Overview

Assets Under Management: $614 million
Headquarters: HOLLAND, MI
High-Net-Worth Clients: 132
Average Client Assets: $3 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (TAMARISK FINANCIAL 2A BROCHURE)

MinMaxMarginal Fee Rate
$0 and above 2.50%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $25,000 2.50%
$5 million $125,000 2.50%
$10 million $250,000 2.50%
$50 million $1,250,000 2.50%
$100 million $2,500,000 2.50%

Clients

Number of High-Net-Worth Clients: 132
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 61.74
Average High-Net-Worth Client Assets: $3 million
Total Client Accounts: 2,993
Discretionary Accounts: 2,993

Regulatory Filings

CRD Number: 312073
Filing ID: 2010412
Last Filing Date: 2025-08-19 11:13:00
Website: https://dinsmorecomplianceservices.com

Form ADV Documents

Primary Brochure: TAMARISK FINANCIAL 2A BROCHURE (2025-05-19)

View Document Text
Tamarisk Financial, LLC Doing Business As: West Michigan Advisors Tamarisk Family Office Form ADV Part 2A – Disclosure Brochure Effective May 19, 2025 This Form ADV 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Tamarisk Financial, LLC (“Tamarisk” or the “Advisor”) dba West Michigan Advisors (“WMA”) and Tamarisk Family Office (“TFO”). If you have any questions about the contents of this Disclosure Brochure, please contact Lonny Elfenbein, Chief Compliance Officer at 513-977-8330 Tamarisk Financial is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. Additional information about Tamarisk Financial and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or with CRD# 312073. Tamarisk Financial, LLC 301 Hoover Blvd. Suite 300 Holland MI 49423 Phone: (616) 820-1040 Fax: (616) 205-9250 https://tamariskfinancial.com Tamarisk Financial, LLC 301 Hoover Blvd. Suite 300 Holland MI 49423 Phone: (616) 820-1040 Fax: (616) 205-9250 https://tamariskfinancial.com Page 1 Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Tamarisk. Tamarisk believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Tamarisk encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes Since our last annual update dated March 31, 2025 the following material change has taken place: • Item 4 - Advisory Services – Section A (Firm Information) has been updated to show Aaron Clark as Managing Partner and Kevin Clark as Senior Partner. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in our business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs in the business practices of Tamarisk. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD #312073. You may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (616) 820-1040. Tamarisk Financial, LLC 301 Hoover Blvd. Suite 300 Holland MI 49423 Phone: (616) 820-1040 Fax: (616) 205-9250 https://tamariskfinancial.com Page 2 Item 3 – Table of Contents Item 2 – Material Changes ......................................................................................................................................... 2 Item 3 – Table of Contents ........................................................................................................................................ 3 Item 4 – Advisory Services ........................................................................................................................................ 4 Item 5 – Fees and Compensation ............................................................................................................................... 8 Item 6 – Performance-Based Fees and Side-By-Side Management ........................................................................ 11 Item 7- Types of Clients B. Advisory Services Offered ......................................................................................... 11 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis ......................... 12 Item 9 – Disciplinary Information ........................................................................................................................... 14 Item 10 – Other Financial Industry Activities and Affiliations ............................................................................... 14 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......................... 14 Item 12 – Brokerage Practices ................................................................................................................................. 15 Item 13 – Review of Accounts ................................................................................................................................ 16 Item 14 – Client Referrals and Other Compensation A. Compensation Received by Tamarisk ............................ 17 Item 15 – Custody .................................................................................................................................................... 18 Item 16 – Investment Discretion .............................................................................................................................. 18 Item 17 – Voting Client Securities .......................................................................................................................... 19 Item 18 – Financial Information .............................................................................................................................. 19 Privacy Policy .......................................................................................................................................................... 20 Tamarisk Financial, LLC 301 Hoover Blvd. Suite 300 Holland MI 49423 Phone: (616) 820-1040 Fax: (616) 205-9250 https://tamariskfinancial.com Page 3 Item 4 – Advisory Services A. Firm Information Tamarisk Financial, LLC (herein “Tamarisk” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”) doing business as West Michigan Advisors (herein “WMA”) and Tamarisk Family Office (herein “TFO”). Tamarisk was organized as a limited liability company (“LLC”) under the laws of the State of Michigan in December 2020. Tamarisk Financial is owned and operated by Kevin H. Clark (Senior Partner), Aaron M. Clark (Managing Partner), Thomas S. Bosch (Partner) and Symphony Grove LLC (Partner), a Michigan Limited Liability Company owned by the KDC Revocable Trust. