orange, CA 92886 PHONE: 714-704-6616 FAX: 714-704-1513 EMAIL: Harry@securawm.com This brochure supplement provides information about Harry M. Barth and supplements Secura Financial, LLC’s brochure. You should have received a copy of that brochure. Please contact Harry M. Barth if you did not receive Secura Financial, LLC brochure or if you have any questions about the contents of this supplement. Additional information about Harry M. Barth (IARD #13891) is available on the SEC’s website at www.adviserinfo.sec.gov. April 30, 2025 20 Secura Financial, LLC  Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure Principal Executive Officer Harry M. Barth, CLU, CFP®, ChFC, CAPP™ • Educational Background and Business Experience Year of birth: 1947 Educational Background: • • • State University of New York; Bachelor of Arts – Liberal Arts; 1971 University of Sarasota, Florida; MBA – Masters in Financial Planning; 1985 Western State College University of Law – J.D. Juris Doctor; 1991 Business Experience: Harry has been in the financial services field for over 40 years and actively practicing individual comprehensive financial planning since 1978. Harry has also been a practicing attorney since 1991. Current business affiliations are as follows below: • • • • • • • • • Professional Certifications Secura Financial, LLC; Member/ Chief Compliance Officer; 01/1997 – Present Arkadios Capital; Registered Representative; 03/2024 - Present Crown Capital Securities, L.P.; Registered Representative; 01/2015- 03/2024 Bentley Financial & Insurance Services, Inc.; President/Agent; 01/2008 – Present BarthCalderon, LLP; Attorney/Senior Partner; 01/2003 - Present Fortress Equity Mortgage; Real Estate Broker; 1997 – 12/2021 J.W. Cole Advisors; Investment Advisor Representative; 01/2014 – 01/2015 J.W. Cole Financial, Inc.; Registered Principal/Branch Manager; 06/2012 – 01/2015 LPL Financial; Registered Principal/Branch Manager; 06/1993 – 06/2012 Employees have earned certifications and credentials that are required to be explained in further detail. Chartered Life Underwriter (CLU): Chartered Life Underwriters are licensed by the American College to use the CLU mark. CLU certification requirements: • • • Complete successfully CLU coursework 5 required and 3 elective Meet the experience requirements: Three years of business experience immediately preceding the date of use of the designation are required. An undergraduate or graduate degree from an accredited educational institution qualifies as one year of business experience. Take the Professional Ethics Pledge. 21 Secura Financial, LLC  • When you achieve your CLU designation, you must earn 30 hours of continuing education credit every two years. Certified Financial Planner (CFP®): Certified Financial Planners are licensed by the CFP Board to use the CFP mark. CFP® certification requirements: • • • • • • Bachelor’s degree from an accredited college or university. Completion of the financial planning education requirements set by the CFP Board (www.cfp.net). Successful completion of the 10-hour CFP® Certification Exam. Three-year qualifying full-time work experience. Successfully pass the Candidate Fitness Standards and background check. When you achieve your CFP® designation, you must renew your certification every year, pay $360 certification fee and complete 30 hours of continuing education. • Chartered Financial Consultant (ChFC): Chartered Financial Consultants are licensed by the American College to use the ChFC mark. ChFC certification requirements: • • • • Complete ChFC coursework within five years from the date of initial enrollment. Pass the exams for all required elective courses. You must achieve a minimum score of 70% to pass. Meet the experience requirements: Three years of business experience immediately preceding the date of use of the designation are required. An undergraduate or graduate degree from an accredited educational institution qualifies as one year of business experience. Take the Professional Ethics Pledge. When you achieve your ChFC designation, you must earn your recertification every two years. Certified Asset Protection Planner (CAPP™): Certified Asset Protection Planners are licensed by The Wealth Preservation Institute (www.thewpi.org) to use the CAPP mark. CAPP certification requirements: • • • • Complete an eighteen-hour educational course. Pass a 180-question multiple choice examination and a two (2) question essay examination. Must follow the Code of Ethics and Rules of Responsibility for CAPP™. When you achieve your CAPP designation, you are required to complete (18) hours of continuing education every two years. 22 Secura Financial, LLC  Other Business Activities Engaged In Harry M. Barth has affiliated businesses as an attorney, registered principal, real estate broker, and insurance agent. From time to time, he offers clients advice or products from these activities. These practices represent conflicts of interest because it gives Mr. Barth an incentive to recommend products or services based on the compensation amount received. This conflict is mitigated by disclosures, procedures, and the firm’s fiduciary obligation to place the best interest of the client first and the clients are not required to purchase any products or services. Clients have the option to purchase these products through another Additional Compensation person of their choosing. Supervision Mr. Barth receives compensation from his law practice, in his capacity as a registered representative for securities transactions, insurance companies for the products he sells, and as a real estate broker. He does not receive any performance based fees. Harry M. Barth is supervised by Richard W. Jackman. He reviews Harry’s work through frequent office interactions. Mr. Jackman can be contacted by: PHONE: 714-704-6616 ext. 102 or EMAIL: Richard@secruawm.com 23 Secura Financial, LLC  Supervisor/Management Person Brochure Richard W. Jackman, CFP®, CRPS®, CAS®, CFS®, CTS®, BCE Secura Financial, LLC 333 City Boulevard West, Suite 2050 Orange, CA 92886 PHONE: 714-704-6616 FAX: 714-704-1513 EMAIL: Richard@securawm.com This brochure supplement provides information about Richard W. Jackman and supplements Secura Financial, LLC brochure. You should have received a copy of that brochure. Please contact Richard W. Jackman if you did not receive Secura Financial, LLC brochure or if you have any questions about the contents of this supplement. Additional information about Richard W. Jackman (IARD #2501641) is available on the SEC’s website at www.adviserinfo.sec.gov. April 30, 2025 24 Secura Financial, LLC  , , , Principal Executive Officers and Management Persons Richard W. Jackman, , , • CFP® CRPS® CAS® CFS® CTS® BCE Educational Background and Business Experience Year of birth: 1965 • Educational Background: Institute of Business and Finance - California; Master of Science in Financial Services; 2009 • Business Experience: • • • • • • • • • Professional Certifications Secura Financial, LLC; Chief Investment Officer; 05/1997 – Present Secura Financial, LLC; Member; 11/2019 – Present Arkadios Capital; Registered Representative; 03/2024 - Present Crown Capital Securities, L.P.; Investment Advisor Representative; 11/2015 – 03/2024 Crown Capital Securities, L.P.; Registered Representative; 12/2014 – 03/2024 