STENGER FAMILY OFFICE, LLC

Disclosure Brochure Disclosure Brochure August 11, 2025 STENGER FAMILY OFFICE, LLC a Registered Investment Adviser Naperville Financial Center 400 East Diehl Road, Suite 550 Naperville, IL 60563 (630) 912-8295 www.stengerfamilyoffice.com  Disclosure Brochure This brochure provides information about the qualifications and business practices of Stenger Family Office, LLC (hereinafter “SFO” or the “Firm”). If you have any questions about the contents of this brochure, please contact the Firm at the telephone number listed above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Additional information about the Firm is available on the SEC’s website at www.adviserinfo.sec.gov. The Firm is a registered investment adviser. Registration does not imply any level of skill or training. Item 2. Material Changes In this Item, SFO is required to discuss any material changes that have been made to the brochure since the last annual amendment. • The firm has updated its Financial Plannings Fees. (Item 5) • The firm has a new Chief Compliance Officer, Julia Huebner. • The firm has updated its assets under management. (Item 4)  Disclosure Brochure Item 3. Table of Contents Item 2. Material Changes ........................................................................................................................................ 2 Item 3. Table of Contents ........................................................................................................................................ 3 Item 4. Advisory Business ....................................................................................................................................... 4 Item 5. Fees and Compensation............................................................................................................................... 7 Item 6. Performance-Based Fees and Side-by-Side Management ......................................................................... 10 Item 7. Types of Clients ......................................................................................................................................... 10 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss .................................................................. 10 Item 9. Disciplinary Information ........................................................................................................................... 15 Item 10. Other Financial Industry Activities and Affiliations................................................................................ 15 Item 11. Code of Ethics ......................................................................................................................................... 16 Item 12. Brokerage Practices ................................................................................................................................. 17 Item 13. Review of Accounts ................................................................................................................................ 20 Item 14. Client Referrals and Other Compensation ............................................................................................... 21 Item 15. Custody ................................................................................................................................................... 21 Item 16. Investment Discretion ............................................................................................................................. 22 Item 17. Voting Client Securities ........................................................................................................................... 22 Item 18. Financial Information .............................................................................................................................. 23  Disclosure Brochure Item 4. Advisory Business SFO offers a variety of advisory services, which include financial planning, consulting, subscription and investment management services. Prior to SFO rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with SFO setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). SFO filed for registration as an investment adviser in January 2023 and is owned by Nicholas D. Stenger and Darin Bond Roth. As of August 2025, SFO had $521,480,800 assets under management, of which $520,022,662 were managed on a discretionary basis, and $1,458,138 was managed on a non- discretionary basis. While this brochure generally describes the business of SFO, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or other persons who provide investment advice on SFO’s behalf and are subject to the Firm’s supervision or control. Financial Planning and Consulting Services SFO offers clients a broad range of financial planning and consulting services, which include any or all of the following functions: • • Cash Flow Forecasting Retirement Planning • • Trust and Estate Planning Tax Planning • • Insurance Planning Education Planning While each of these services is available on a stand-alone basis, certain of them can also be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below). In performing these services, SFO is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. SFO recommends certain clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents or an affiliated investment agency, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage SFO or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by SFO under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising SFO’s recommendations and/or services.  