Bentley Financial & Insurance Services, Inc.; Endorsed Agent; 09/2008 – Present Fortress Equity Mortgage; Real Estate Loan Officer; 10/2006 – 12/2018 J.W. Cole Advisors; Investment Advisor Representative; 01/2014 - 12/2014 J.W. Cole Financial, Inc.; Registered Principal/Registered Representative; 06/2012 – 12/2014 LPL Financial; Registered Principal/Registered Representative; 05/1995 – 06/2012 Employees have earned certifications and credentials that are required to be explained in further detail. Certified Financial Planner (CFP®): Certified Financial Planners are licensed by the CFP Board to use the CFP® mark. CFP® certification requirements: • • • • • • Bachelor’s degree from an accredited college or university. Completion of the financial planning education requirements set by the CFP Board (www.cfp.net). Successful completion of the 10-hour CFP® Certification Exam. Three-year qualifying full-time work experience. Successfully pass the Candidate Fitness Standards and background check. When you achieve your CFP® designation, you must renew your certification every year, pay $360 certification fee and complete 30 hours of continuing education. 25 Secura Financial, LLC  • Chartered Retirement Plans Specialist (CRPS®): Chartered Retirement Plans Specialist is granted by the College for Financial Planning to use the CRPS® mark. CRPS® award requirements: • • • • Completion of the education requirements set by the College for Financial Planning. (www.cffp.edu). Successful pass of the CRPS® final examination. Comply with the Code of Ethics and abide by the Standard of Professional Conduct and Terms and Conditions. Successfully pass the Candidate Fitness Standards and background check. When you achieve your CRPS® designation, you must renew your certification every 2 years, pay $75 renewal fee and complete 16 hours of continuing education. • Certified Annuity Specialist (CAS®): Certified Annuity Specialist are licensed by the Institute of Business & Finance (“IBF”) to use the CAS® mark. CAS® certification requirements: • • Completion of six modules, 3 examinations and one case study. (www.icfs.com). Adhere to IBF’s Code of Ethics and Standards of Practice. When you achieve your CAS® designation, you are required to complete (30) hours of continuing education every two years. Certified Funds Specialist (CFS®): Certified Funds Specialist are licensed by the Institute of Business & Finance (“IBF”) to use the CFS® mark. CFS® certification • requirements: • • Completion of six modules, 3 examinations and one case study. (www.icfs.com). Adhere to IBF’s Code of Ethics and Standards of Practice. When you achieve your CFS® designation, you are required to complete (30) hours of continuing education every two years. • Certified Tax Specialist (CTS®): Certified Tax Specialist are licensed by the Institute of Business & Finance (“IBF”) to use the CTS® mark. CTS® certification requirements: • • Completion of six modules, 3 examinations and one case study. (www.icfs.com). Adhere to IBF’s Code of Ethics and Standards of Practice. When you achieve your CTS® designation, you are required to complete (30) hours of continuing education every two years. 26 Secura Financial, LLC  Board Certified Estate Planning (BCE): Board Certified estate Planning are licensed by the Institute of Business & Finance (“IBF”) to use the BCE mark. BCE certification • requirements: • • Completion of six modules, 3 examinations and one case study. (www.icfs.com). Adhere to IBF’s Code of Ethics and Standards of Practice. When you achieve your BCE designation, you are required to complete (30) hours of continuing education every two years. Disciplinary Information Other Business Activities None to report Richard W. Jackman has affiliated businesses as a registered principal and insurance agent. From time to time, he offers clients advice or products from these activities. Additional Compensation These practices represent conflicts of interest because it gives Mr. Jackman an incentive to recommend products or services based on the compensation amount received. This conflict is mitigated by disclosures, procedures, and the firm’s fiduciary obligation to place the best interest of the client first and the clients are not required to purchase any products or services. Clients have the option to purchase these products through another professional of their choosing. Supervision Mr. Jackman receives compensation in his capacity as a registered representative for securities transactions, and as an insurance companies on the insurance products he sells . He does not receive any performance based fees. Richard W. Jackman is supervised by Harry M. Barth, Chief Compliance Officer. He reviews Richard’s work through frequent office interactions. Mr. Barth can be contacted by: PHONE: 714-704-6616 or EMAIL: Harry@securawm.com 27 Secura Financial, LLC  Supervised Person Brochure Part 2B of Form ADV Jason Douglas Stone CFP® Secura Financial, LLC 333 City Boulevard West, Suite 2050 Orange, CA 92868-2944 PHONE: 714-704-6616 FAX: 714-704-1513 EMAIL: jason@securawm.com This brochure provides information about Jason D. Stone and supplements Secura Financial, LLC’s brochure. Being registered as a registered investment adviser does not imply a certain level of skill or training. You should have received a copy of that brochure. Please contact Jason D. Stone if you did not receive Secura Financial, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Jason D. Stone (CRD #5455271) is available on the SEC’s website at www.adviserinfo.sec.gov. April 30, 2025 28 Secura Financial, LLC  Brochure Supplement (Part 2B of Form ADV) Additional Investment Advisor Representative Jason Douglas Stone CFP® • Item 2 Educational Background and Business Experience Year of birth: 1982 • Educational Background: California State University, Long Beach; BS in Management, Finance and minor in Economics; 01/2006 • Business Experience: • • • • • • • • • • • • Professional Certifications Secura Financial, LLC; Investment Advisor Representative; 09/2013 – Present Secura Financial, LLC; Member/Managing Director; 11/2019 - Present Arkadios Capital; Registered Representative; 03/2024 - Present Bentley Financial & Insurance Services, Inc.; Insurance Agent; 09/2013 – Present Crown Capital Securities, LP; Registered Representative; 1/2015 – 03/2024 J.W. Cole Advisors, Inc.; Investment Advisor Representative; 01/2014 – 12/2014 J.W. Cole Financial, Inc.; Registered Representative; 08/2013-12/2014 Comprehensive Child Development; Board Member; 10/2012-Present Theta Chi Fraternity Alumni Board; Treasurer; 01/2006-Present Ameriprise; Financial Advisor; 02/2008-08/2013 Pacific Partners Investments; Sales Manager; 06/2006-02/2008 Keller Williams; Realtor; 08/2004-06/2006 T.R.E.O.; Asset Coordinator; 09/2002-08/2004 Employees have earned certifications and credentials that are required to be explained in further detail. ® ™ , CFP and federally registered CFP (with flame The CERTIFIED FINANCIAL PLANNER ® design) marks (collectively, the “CFP marks”) are professional certification marks granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). ® ® certification is a voluntary certification; no federal or state law or regulation The CFP requires financial planners to hold CFP certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical 29 Secura Financial, LLC  ® certification in the United States. requirements that govern professional engagements with clients. Currently, more than 62,000 individuals have obtained CFP ® marks, an individual must satisfactorily fulfill the To attain the right to use the CFP • following requirements: • ® • Standards of Professional Conduct • , a set of ® Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; Examination – Pass the comprehensive CFP Certification Examination. The examination, administered in 10 hours over a two-day period, includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances; Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and Ethics – Agree to be bound by CFP Board’s documents outlining the ethical and practice standards for CFP professionals. ® • Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP marks: Standards of Code of Ethics Continuing Education – Complete 30 hours of continuing education hours every two Professional Conduct years, including two hours on the and other parts of the , to maintain competence and keep up with developments in the Standards of Professional Conduct. • Standards prominently require that CFP ® professionals provide financial professionals financial planning field; and Ethics – Renew an agreement to be bound by the ® The planning services at a fiduciary standard of care. This means CFP must provide financial planning services in the best interests of their clients. ® CFP professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or ® Item 3 Disciplinary Information permanent revocation of their CFP certification. Item 4 Other Business Activities None to report. Jason D. Stone has affiliated businesses as a registered representative and insurance agent. From time to time, he offers clients advice or products from those activities. Clients are not required to purchase any products. He may receive separate, yet typical, compensation in the form of commissions for the sale of insurance and securities products. 30 Secura Financial, LLC  Item 5 Additional Compensation These practices represent conflicts of interest because it gives Mr. Stone an incentive to recommend products based on the commission amount received. This conflict is mitigated by disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the client first. Clients are not required to purchase any products. Clients have the option to purchase these products through another insurance agent, registered representative or investment advisor representative of their choosing. Item 6 Supervision Jason D. Stone receives additional compensation in his capacity as an insurance agent, registered representative and investment advisor representative, but he does not receive any performance based fees. Jason D. Stone is supervised by Richard W. Jackman, Chief Investment Officer. He reviews Jason’s work through frequent office interactions, as well as remote interactions. Richard W. Jackman’s contact information: Phone: 714-704-6616 ext. 102, or by email at: Richard@secruawm.com 31 Secura Financial, LLC 

Wrap Fee Program Brochure (Part 2A Appendix of Form ADV) Private Wealth Management II Program Secura Financial, LLC 333 City Boulevard West, Suite 2050 Orange, CA 92868 714-704-6616 WEBSITE: www.Securawm.com This wrap fee program brochure provides information about the qualifications and business practices of Secura Financial, LLC. Being registered as an investment adviser does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at 714-704-6616. 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 Secura Financial, LLC (CRD #137324) is available on the SEC’s website at www.adviserinfo.sec.gov April 30, 2025 Secura Financial, LLC  Item 2: Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. Material Changes since the Last Update This update is in accordance with the annual filing requirements for Investment Advisors. Since the last update on March 21, 2024, there have been no material changes. i Secura Financial, LLC  Item 3: Table of Contents Form ADV – Part 2A Appendix 1 – Firm Brochure Item 1: Cover Page Item 2: Material Changes ...................................................................................................................... i Annual Update .................................................................................................................................................. i Item 3: Table of Contents .................................................................................................................... ii Material Changes since the Last Update ................................................................................................ i Item 4: Services, Fees and Compensation ..................................................................................... 1 Firm Description ............................................................................................................................................ 1 Program Services ........................................................................................................................................... 1 Item 5: Account Requirements and Types of Clients ................................................................ 3 Program Fees ................................................................................................................................................... 1 Account Minimum ......................................................................................................................................... 3 Item 6: Portfolio Manager Selection and Evaluation ................................................................ 3 Types of Clients ............................................................................................................................................... 3 Portfolio Manager .......................................................................................................................................... 3 Conflicts of Interest ....................................................................................................................................... 4 Advisory Business.......................................................................................................................................... 5 Sharing of Capital Gains ............................................................................................................................... 5 Methods of Analysis, Investment Strategies and Risk of Loss ...................................................... 6 Item 7: Client Information Provided to Portfolio Managers ................................................ 10 Proxy Voting..................................................................................................................................................... 9 Item 8: Client Contact with Portfolio Managers ....................................................................... 10 Description .....................................................................................................................................................10 Item 9: Additional Information ...................................................................................................... 