Disclosure Brochure Stenger+ Stenger+ is a subscription service that allows subscribers to access the Firm’s premium shows, podcasts, articles and webinars. Stenger+ does not include any individualized investment advice. The subscription cost is $5 per month and is included in the investment management and wealth management services described below for any client with $1,000 or more in a managed account. Investment and Wealth Management Services SFO provides clients with wealth management services which include a broad range of financial planning and consulting services as well as discretionary and/or non-discretionary management of investment portfolios. They type of services (including investment management only, wealth management, and family office services) will depend on the client’s needs as well as the assets under management. SFO primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, and independent investment managers (“Independent Managers”) in accordance with their stated investment objectives. Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, but clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage SFO to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, SFO directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. SFO tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. SFO consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify SFO if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if SFO determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. The Firm currently has the following offerings:  Disclosure Brochure Stenger Wealth Management Wealth management clients have unlimited access to an SFO investment adviser representative who will create a comprehensive, custom financial plan and deliver detailed financial coaching to the client and their family. The investment adviser representative will proactively host an annual review meeting each year and a series of additional check-in calls as needed. Fees start at 1.25% per year. Stenger Family Office For clients with $2 million investable assets or more, SFO combines our wealth management offering with tax planning and preparation and estate planning services. SFO clients have dedicated, unlimited access to a senior level investment adviser representative. Clients also have access to accountants and estate planning attorneys. SFO Family Office clients receive an annual engagement bonus of $650 towards the cost of tax preparation services and $500 towards the cost of estate planning services offered through Legacy & Life Law Firm. In addition to the annual review and mid-year check in process, Family Office clients will receive an estate plan review with a team of estate planning attorneys. Stenger Investment Management Clients that do not require a full-service relationship with an investment adviser representative can access our proprietary, custom investment portfolios. Portfolios can be customized to meet certain objectives or invested in a model portfolio managed by the SFO Investment Committee. Stenger Investment Management employs the use of tax loss harvesting and because accounts are highly customized, typically do not issue costly capital gains distributions, a common issue with mutual funds and ETFs. Proxy voting is maintained by the SFO Investment Committee. Investment Management clients also have access to tax planning, estate planning and insurance services for an additional fee. Stenger GoldDesk Investors with less than $100,000 who would like to start a full-service financial planning and investment relationship with an investment adviser representative can access all the resources of SFO with a low minimum account size of $1,000. Stenger GoldDesk clients have access to an investment adviser representative and will receive a fully customized and comprehensive financial plan, reviewed once per year. GoldDesk clients also have access to tax planning, estate planning and insurance services for an additional fee. Use of Independent Managers As mentioned above, SFO selects certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager are set forth in a separate written agreement with the designated Independent Manager. That agreement can be between the Firm and the Independent Manager (often called a subadvisor) or the client and the Independent Manager (sometimes called a separate account manager). In addition to this brochure,  Disclosure Brochure clients will typically also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. SFO evaluates a variety of information about Independent Managers, which includes the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. SFO also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. SFO continues to provide services relative to the discretionary or non-discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. SFO seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Item 5. Fees and Compensation SFO offers services on a fee basis, which includes fixed fees, as well as fees based upon assets under management or advisement. Additionally, certain of the Firm’s Supervised Persons, in their individual capacities, offer insurance products under a separate commission-based arrangement. Financial Planning and Consulting Fees SFO charges a fixed fee for providing financial planning and consulting services under a stand-alone engagement. These fees are negotiable and can be up to $5,000 for a financial plan or $500 hourly depending upon the scope and complexity of the services and the professional rendering the financial planning and/or the consulting services. If the client engages the Firm for additional investment advisory services, SFO can offset all or a portion of its fees for those services based upon the amount paid for the financial planning and/or consulting services. The terms and conditions of the financial planning and/or consulting engagement are set forth in the Advisory Agreement. For project-based services SFO requires one-half of the fee (estimated hourly or fixed) payable upon execution of the Advisory Agreement. The outstanding balance is due upon delivery of the financial plan or completion of the agreed upon services. The Firm does not, however, take receipt of $1,200 or more in prepaid fees, six or more months in advance of services rendered. The Firm also provides subscription-based services for its content. The Firm will charge an ongoing fixed fee for subscriptions. The terms of the fees will be disclosed in the agreement with the subscriber.  