10 Restrictions ....................................................................................................................................................10 Disciplinary Information ...........................................................................................................................10 Other Financial Industry Activities and Affiliations .......................................................................10 Code of Ethics Description .......................................................................................................................11 ii Secura Financial, LLC  Review of Accounts .....................................................................................................................................12 Client Referrals and Other Compensation..........................................................................................12 Financial Information .................................................................................................................................12 iii Secura Financial, LLC  Item 4: Services, Fees and Compensation Firm Description Secura Financial, LLC (“Advisor”) is an investment advisor registered with the California Department of Corporations pursuant to the Investment Advisers Act of 1940. Advisor offers investment advice to clients through the Private Wealth Management II (“Program”) based on the individual needs of the client. Advisor is the sponsor of the Program. Harry M. Barth, Richard W. Jackman, Phillip Napper, Sr., Jason Stone, Brent Honea, and Kraig Strom are advisory representatives of the Advisor and responsible for management of the Program accounts. Program Services This disclosure brochure is limited to describing the Program and other information that client should consider prior to establishing an account in the Program. For a complete description of other programs and services offered by Advisor, clients should refer to Advisor’s Form ADV Part 2A, a copy of which will be provided by Advisor to client upon request. The Program offers clients an asset management account in which the Advisor directs and manages Program assets for client. The Program permits a client to authorize Advisor to purchase and sell on a discretionary basis mutual funds, ETFs, equities, fixed income securities, and managed futures. The Advisor obtains the necessary financial data from the client and assists the client in setting appropriate investment objectives for the Program account. The Advisor obtains updated information from the client as necessary in order to provide personalized investment advice to the client. Program Fees Client will be required to enter into a written agreement with Advisor in order to establish a Program account. Client will also be required to complete an application with the broker/dealer that will act as custodian for Program account assets. The annual investment advisory fee (“Annual Fee”) schedule for the Program is described Equity and Balanced Accounts* below: Market Value of Portfolio Max. Client Fee Max. Quarterly Fee On the first $1,000,000 On the next $1,500,000 2.25% 1.0% 0.5625% 0.25% On next $2,500,000 0.75% 0.1875% On the next $5,000,000 In excess of $10,000,000 0.50% 0.40% 0.125% 0.10% *With a minimum fee of $1,250 per quarter - 1 - Secura Financial, LLC  Fixed Income Accounts** Market Value of Portfolio Max. Client Fee Max. Quarterly Fee On the first $1,000,000 2.25% 0.5625% On the next $1,500,000 0.50% 0.125% On the next $2,500,000 0.40% 0.10% On the next $5,000,000 0.30% 0.075% 0.25% 0.0625% In excess of $10,000,000 **With a minimum fee of $1,250 per quarter Equity and Balanced Accounts with Financial Planning and Consulting*** Market Value of Portfolio Max. Client Fee Max. Quarterly Fee On the first $1,000,000 2.50% 0.625% On the next $1,500,000 1.10% 0.275% On the next $2,500,000 0.85% 0.2125% On the next $5,000,000 0.60% 0.15% 0.50% 0.125% In excess of $10,000,000 ***With a minimum fee of $1,625 per quarter Advisor’s annual investment advisory fee shall include investment advisory services. Should the client be enrolled in the combined investment advisory and financial planning service, financial planning and consulting services are limited to those planning and consulting services offered by Advisor and specifically requested by the client. In the event that the client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of Advisor), Advisor may determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written notice to the client. Fees are billed quarterly in advance based on the amount of assets managed as of the close of business on the last business day of prior quarter. Quarterly advisory fees deducted from the clients' account by the custodian will be reflected in a provided fee invoice as fees are withdrawn. If margin is utilized, the fees will be billed based on the net asset value of the account. Lower fees for comparable services may be available from other sources. For purposes of calculating Annual Fees, the account quarter begins on the first day of the month in which the account is opened. The initial Annual Fee is due at the beginning of the quarter following account opening and includes a prorated fee for the initial quarter in addition to the standard quarterly fee for the upcoming quarter. Subsequent Annual Fee payments are due and assessed at the beginning of each quarter based on the value of the assets under management as of the close of business on the last business day of the preceding quarter as valued by the custodian. Additional deposits and withdrawals will be added or subtracted from account assets, as the case may be, which may lead to an adjustment of the Annual Fee. All Annual Fees are deducted from the account by the custodian unless other - 2 - Secura Financial, LLC  arrangements have been made in writing. The Annual Fee is paid to and retained by the Advisor and the advisory representatives. In addition to the Annual Fee, client may also incur certain charges imposed by third parties in connection with investments made through Program accounts, including those imposed by the custodian. These may include, but are not limited to, the following: mutual fund or money market 12b-1 fees, sub transfer agent fees, omnibus processing fees and networking fees, mutual fund or money market management fees and administrative expenses, mutual fund transaction fees, certain deferred sales charges on previously purchased mutual funds transferred into the account, variable annuity expenses, other transaction charges and service fees, IRA and qualified retirement plan fees, alternative investment administrative fees, administrative servicing fees for trust accounts, creation and development fees or similar fees imposed by unit investment trust sponsors, hedge fund investment management fees, managed futures investor servicing fees, participation fees from auction rate preferred securities, and other charges required by law. Advisor does not receive any portion of these fees. Further information regarding charges and fees assessed by a mutual fund or variable annuity are available in the appropriate prospectus. Margin interest may also apply for Client electing to utilize margin on their account(s). Mutual funds may also charge a redemption fee if a redemption is made within a specific time period following the investment. The