Disclosure Brochure Investment Management Fees SFO offers investment management services for an annual fee based on the amount of assets under the Firm’s management. This management fee varies between 35 and 125 basis points (0.35% – 1.25%), depending upon the size and composition of a client’s portfolio, the type and amount of services rendered and the individual(s) providing the services. The fee is partially determined by the level of services provided. Those levels can include investment management only, wealth management, and family office services. Depending on the amount of assets under management with the Firm, the investment management fees can also include the Stenger+ services as well as an allowance for tax preparation and/or estate planning done through the Firm or a third-party Firm with which the Firm has a relationship. The annual fee is prorated and charged monthly, in arrears, based upon the market value of the average daily account balance as determined by a party independent from the Firm (including the client’s custodian or another third-party). The Firm includes cash in a client’s account in determining the valuation for billing purposes. The Firm may, in its sole discretion, not include cash in determining the fee, especially where a client has a high percentage of cash for reasons other than the Firm's investment management decision. Since the asset-based fee is determined by average daily account balance, if assets are deposited into or withdrawn from an account after the inception of a month, the base fee payable with respect to such assets is adjusted accordingly. In the event the advisory agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination and the outstanding or unearned portion of the fee is charged or refunded to the client, as appropriate. Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g., held-away assets, accommodation accounts, alternative investments, etc.), SFO can negotiate a fee rate that differs from the range set forth above. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage SFO for additional services for compensation, including rolling over retirement accounts or moving other assets to the Firm’s management. Clients retain absolute discretion over all decisions regarding engaging the Firm and are under no obligation to act upon any of the recommendations. Fee Discretion SFO may, in its sole discretion, negotiate to charge a lesser fee based upon certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing/legacy client relationship, account retention, pro bono activities, or competitive purposes.  Disclosure Brochure Additional Fees and Expenses In addition to the advisory fees paid to SFO, clients also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions (collectively “Financial Institutions”). These additional charges include securities brokerage commissions, transaction fees, custodial fees, fees charged by the Independent Managers, margin and other borrowing costs, charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. The Firm’s brokerage practices are described at length in Item 12, below. Schwab does not charge commissions on many types of transactions. Direct Fee Debit Clients provide SFO and/or certain Independent Managers with the authority to directly debit their accounts for payment of the investment advisory fees. The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to SFO. Use of Margin SFO can recommend that certain clients utilize margin in the client’s investment portfolio or other borrowing. SFO only recommends such borrowing for non-investment needs, such as bridge loans and other financing needs. The Firm’s fees are determined based upon the value of the assets being managed gross of any margin or borrowing. Account Additions and Withdrawals Clients can make additions to and withdrawals from their account at any time, subject to SFO’s right to terminate an account. Additions can be in cash or securities provided that the Firm reserves the right to liquidate any transferred securities or declines to accept particular securities into a client’s account. Clients can withdraw account assets on notice to SFO, subject to the usual and customary securities settlement procedures. However, the Firm designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. SFO may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, short-term redemption  Disclosure Brochure fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications. Item 6. Performance-Based Fees and Side-by-Side Management SFO does not provide any services for a performance-based fee (i.e., a fee based on a share of capital gains or capital appreciation of a client’s assets). Item 7. Types of Clients SFO offers services to individuals, trusts, estates, charitable organizations, corporations and other business entities. SFO does not impose a stated minimum fee or minimum portfolio value for starting and maintaining an investment management relationship. The Firm does, however, have minimum investments in certain of its portfolios or services (as described above). Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies Equities SFO employs a comprehensive due diligence process meeting with over 25 third party asset managers each year starting with a macro economic outlook to gain a view on the future path of interest rates. SFO employs factor analysis to determine if clients should overweight towards value or growth, depending on the current interest rate environment. SFO primarily allocates towards U.S. based companies in the large or mid cap space, but will sometimes buy small cap stocks if appropriate. SFO rebalances portfolios at least annually, and up to four times in some years if market conditions warrant. On a security level, SFO engages in fundamental analysis of securities analyzing their earnings and growth prospects.  Disclosure Brochure Equity portfolios: The following are examples of the Firm’s model portfolios. Clients can be invested in one or more of the models and each client portfolio may differ depending on when they added assets as well as any restrictions requested by the client. A) Stenger Resilient America • 30-50 U.S. based large cap stocks • Balanced growth vs. value factors • Usually titled slightly to growth stocks • Benchmarked to S&P 500 Index B) Stenger Strategic Value • 30-50 U.S. based large and mid cap stocks • Overweighted towards dividend paying companies • Benchmarked to S&P 500 Index C) Stenger High Dividend Yield • 30-50 U.S. based large • Overweighted towards high dividend yield companies with strong fundamentals • Benchmarked to S&P 500 Index Fixed Income SFO’ fixed income allocation is derived from a client’s financial plan and upcoming cash needs. The Firm overweights towards high quality, short term U.S. Treasuries with a goal of delivering stability in client portfolios. The following are examples of the Firm’s model portfolios. Clients can be invested in one or more of the models and each client portfolio may differ depending on when they added assets as well as any restrictions requested by the client. A) Core Bond Portfolio • High quality, U.S. based bond portfolio • 5-7 year duration B) Short Term Portfolio • Short term treasuries, U.S. based • 1-3 year duration  Disclosure Brochure Exchange Traded Funds – Asset Allocation Models SFO manages and creates custom and model portfolios for clients derived from risk tolerance and general financial planning. The ETF portfolios consist of equity and fixed income based products and are rebalanced annually or bi-annually. The following are examples of the Firm’s model portfolios. Clients can be invested in one or more of the models and each client portfolio may differ depending on when they added assets as well as any restrictions requested by the client. • Ultra Aggressive – 100% stock • Aggressive – 80-90% stock, 10-20% bonds • Moderate – 70% stock, 30% bonds • Conservative – 50% stock, 50% bonds • Ultra conservative – 30% stock, 70% bonds Risk of Loss The following list of risk factors does not purport to be a complete enumeration or explanation of the risks involved with respect to the Firm’s investment management activities. Clients should consult with their legal, tax, and other advisors before engaging the Firm to provide investment management services on their behalf. Market Risks Investing involves risk, including the potential loss of principal, and all investors should be guided accordingly. The profitability of a significant portion of SFO’s recommendations and/or investment decisions may depend to a great extent upon correctly assessing the future course of price movements of stocks, bonds and other asset classes. In addition, investments may be adversely affected by financial markets and economic conditions throughout the world. There can be no assurance that SFO will be able to predict these price movements accurately or capitalize on any such assumptions. Volatility Risks The prices and values of investments can be highly volatile, and are influenced by, among other things, interest rates, general economic conditions, the condition of the financial markets, the financial condition of the issuers of such assets, changing supply and demand relationships, and programs and policies of governments.  Disclosure Brochure Cash Management Risks The Firm may invest some of a client’s assets temporarily in money market funds or other similar types of investments, during which time an advisory account may be prevented from achieving its investment objective. Equity-Related Securities and Instruments The Firm may take long positions in common stocks of U.S. and non-U.S. issuers traded on national securities exchanges and over-the-counter markets. The value of equity securities varies in response to many factors. These factors include, without limitation, factors specific to an issuer and factors specific to the industry in which the issuer participates. Individual companies may report poor results or be negatively affected by industry and/or economic trends and developments, and the stock prices of such companies may suffer a decline in response. In addition, equity securities are subject to stock risk, which is the risk that stock prices historically rise and fall in periodic cycles. U.S. and non-U.S. stock markets have experienced periods of substantial price volatility in the past and may do so again in the future. In addition, investments in small-capitalization, midcapitalization and financially distressed companies may be subject to more abrupt or erratic price movements and may lack sufficient market liquidity, and these issuers often face greater business risks. Fixed Income Securities While the Firm emphasizes risk-averse management and capital preservation in its fixed-income bond portfolios, clients who invest in this product can lose money, including losing a portion of their original investment. The prices of the securities in our portfolios fluctuate. The Firm does not guarantee any particular level of performance. Below is a representative list of the types of risks clients should consider before investing in this product. • Interest rate risk. Prices of bonds tend to move in the opposite direction to interest rate changes. Typically, a rise in interest rates will negatively affect bond prices. The longer the duration and average maturity of a portfolio, the greater the likely reaction to interest rate moves. • Credit (or default) risk. A bond’s price will generally fall if the issuer fails to make a scheduled interest or principal payment, if the credit rating of the security is downgraded, or if the perceived creditworthiness of the issuer deteriorates. • Liquidity risk. Sectors of the bond market can experience a sudden downturn in trading activity. When there is little or no trading activity in a security, it can be difficult to sell the security at or near its perceived value. In such a market, bond prices may fall. • Call risk. Some bonds give the issuer the option to call or redeem the bond before the maturity date. If an issuer calls a bond when interest rates are declining, the proceeds may have to be reinvested at a lower yield. During periods of market illiquidity or rising rates, prices of callable securities may be subject to increased volatility.  Disclosure Brochure • Prepayment risk. When interest rates fall, the principal of mortgage-backed securities may be prepaid. These prepayments can reduce the portfolio’s yield because proceeds may have to be reinvested at a lower yield. • Extension risk. When interest rates rise or there is a lack of refinancing opportunities, prepayments of mortgage-backed securities or callable bonds may be less than expected. This would lengthen the portfolio’s duration and average maturity and increase its sensitivity to rising rates and its potential for price declines. Mutual Funds and ETFs An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual fund’s shares may differ from the NAV during periods of market volatility, which may, among other factors, lead to the mutual fund’s shares trading at a premium or discount to actual NAV. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for index-based ETFs and potentially more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. Finally, some mutual funds and ETFs may have lock-up periods that restrict an investor from selling their position for a period of time. Other mutual funds and ETFs could also have early redemption fees that are taken if the investor sells their position before a certain amount of time. Use of Independent Managers As stated above, SFO selects certain Independent Managers to manage a portion of its clients’ assets. In these situations, SFO continues to conduct ongoing due diligence of such managers, but such recommendations rely to a great extent on the Independent Managers’ ability to successfully implement  Disclosure Brochure their investment strategies. In addition, SFO does not have the ability to supervise the Independent Managers on a day-to-day basis. Interest Rate Risks Interest rates may fluctuate significantly, causing price volatility with respect to securities or instruments held by clients. Item 9. Disciplinary Information SFO has not been involved in any legal or disciplinary events that are material to a client’s evaluation of its advisory business or the integrity of its management. Item 10. Other Financial Industry Activities and Affiliations This item requires investment advisers to disclose certain financial industry activities and affiliations. Licensed Insurance Agents A number of the Firm’s Supervised Persons are licensed insurance agents and offer certain insurance products on a fully-disclosed commissionable basis. This can be done through an affiliated agency of the Firm. A conflict of interest exists to the extent that SFO recommends the purchase of insurance products where its Supervised Persons and/or an affiliate of the Firm are entitled to insurance commissions or other additional compensation. The Firm has procedures in place whereby it seeks to ensure that all recommendations are made in its clients’ best interest regardless of any such affiliations. Related Certified Public Accounting Firm SFO does not render accounting services to clients. In the event a client requires accounting services, the Firm will generally recommend the services of the certified public accounting firm of Stenger Tax Advisory LLC (“STA”). These services are rendered independent of SFO and pursuant to a separate agreement between the client and the accounting firm. The Firm does not receive any portion of the fees paid by the client to STA and does not receive a referral fee in connection with the accounting services that STA renders to its clients. However, one or more of the Firm’s Supervised Persons are principals of STA and are entitled to receive distributions relative to their ownership interest. There exists a conflict of interest to the extent that either SFO or STA recommend the services of the other.  