terms of any redemption fee are disclosed in the fund’s prospectus. Transactions in mutual fund shares (e.g., for rebalancing, liquidations, deposits or tax harvesting) may be subject to a fund’s frequent trading policy. Client should be aware that margin borrowing involves additional risks. Margin borrowing will result in increased gain if the value of the securities in the account go up, but will result in increased losses if the account value decreases. Item 5: Account Requirements and Types of Clients Account Minimum Types of Clients A minimum account value of $250,000 is required for Program. In certain instances, the minimum account size may be lower. Advisor offers investment advice to individuals, pension and profit sharing plans, trusts, estates, charitable organizations, corporations, and other business entities. Item 6: Portfolio Manager Selection and Evaluation Portfolio Manager Harry M. Barth, Managing Member and Richard W. Jackman, Chief Investment Officer will manage all Program accounts. In general, all individuals that render investment advice on behalf of Advisor are required to have a college degree and/or five (5) years of equivalent industry experience. In addition, all advisory representatives must have obtained all required licenses or a professional designation. - 3 - Secura Financial, LLC  Conflicts of Interest Each individual will be reviewed and considered on a case-by-case basis by an executive member of Advisor. Advisor requires that individuals have high standards or morals and ethics and be committed to providing quality investment advice. Additionally, advisory representatives will be required to obtain any required regulatory examinations. In establishing a Program account, client elects to appoint a broker/dealer with whom the Adviser has a custodial relationship with to processing securities transactions for the Program account. The Advisor does not maintain custody of client assets. Securities transactions for Program account are effected without commissions being charged to client. While Advisor makes every attempt to obtain the best execution possible, there is no assurance that it will be obtained. Clients should consider whether or not the appointment of the broker/dealer and custodian may or may not result in certain costs or disadvantages to the client as a result of possibly less favorable executions. In considering whether or not to restrict the execution of transactions through a broker/dealer, Advisor considered the capabilities of said broker/dealer. Although client will not be charged a transaction charge for transactions through the broker/dealer, client should be aware that Advisor will be required to pay transaction charges to the broker/dealer. The transaction charges borne by Advisor vary based on the type of transactions (e.g., mutual fund, equity or fixed income security) and for mutual funds based on whether or not the mutual fund pays 12b-1 fees and/or sub transfer agent fees that are retained by the custodian in amounts sufficient to cover the majority of trading costs. Client should understand that the cost to Advisor of transaction charges may be a factor the Advisor considers when deciding which securities to select and whether or not to place transactions in a Program account. No agency-cross transactions or principal transactions are effected by Advisor in Program accounts. Advisor may aggregate transactions for a client with other clients to improve the quality of execution. When transactions are so aggregated, the actual prices applicable to the aggregated transactions will be averaged, and the client will be deemed to have purchased or sold its proportionate share of the securities involved at the average price obtained. Advisor may receive support services and/or products from the broker/dealer, which assist the Advisor to better monitor and service Program accounts maintained at said broker/dealer. These support services and/or products may be received without cost, at a discount, and/or at another negotiated rate, and may include investment-related research, pricing information and market data, software and other technology that provide access to client account data, compliance and/or practice management-related publications, consulting services, attendance at conferences, meetings, and other educational and/or social events, marketing support, computer hardware and/or software and/or other products used by Advisor in furtherance of its investment advisory business operations. Clients do not pay more for services as a result of this arrangement. There is no corresponding commitment made by the Advisor to the custodial broker/dealer or any other entity to invest any specific amount or percentage of client assets in any specific securities as a result of the arrangement. - 4 - Secura Financial, LLC  Advisor and advisory representatives may receive additional non-cash compensation from product sponsors. Compensation may include such items as gifts valued at less than $100 annually, an occasional dinner or ticket to a sporting event, or reimbursement in connection with educational meetings or marketing or advertising initiatives. The Program may cost the client more or less than purchasing Program services separately. Factors that bear upon the cost of the Program account in relation to the cost of the same services purchased separately include: the type and size of the account, the historical and/or expected size or number of trades for the account, and the number and range of supplementary advisory and client related services provided to the account. The Annual Fee is an ongoing fee for investment advisory services and may cost the client more than if the assets were held in a traditional brokerage account. In a brokerage account, a client is charged a commission for each transaction and the representative has no duty to provide ongoing advice with respect to the account. If the client plans to follow a buy and hold strategy for the account or does not wish to purchase ongoing investment advice or management services, the client should consider opening a brokerage account rather than a Program account. The Advisor receives compensation as a result of the client’s participation in the Program. The amount of this compensation may be more or less than what the Advisor would receive if the client participated in other programs or paid separately for investment advice, brokerage and other client services. Therefore, the Advisor may have a financial incentive to recommend the Program account over other programs and services. Advisory representatives have a relationship with Arkadios Capital, member FINRA/SIPC. In such capacity, they may offer securities and receive normal and customary commissions as a result of securities transactions outside of Program account. Advisory Business Advisory representatives also have a relationship with various insurance companies. Some of the Advisory representatives are also licensed insurance agents/brokers and if applicable, is disclosed in their ADV Part 2B supplement brochure. In such capacity, they may receive normal and customary commissions as a result of insurance sales outside of Program account. The Advisor offers clients an asset management account through the Program in which the Advisor directs and manages Program