Disclosure Brochure Item 11. Code of Ethics SFO has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”) that sets forth the standards of conduct expected of its Supervised Persons. SFO’s Code of Ethics contains written policies reasonably designed to prevent certain unlawful practices such as the use of material non-public information by the Firm or any of its Supervised Persons and the trading by the same of securities ahead of clients in order to take advantage of pending orders. The Code of Ethics also requires certain of SFO’s personnel to report their personal securities holdings and transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited offerings). However, the Firm’s Supervised Persons are permitted to buy or sell securities that it also recommends to clients if done in a fair and equitable manner that is consistent with the Firm’s policies and procedures. This Code of Ethics has been established recognizing that some securities trade in sufficiently broad markets to permit transactions by certain personnel to be completed without any appreciable impact on the markets of such securities. Therefore, under limited circumstances, exceptions may be made to the policies stated below. When the Firm is engaging in or considering a transaction in any security on behalf of a client, no Supervised Person with access to this information may knowingly effect for themselves or for their immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in that security unless: • the transaction has been completed; • the transaction for the Supervised Person is completed as part of a batch trade with clients; or • a decision has been made not to engage in the transaction for the client. These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments, including repurchase agreements; (iii) shares issued by money market funds; and iv) shares issued by other unaffiliated open- end mutual funds. Clients and prospective clients may contact SFO to request a copy of its Code of Ethics by contacting the Firm at the phone number on the cover page of this brochure.  Disclosure Brochure Item 12. Brokerage Practices Recommendation of Broker-Dealers for Client Transactions SFO recommends that clients utilize the custody, brokerage and clearing services of Charles Schwab & Co, Inc. through its Schwab Advisor Services division (“Schwab”) for investment management accounts. The final decision to custody assets with Schwab is at the discretion of the client, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. SFO is independently owned and operated and not affiliated with Schwab. Schwab provides SFO with access to its institutional trading and custody services, which are typically not available to retail investors. Factors which SFO considers in recommending Schwab or any other broker-dealer to clients include their respective financial strength, reputation, execution, pricing, research and service. The commissions and/or transaction fees charged by Schwab may be higher or lower than those charged by other Financial Institutions. The commissions paid by SFO’s clients to Schwab comply with the Firm’s duty to obtain “best execution.” Clients may pay commissions that are higher than another qualified Financial Institution might charge to effect the same transaction where SFO determines that the commissions are reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a Financial Institution’s services, including among others, the value of research provided, execution capability, commission rates and responsiveness. SFO seeks competitive rates but may not necessarily obtain the lowest possible commission rates for client transactions. Consistent with obtaining best execution, brokerage transactions are directed to certain broker-dealers in return for investment research products and/or services which assist SFO in its investment decision- making process. Such research will be used to service all of the Firm’s clients, but brokerage commissions paid by one client may be used to pay for research that is not used in managing that client’s portfolio. The receipt of investment research products and/or services as well as the allocation of the benefit of such investment research products and/or services poses a conflict of interest because SFO does not have to produce or pay for the products or services. SFO periodically and systematically reviews its policies and procedures regarding its recommendation of Financial Institutions in light of its duty to obtain best execution. Software and Support Provided by Financial Institutions  Disclosure Brochure SFO receives without cost from Schwab administrative support, computer software, related systems support, as well as other third party support as further described below (together "Support") which allow SFO to better monitor client accounts maintained at Schwab and otherwise conduct its business. SFO receives the Support without cost because the Firm renders investment management services to clients that maintain assets at Schwab. The Support is not provided in connection with securities transactions of clients (i.e., not “soft dollars”). The Support benefits SFO, but not its clients directly. Clients should be aware that SFO’s receipt of economic benefits such as the Support from a broker-dealer creates a conflict of interest since these benefits will influence the Firm’s choice of broker-dealer over another that does not furnish similar software, systems support or services. In fulfilling its duties to its clients, SFO endeavors at all times to put the interests of its clients first and has determined that the recommendation of Schwab is in the best interest of clients and satisfies the Firm's duty to seek best execution. Specifically, SFO receives the following benefits from Schwab: i) receipt of duplicate client confirmations and bundled duplicate statements; ii) access to a trading desk that exclusively services its institutional traders; iii) access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; and iv) access to an electronic communication network for client order entry and account information. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as a certain amount of the advisor’s clients’ assets are maintained in accounts at Schwab. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab also makes available to the Firm other products and services that benefit the Firm but may not benefit its clients’ accounts. These benefits may include national, regional or Firm specific educational events organized and/or sponsored by Schwab. Other potential benefits may include occasional business entertainment of personnel of SFO by Schwab personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist SFO in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of the Firm's fees from its clients’ accounts, and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of the Firm’s accounts, including accounts not maintained at Schwab. Schwab also makes available to SFO other services intended to help the Firm manage and further develop its business enterprise. These services  Disclosure Brochure may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services rendered to the Firm by independent third parties. Schwab may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to the Firm. While, as a fiduciary, SFO endeavors to act in its clients’ best interests, the Firm's recommendation that clients maintain their assets in accounts at Schwab may be based in part on the benefits received and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which creates a potential conflict of interest. Brokerage for Client Referrals SFO does not consider, in selecting or recommending broker-dealers, whether the Firm receives client referrals from the Financial Institutions or other third party. Directed Brokerage The client may direct SFO in writing to use a particular Financial Institution to execute some or all transactions for the client. In that case, the client will negotiate terms and arrangements for the account with that Financial Institution and the Firm will not seek better execution services or prices from other Financial Institutions or be able to “batch” client transactions for execution through other Financial Institutions with orders for other accounts managed by SFO (as described above). As a result, the client may pay higher commissions or other transaction costs, greater spreads or may receive less favorable net prices, on transactions for the account than would otherwise be the case. Subject to its duty of best execution, SFO may decline a client’s request to direct brokerage if, in the Firm’s sole discretion, such directed brokerage arrangements would result in additional operational difficulties. Trade Aggregation Transactions for each client will be effected independently, unless SFO decides to purchase or sell the same securities for several clients at approximately the same time. SFO may (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among the Firm’s clients differences in prices and commissions or other transaction costs that might not have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and allocated among SFO’s clients pro rata to the purchase and sale orders placed for each client on any given day. To the extent that the Firm determines to aggregate client orders for the purchase or sale of securities, including securities in which SFO’s Supervised Persons may invest, the Firm does so in accordance with applicable rules promulgated  Disclosure Brochure under the Advisers Act and no-action guidance provided by the staff of the U.S. Securities and Exchange Commission. SFO does not receive any additional compensation or remuneration as a result of the aggregation. In the event that the Firm determines that a prorated allocation is not appropriate under the particular circumstances, the allocation will be made based upon other relevant factors, which include: (i) when only a small percentage of the order is executed, shares may be allocated to the account with the smallest order or the smallest position or to an account that is out of line with respect to security or sector weightings relative to other portfolios, with similar mandates; (ii) allocations may be given to one account when one account has limitations in its investment guidelines which prohibit it from purchasing other securities which are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an allocation, shares may be reallocated to other accounts (this may be due to unforeseen changes in an account’s assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, the Firm may exclude the account(s) from the allocation; the transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts on a random basis. Item 13. Review of Accounts Account Reviews SFO monitors client portfolios on a continuous and ongoing basis and regular account reviews are conducted on at least an annual basis. Such reviews are conducted by the Firm’s financial advisors and principals on the investment committee. All investment advisory clients are encouraged to discuss their needs, goals and objectives with SFO and to keep the Firm informed of any changes thereto. Account Statements and Reports Clients are provided with transaction confirmation notices and regular summary account statements directly from the Financial Institutions where their assets are custodied. From time-to-time or as otherwise requested, clients may also receive written or electronic reports from SFO and/or an outside service provider, which contain certain account and/or market-related information, such as an inventory of account holdings or account performance. Clients should compare the account statements they receive from their custodian with any documents or reports they receive from SFO or an outside service provider.  Disclosure Brochure Item 14. Client Referrals and Other Compensation Client Referrals The Firm does not currently provide compensation to any third-party solicitors for client referrals. In the event a client is introduced to SFO by an affiliated solicitor, the Firm may pay that solicitor a referral fee in accordance with applicable laws. Unless otherwise disclosed, any such referral fee is paid solely from SFO’s investment management fee and does not result in any additional charge to the client. Any affiliated solicitor of SFO is required to disclose the nature of his or her relationship with the Firm to prospective clients at the time of the solicitation. Other Compensation The Firm receives economic benefits from Schwab. The benefits, conflicts of interest and how they are addressed are discussed above in response to Item 12. Item 15. Custody SFO is deemed to have custody of client funds and securities because the Firm is given the ability to debit client accounts for payment of the Firm’s fees. As such, client funds and securities are maintained at one or more Financial Institutions that serve as the qualified custodian with respect to such assets. Such qualified custodians will send account statements to clients at least once per calendar quarter that typically detail any transactions in such account for the relevant period. In addition, as discussed in Item 13, SFO will also send, or otherwise make available, periodic supplemental reports to clients. Clients should carefully review the statements sent directly by the Financial Institutions and compare them to those received from SFO. Any other custody disclosures can be found in the Firm’s Form ADV Part 1. Standing Letters of Authorization SFO also will have custody due to clients giving the Firm limited power of attorney in a standing letter of authorization (“SLOA”) to disburse funds to one or more third parties as specifically designated by the client. In such circumstances, the Firm will implement the steps in the SEC’s no-action letter on February 21, 2017 which includes (in summary): i) client will provide instruction for the SLOA to the custodian; ii) client will authorize the Firm to direct transfers to the specific third party; iii) the custodian will perform appropriate verification of the instruction and provide a transfer of funds notice to the client promptly after each transfer; iv) the client will have the ability to terminate or change the instruction; v) the Firm will have  Disclosure Brochure no authority or ability to designate or change the identity or any information about the third party; vi) the Firm will keep records showing that the third party is not a related party of the Firm or located at the same address as the Firm; and vii) the custodian will send the client an initial and annual notice confirming the SLOA instructions. Item 16. Investment Discretion SFO is given the authority to exercise discretion on behalf of clients. SFO is considered to exercise investment discretion over a client’s account if it can effect and/or direct transactions in client accounts without first seeking their consent. SFO is given this authority through a power-of-attorney included in the agreement between SFO and the client. Clients may request a limitation on this authority (such as certain securities not to be bought or sold). SFO takes discretion over the following activities: • The securities to be purchased or sold; • The amount of securities to be purchased or sold; • When transactions are made; and • The Independent Managers to be hired and fired. Item 17. Voting Client Securities Acceptance of Proxy Voting Authority SFO accepts the authority to vote a client’s securities (i.e., proxies) on their behalf. When SFO accepts such responsibility, it will only cast proxy votes in a manner consistent with the best interest of its clients. Absent special circumstances, which are fully-described in the Firm’s Proxy Voting Policies and Procedures, all proxies will be voted consistent with guidelines established and described in SFO’s Proxy Voting Policies and Procedures, as they may be amended from time-to-time. Clients may contact SFO to request information about how the Firm voted proxies for that client’s securities or to get a copy of SFO’s Proxy Voting Policies and Procedures. A brief summary of SFO’s Proxy Voting Policies and Procedures is as follows: • SFO has formed a Proxy Voting Committee that will be responsible for monitoring corporate actions, making voting decisions in the best interest of clients, and ensuring that proxies are submitted in a timely manner. • The Proxy Voting Committee will vote proxies according to SFO’s then current Proxy Voting Guidelines. The Proxy Voting Guidelines include many specific examples of voting decisions for the types of proposals that are most frequently presented, including: composition of the board of  Disclosure Brochure directors; approval of independent auditors; management and director compensation; anti-takeover mechanisms and related issues; changes to capital structure; corporate and social policy issues; and issues involving mutual funds. • Although the Proxy Voting Guidelines are followed as a general policy, certain issues are considered on a case-by-case basis based on the relevant facts and circumstances. Since corporate governance issues are diverse and continually evolving, the Firm devotes an appropriate amount of time and resources to monitor these changes. • Clients cannot direct SFO’s vote on a particular solicitation but can revoke the Firm’s authority to vote proxies. In situations where there is a conflict of interest in the voting of proxies due to business or personal relationships that SFO maintains with persons having an interest in the outcome of certain votes, the Firm takes appropriate steps to ensure that its proxy voting decisions are made in the best interest of its clients and are not the product of such conflict. Item 18. Financial Information SFO is not required to disclose any financial information listed in the instructions to Item 18 because: • The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance of services rendered; • The Firm does not have a financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients; and • The Firm has not been the subject of a bankruptcy petition at any time during the past ten years.