assets for client. Sharing of Capital Gains The goals and objectives for each client are documented in our client files. Investment strategies are created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Fees are not based on a share of the capital gains or capital appreciation of managed securities. Advisor 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. - 5 - Secura Financial, LLC  Methods of Analysis, Investment Strategies and Risk of Loss OUR APPROACH TO PORTFOLIO MANAGEMENT We employ Modern Portfolio management techniques which are concerned with investment analysis, portfolio design, and performance evaluation. These methods express quantitatively our views regarding risk and its relationship to investment return. They focus attention on the overall composition of the portfolio rather than the traditional method of analyzing and evaluating the individual components. As your adviser, we are therefore able to examine and design portfolios predicated on explicit risk-reward parameters and on the identification and quantification of portfolio objectives. Simply stated, asset allocation is the process of selecting a mix of asset classes and the efficient allocation of capital to those assets by matching rates of return to a specified and quantifiable tolerance for risk. Risk tolerance is essentially the percentage of an investment portfolio that an investor is willing to risk to achieve a specific rate of return. It is no longer a one- dimensional process of selecting the right stock, bond or property to place in a portfolio. Modern portfolio theory methods have as their foundation four basic premises. First, those investors are inherently risk-averse. Investors are not willing to accept risk except where the level of returns generated will fairly compensate for that risk. It is probably reasonable to assume that investors are more concerned with risk than they are with rewards. The problem in the past has been to quantify risk and its relation to return. The second premise to modern portfolio theory is that the markets are basically efficient. As discussed above, most studies support this concept. With the advance in information technology and more sophisticated investors, the markets are likely to become even more efficient. The third premise is that the focus of attention should be shifted away from individual securities analysis to consideration of portfolios as a whole predicated on explicit risk-reward parameters and on the identification and quantification of portfolio objectives. Today it is more likely that the efficient allocation of capital to specific asset classes will be far more important than selecting the "right" components of that asset class. Studies have dramatically supported the concept that asset allocation is the primary determinant of portfolio performance, with market timing and security selection playing minor roles. The fourth premise for modern portfolio theory is the optimality of portfolio returns. In other words, for any level of risk that one is willing to accept, there is a rate of return that should be achieved. Quantitative methods are used for measuring risk and diversification, making it possible to create efficient and theoretically optimal portfolios. Portfolio diversification is not so much a function of how many issues are involved, as it is of the relationships of each asset to each other asset and the proportionality of those assets in the portfolio. In other words, investors should search for those assets which tend to have negative relationships to each other and should include assets which go up in value as the value of other assets declines. The number of assets in the portfolio is less important than the relationship of those assets. Therefore having many assets in a portfolio will not reduce the systematic risk in the portfolio as much as having negatively correlated assets. Further, it is a misconception, albeit a widely held one, that investors must accept higher levels of risk to achieve higher returns. By using asset allocation methodologies, investors may achieve higher returns with less risk. - 6 - Secura Financial, LLC  STRATEGIC ASSET ALLOCATION The process of asset allocation may include one or all of the following approaches: - uses historical data (mean rates of return, standard deviations and covariances) in an attempt to understand how the asset has performed and is likely to perform over long periods of time. The goal is not to "beat" the market, but to TACTICAL ASSET ALLOCATION establish a long-term investment strategy using a core mix of assets. - uses periodic assumptions regarding the performance and characteristics of the assets and/or the economy. This approach attempts to improve portfolio performance by making "mid-course" changes in the long-term strategy based on near-term DYNAMIC ASSET ALLOCATION expectations. - involves changes in investor circumstances, which may lead to the modification of policies, objectives and/or risk tolerances. Resulting changes are intended to maintain equilibrium between the investor's policies and objectives and the asset allocation process. The economic environment and investment alternatives today are substantially different from those of the past. We believe that investors can no longer be myopic in their view of investments in so far as they restrict their analysis to domestic markets or investment vehicles. The traditionally domestic portfolio is clearly inadequate in today's internationally based economic and investment environment. Further, the complexity and volatility of today's investment world requires access to, and proficiency with superior analytical tools and data bases. We fully recognize that developing successful investment strategies and competing for investment capital depends on our ability to employ the most sophisticated analytical techniques. Successful investors require the development of long-term plans arrived at in an objective and dispassionate manner. Too often, investment decisions are based on isolated, short-term considerations, without regard to the portfolio or the inter-relationships of the assets used. Our approach to money management ignores the narrow approach of attempting to beat the performance of individual markets and applies a much broader method of devising strategies which will achieve investor's long-term policies and objectives within specified risk parameters. If 90% of future portfolio performance is determined by asset allocation policies, then it should be at the asset allocation and investment policy level that investors address issues of risk and return. To provide the services that our clients require today, we utilize integrated investment systems which include all of the computer models and ancillary services required to develop and manage your portfolio in a sophisticated asset allocation program. SECURITY SPECIFIC INFORMATION Certain mutual funds available in the Program invest primarily in alternative investments and/or alternative strategies. Investing in alternative investments and/or alternative strategies may not be suitable for all investors and involves special risks, such as risks associated with commodities, leverage, selling securities short, use of derivatives, potential adverse market forces, regulatory changes and potential liquidity. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. - 7 - Secura Financial, LLC  Exchange Traded Funds (ETFs) may be purchased in the Program. ETFs are typically investment companies that are legally classified as open end mutual funds or a unit investment trusts. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly-traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity, and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities are not registered as an investment company under the Investment Company Act of 1940. Exchange Traded Notes (ETNs) also may be purchased in the Program. An ETN is a senior unsecured debt obligation designed to track the total return of an underlying market index or other benchmark. ETNs may be linked to a variety of assets, for example, commodity futures, foreign currency and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the prevailing market price. The risks associated with a particular ETN are set forth in the prospectus for the ETN. Some of the more common risks of an ETN are as follows. The repayment of the principal, interest (if any), and the payment of any returns at maturity or upon redemption are dependent upon the issuer’s ability to pay. In addition, the trading price of the ETN in the secondary market may be adversely impacted if the issuer’s credit rating is downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated in a specific sector, asset class or country and may therefore carry specific risks. Leveraged ETFs, ETNs and mutual funds, sometimes labeled “ultra” or “2x” for example, are designed to provide a multiple of the underlying index's return, typically on a daily basis. Inverse products are designed to provide the opposite of the return of the underlying index, typically on a daily basis. These products are different from and can be riskier than traditional ETFs, ETNs and mutual funds. Although these products are designed to provide returns that generally correspond to the underlying index, they may not be able to exactly replicate the performance of the index because of fund expenses and other factors. This is referred to as tracking error. Continual re-setting of returns within the product may add to the underlying costs and increase the tracking error. As a result, this may prevent these products from achieving their investment objective. In addition, compounding of the returns can produce a divergence from the underlying index over time, in particular for leveraged products. In highly volatile markets with large positive and negative swings, return distortions are magnified over time. Because of these distortions, these products should be actively monitored, as frequently as daily, and are generally not appropriate as an intermediate or long-term holding. To accomplish their objectives, these products use a range of strategies, including swaps, futures contracts and other derivatives. These products may not be diversified and can be based on commodities or currencies. These products may have higher expense ratios and be less tax-efficient than more traditional ETFs, ETNs and mutual funds. Structured products are available for purchase in the Program. Structured products are securities derived from another asset, such as a security or a basket of securities, an index, a - 8 - Secura Financial, LLC  commodity, a debt issuance, or a foreign currency. Structured products frequently limit the upside participation in the reference asset. Structured products are senior unsecured debt of the issuing bank and subject to the credit risk associated with that issuer. This credit risk exists whether or not the investment held in the account offers principal protection. The credit worthiness of the issuer does not affect or enhance the likely performance of the investment other than the ability of the issuer to meet its obligations. Any payments due at maturity are dependent on the issuer’s ability to pay. In addition, the trading price of the security in the secondary market, if there is one, may be adversely impacted if the issuer’s credit rating is downgraded. Investing in structured products involves risks. Some structured products offer full protection of the principal invested, others offer only partial or no protection. A client in a structured product never has a claim on the underlying investment, whether a security, zero coupon bond, or option. Any principal protection that is offered is subject to the credit worthiness of the issuer. Clients may be sacrificing a higher yield to obtain the principal guarantee. In addition, the principal guarantee relates to nominal principal and does not offer inflation protection. There may be little or no secondary market for the securities and information regarding independent market pricing for the securities may be limited. This is true even if the product has a ticker symbol or has been approved for listing on an exchange. Tax treatment of structured products may be different from other investments held in the account (e.g., income may be taxed as ordinary income even though payment is not received until maturity). Structured CDs that are insured by the FDIC will be subject to applicable FDIC limits. Hedge funds are available for purchase in the Program by clients meeting certain qualification standards. Investing in hedge funds involves additional risks including, but not limited to, the risk of investment loss due to the use of leveraging and other speculative investment practices and the lack of liquidity. In addition, hedge funds are not required to provide periodic pricing or valuation information to investors and may involve complex tax structures and delays in distributing important tax information. Clients should be aware that hedge funds are not liquid as there is no secondary trading market available. At the absolute discretion of the issuer of the hedge fund, there may be certain repurchase offers made from time to time. However, there is no guarantee that client will be able to redeem the hedge fund during the repurchase offer. Managed futures are available for purchase in the Program by clients meeting certain qualification standards. Investing in managed futures involves additional risks including, but not limited to, the risk of investment loss due to the use of leveraging and other speculative investment practices, the lack of liquidity and performance volatility. Clients should be aware that managed futures are not liquid as there is no secondary trading market available. At the absolute discretion of the issuer of the managed futures fund, there may be certain repurchase offers made from time to time. However, there is no guarantee that client will be able to redeem the managed futures during the repurchase offer. Proxy Voting Advisor does not vote proxies on securities. Clients are expected to vote their own proxies. The client will receive their proxies directly from the custodian of their account or from a transfer agent. - 9 - Secura Financial, LLC  When assistance on voting proxies is requested, Advisor will provide recommendations to the client. If a conflict of interest exists, it will be disclosed to the client Item 7: Client Information Provided to Portfolio Managers Description The Advisor obtains the necessary financial data from the client and assists the client in setting appropriate investment objectives for the Program account. The Advisor obtains updated information from the client as necessary in order to provide personalized investment advice to the client. Client will be required to enter into a written agreement with Advisor in order to establish a Program account. Client will also be required to complete an application with the broker/dealer that will act as custodian for Program account assets. Item 8: Client Contact with Portfolio Managers Restrictions There are no restrictions placed on clients’ ability to contact and consult with the portfolio managers. Item 9: Additional Information Disciplinary Information Criminal or Civil Actions Advisor and its management have not been involved in any criminal or civil action. Administrative Enforcement Proceedings Advisor and its management have not been involved in administrative enforcement proceedings. Self Regulatory Organization Enforcement Proceedings Advisor and its management have not been involved in legal or disciplinary events related to past or present investment clients. Broker-Dealer or Representative Registration Neither Advisor nor any of its employees are affiliated with a broker-dealer. Futures or Commodity Registration Other Financial Industry Activities and Affiliations Neither Advisor nor its employees are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor. Material Relationships Maintained by this Advisory Business and Conflicts of Interest Advisory representatives have a relationship with Arkadios Capital. In such capacity, they may offer securities and receive normal and customary commissions as a result of securities transactions outside of Program account. Advisory representatives have a relationship with various insurance companies. Some of Advisor’s advisory representatives are licensed insurance agents/brokers. In such capacity, - 10 - Secura Financial, LLC  they may receive normal and customary commissions as a result of insurance sales outside of Program account. These practices represent potential conflicts of interest because it gives an incentive to recommend products and services based on the commission/fee amount received. This conflict is mitigated by disclosures, procedures, and the firm’s fiduciary obligation and clients are not required to purchase any products or services. Clients have the option to insurance agent, attorney or registered purchase these products through another representative of their choosing. Recommendations or Selections of Other Investment Advisors and Conflicts of Interest Code of Ethics Description Advisor may at times utilize the services of Third Party Money Managers to manage client accounts. In such circumstances, Advisor will share in the Third Party asset management fee. This situation creates a conflict of interest. However, when referring clients to a third party money manager, the client’s best interest will be the main determining factor of These fees do not include brokerage fees that may be assessed by the custodial Advisor. broker dealer. Fees for these services will be based on a percentage of assets under management not to exceed any limit imposed by any regulatory agency. The final fee schedule will be attached to Exhibit D in Advisor's Investment Advisory Agreement. The employees of Advisor have committed to a Code of Ethics. The purpose of our Code of Ethics is to ensure that when employees buy or sell securities for their personal account, they do not create actual or potential conflict with our clients. We do not allow any employees to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our clients. The firm will provide a copy of the Code of Ethics to any client or prospective client upon request. Investment Recommendations Involving a Material Financial Interest and Conflict of Interest Advisor and its employees do not recommend to clients, securities in which we have a material financial interest. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest Advisor and its employees may buy or sell securities that are also held by clients. In order to avoid potential conflicts of interest such as front running of client trades, employees are required to disclose all reportable securities transactions as well as provide Advisor with copies of their brokerage statements. The Chief Compliance Officer of Advisor is Harry M. Barth. He reviews all employee trades each quarter. The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the firm receive preferential treatment. Since most employee trades are in products such as mutual funds, government securities, bonds or are small in size, they do not impact the securities markets. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest Advisor does not maintain a firm proprietary trading account and does not have a material financial interest in any securities being recommended and therefore no conflicts of interest exist. - 11 - Secura Financial, LLC  Review of Accounts Client Referrals and Other Compensation Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Account reviews are performed monthly or quarterly depending on the nature of the account and client relationship. All reviews are conducted by Harry M. Barth, Chief Compliance Officer and Richard W. Jackman, CFP, MSFS on a portfolio analysis basis. Account reviews are performed more frequently when market conditions dictate. Financial Plans are considered complete when recommendations are delivered to the client and a review is done only upon request of client. Review of Client Accounts on Non-Periodic Basis Other conditions that may trigger a review of clients accounts are changes in the tax laws, new investment information, and changes in a client's own situation. Content of Client Provided Reports and Frequency Clients receive account statements usually on a monthly basis, but no less than quarterly for managed accounts. Account performance reports are issued on a quarterly basis. Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest Advisor does not receive any economic benefits from external sources. Advisory Firm Payments for Client Referrals Advisor does compensate for employees and outside solicitors for client referrals. The fees charged to the clients are not increased because of the referral fees paid. Financial Information Advisor may enter into solicitor relationships. These individual solicitors refer clients to Advisor for services. Advisor pays a referral fee to the solicitor based on its advisory fee and written agreement. Solicitors will also be appropriately registered under federal and state securities laws where applicable. Client receives all related agreements and disclosures prior to or at the time of entering into an Investment Advisory Agreement. Balance Sheet A balance sheet is not required to be provided because Advisor does not serve as a custodian for client funds or securities and Advisor does not require prepayment of fees of more than $1200 per client and six months or more in advance. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients Advisor has no condition that is reasonably likely to impair our ability to meet contractual commitments to our clients. Bankruptcy Petitions during the Past Ten Years Neither Advisor nor its management has had any bankruptcy petitions in the last ten years. - 12 - Secura Financial, LLC