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Tamarisk. For information regarding this Disclosure Brochure, please contact Lonny Elfenbein, Chief Compliance Officer at (513) 977-8330. B. Advisory Services Offered Tamarisk offers investment advisory services through WMA and Tamarisk Family Office which are designed to meet the needs of individuals, high net worth individuals, family offices, trusts, estates, charitable organizations and businesses (each referred to as a “Client”). Unless noted by agreement the Advisor serves as a fiduciary to Clients, as defined under applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Tamarisk’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services Tamarisk provides customized investment management solutions for its Clients through its dba WMA. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. WMA works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create an investment strategy. WMA will construct Client portfolios utilizing exchange-traded funds (“ETFs”), mutual funds, individual equities, and/or individual bonds. The Advisor also includes alternative investment vehicles and other types of investments, as appropriate, to meet the needs of its Clients. WMA will may retain the Client’s legacy investments based on portfolio fit, tax implications and/or other factors. WMA’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate investments that have been held for less than one year to meet the objectives of the Client or due to market conditions. WMA will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. WMA evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. WMA may recommend, on occasion, redistributing investment allocations to diversify the portfolio. WMA may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. WMA may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Tamarisk Financial, LLC 301 Hoover Blvd. Suite 300 Holland MI 49423 Phone: (616) 820-1040 Fax: (616) 205-9250 https://tamariskfinancial.com Page 4 Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. At no time will the Advisor accept or maintain custody of a Client’s funds or securities, except for the limited authority as detailed in Item 15 – Custody. All Client assets will be managed within their designated brokerage account or pension account, pursuant to the Client investment advisory agreement. Use of Independent Managers - WMA may recommend that a Client utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio. In such instances, the Client may be required to authorize and enter into an advisory agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide investment management and related services. The Advisor may also assist in the development of the initial policy recommendations and managing the ongoing Client relationship. The Advisor will perform initial and ongoing oversight and due diligence over the selected Independent Manager[s] to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. The Client, prior to entering into an agreement with unaffiliated investment manager[s] or investment platform[s], will be provided with the Independent Manager's Form ADV 2A (or a brochure that makes the appropriate disclosures). Financial Planning Services WMA will typically provide a variety of financial planning services to Clients, pursuant to a separate agreement between the Advisor and the Client, or alternatively included in the overall wealth management engagement. The Advisor, at its sole discretion, may waive its financial planning fee. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not limited to investment planning, retirement planning, estate planning, personal savings, education savings, insurance needs, and other areas of a Client’s financial situation. Services are defined as mutually agreed in the Client engagement. A financial plan developed for or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Financial planning and consulting recommendations poses a potential conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Client engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Tamarisk Financial, LLC 301 Hoover Blvd. Suite 300 Holland MI 49423 Phone: (616) 820-1040 Fax: (616) 205-9250 https://tamariskfinancial.com Page 5 WMA may also refer Clients to an accountant, attorney or other specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. Retirement Plan Advisory Services WMA provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsors”) The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: • Plan Participant Enrollment and Education Tracking • Ongoing Investment Recommendation and Assistance • Ongoing Investment Management (ERISA 3(38)) • Ongoing Investment Recommendations (ERISA 3(21)) These services are provided by WMA serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of WMA’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the agreement. Family Office Services Tamarisk offers the following family office services to high net worth individuals, investment limited partnerships, trusts, estates, charitable organizations, corporations, family offices and business entities through its Tamarisk Family Office DBA (“TFO”). Financial Planning Services TFO will typically provide a variety of financial planning services to Clients, pursuant to a separate agreement between the Advisor and the Client, or included in the overall wealth management engagement. The Advisor, at its sole discretion, may waive its financial planning fee. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not limited to investment planning, retirement planning, estate planning, personal savings, education savings, insurance needs, and other areas of a Client’s financial situation. A financial plan developed for or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. TFO works with each client to gather all relevant information from other professional advisers; accountants, attorneys, insurers, etc. to assemble a client’s financial profile so TFO can make well-informed recommendations that are suitable and in the client’s best interest. TFO acts as a project manager to coordinate the activities of the other professional advisers developing the family financial plan and to maintain it into the future with regular reviews and updates. Tamarisk Financial, LLC 301 Hoover Blvd. Suite 300 Holland MI 49423 Phone: (616) 820-1040 Fax: (616) 205-9250 https://tamariskfinancial.com Page 6 Financial planning and consulting recommendations poses a potential conflict between the interests of TFO and the interests of the Client. For example, the Advisor has an incentive to recommend that Client engage WMA for investment management services or to increase the level of investment assets with WMA, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by TFO or maintain an ongoing relationship with the TFO. If the Client elects to act on any of the recommendations made by the TFO, the Client is under no obligation to implement the transaction through the Advisor. Family Office Services and Special Projects TFO provides Family Office services such as consulting, expense management, bill pay, concierge services, philanthropic management and property management These services do not involve any type of investment advisory services or financial planning services. C. Client Account Management Prior to engaging with the Advisor to provide investment advisory, financial planning, or family office services, each Client is required to enter into one or more service agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. Engagements may be ongoing, or limited, as mutually agreed between Client and Advisor. These services may include:  Establishing an Investment Strategy – WMA, in connection with the Client, will develop a strategy that seeks to achieve the Client’s investment goals and objectives.  Asset Allocation – WMA will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.  Portfolio Construction – WMA will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.  Investment Management and Supervision – WMA will provide investment management and ongoing oversight of the Client’s portfolio.  Financial Planning Services – WMA will provide a variety of financial planning services to its clients on either a comprehensive or limited basis.  Family Office Financial Planning Services – TFO will provide individualized planning services for its clients on a comprehensive or limited basis.  Family Office Services and Special Projects – TFO will provide a variety of family office services for its clients. D. Wrap Fee Programs Tamarisk does not manage or place Client assets into a wrap fee program. E. Assets Under Management As of December 31, 2024, Tamarisk managed $614,378,709 in Client assets, all of which are managed on a discretionary basis. Tamarisk Financial, LLC 301 Hoover Blvd. Suite 300 Holland MI 49423 Phone: (616) 820-1040 Fax: (616) 205-9250 https://tamariskfinancial.com Page 7 Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client shall sign one or more agreements that detail the responsibilities of Tamarisk and the Client. A. Fees for Advisory Services Investment Management Services Investment advisory fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the investment advisory agreement. Investment advisory fees are computed using the fee schedule in the Client Agreement and the market value of assets under management on the last day of the previous quarter, including cash, accrued interest, accrued dividends, and securities purchased on margin, using the following guidelines: (a) cash and cash equivalents are valued at their dollar value; (b) marketable securities are valued at the current market price provided by the custodian; and (c) private investment funds and securities for which there is no active market are valued at the most recent valuation provided by the sponsor or the initial investment cost, as applicable. Investment advisory fees range from 0.25% to 2.50% based on several factors, including, but not limited to: the services offered to the Client, the complexity of the services to be provided, the level of Client assets managed by the Advisor, and/or the overall relationship with the Advisor. The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by WMA will be independently valued by the Custodian. Clients may make additions to and withdrawals from their account[s] at any time, subject to WMA’s right to terminate an account. Additions may be in cash or securities provided that WMA reserves the right to liquidate any transferred securities or decline to accept particular securities into a Client’s account[s]. Clients may withdraw account assets on notice to WMA, subject to the usual and customary securities settlement procedures. However, WMA designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a Client’s investment objectives. WMA may consult with its Clients about the options and ramifications of transferring securities. However, Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax ramifications. Use of Independent Managers For Clients referred by the Advisor to an Independent Manager, the Client’s fee may be separately billed or deducted from the Client’s account[s] by the Independent Manager, as mutually agreed. Financial Planning Services WMA typically includes financial planning services as part of a wealth management engagement and fee. WMA also offers its services on a stand-alone basis at hourly rate beginning at $250/hour or a fixed engagement fee. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. Fixed fee engagements are negotiated based on the expected number of hours to complete an engagement at the Advisor’s hourly rate. An estimate for total hours and/or total costs will be provided to the Client prior to engaging for these services. Retirement Plan Advisory Services Fees Fees for retirement plan advisory services are charged an annual asset-based fee of up to 2.50%, in advance of each calendar quarter, pursuant to the terms of the agreement. Retirement plan fees are based on the market value of assets under management at the end of the prior calendar quarter. Fees may be negotiable depending on the size and complexity of the Plan. Tamarisk Financial, LLC 301 Hoover Blvd. Suite 300 Holland MI 49423 Phone: (616) 820-1040 Fax: (616) 205-9250 https://tamariskfinancial.com Page 8 Tamarisk Family Office Fees The specific manner in which fees are charged by TFO are established in each respective Agreement. Depending on the terms of the Agreement, TFO may agree to provide its Financial Planning or Family Office/Special Project services on either an hourly and/or fixed fee basis, or on the basis of assets under management. Generally TFO requires a retainer for its family office services (estimated hourly or fixed). TFO’s family office fees are negotiable but generally range from $10,000 to $500,000 on an annual fixed fee basis, $250 to $800 on an hourly rate basis and/or .25% to 1.5% of assets under advisement depending upon the level and scope of the services and the professional rendering the services. Calculations for the initial fee/retainer may be estimates based on the projected assets under management or on projected time and materials required for certain non-investment related family office services, such as tax return preparation. B. Fee Billing Investment Management Services Investment advisory fees will be calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the respective quarter-end date. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with WMA at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. Clients provide written authorization permitting advisory fees to be deducted by WMA to be paid directly from their accounts held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Use of Independent Managers For Clients referred by the Advisor to an Independent Manager, the Client’s fee may be separately billed or deducted from the Client’s account[s] with the respective manager and a portion of the investment advisory fee may be provided to WMA, as mutually agreed. Financial Planning Services One-time financial planning engagements require an advance payment of fees up to 50% of the expected total cost of the engagement. Upon completion of the engagement deliverable[s], the remaining balance of the engagement fees shall be invoiced by the Advisor and are due upon receipt of the invoice. Fees are typically paid via check however clients with assets managed by WMA may elect to have these fees deducted from their custodial accounts. Retirement Plan Advisory Services Fees WMA is compensated for its services at the beginning of the quarter before advisory services are rendered. Fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. Tamarisk Family Office Fees Clients engaging with TFO on a fixed annual fee or percentage of assets under management basis will be billed for its services at the beginning of each month based on the annual fee and terms of the Agreement. Fixed annual fees are invoiced by the Advisor and are due upon receipt of the invoice or as otherwise agreed upon between the Client and TFO. Clients engaging with TFO on a percentage of assets under advisement basis will be billed for its services per the terms of the Investment Advisory agreement with WMA. Tamarisk Financial, LLC 301 Hoover Blvd. Suite 300 Holland MI 49423 Phone: (616) 820-1040 Fax: (616) 205-9250 https://tamariskfinancial.com Page 9 Clients engaging with TFO on an hourly basis generally require an advance payment of fees of up to 50% of the expected cost of the engagement. Upon completion of the engagement the remaining balance of the engagement fees shall be invoiced by the Advisor and are due upon receipt of the invoice. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties in connection with investments made on behalf of the Client’s account[s], such as securities transaction fees, wire transfer fees, fees for trades executed away from the Custodian (if applicable) and other fees. In addition, all fees paid to WMA for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of WMA, but would not receive the services provided by WMA which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by WMA to fully understand the total fees to be paid. D. Advance Payment of Fees and Termination Investment Management Services WMA is compensated for its services in advance of the quarter in which investment advisory services are rendered. Either party may request to terminate the investment advisory agreement with WMA, at any time, by providing advance written notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five- day period, the Client will incur charges for bona fide advisory services rendered to the point of termination the Advisor will promptly refund any unearned, prepaid advisory fees. Use of Independent Managers In the event that a Client should wish to terminate their relationship with the Independent Manager, the terms for termination will be set forth in the respective agreements between the Client and that Independent Manager. WMA will assist the Client with the termination and transition as appropriate. Financial Planning Services WMA requires an advance deposit as described above. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid fees based on the number of hours worked by the Advisor or the percentage of the engagement completed, as applicable. Retirement Plan Advisory Services Fees WMA is compensated for its services in advance of the quarter in which retirement plan advisory services are rendered. Either party may request to terminate their services with WMA in whole or in part, by providing advance written notice to the other party. The Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s retirement plan services agreement with the Advisor is non-transferable without the Client’s written approval. Tamarisk Financial, LLC 301 Hoover Blvd. Suite 300 Holland MI 49423 Phone: (616) 820-1040 Fax: (616) 205-9250 https://tamariskfinancial.com Page 10 Tamarisk Family Office Services TFO is compensated for its fixed fee services in advance of the quarter in which Family Office services are rendered. Either party may request to terminate the investment advisory agreement with TFO, at any time, by providing advance written notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five- day period, the Advisor will promptly refund any unearned, prepaid advisory fees. Clients engaging with TFO on an hourly basis generally require an advance payment of fees of up to 50% of the expected cost of the engagement. Either party may request to terminate the investment advisory agreement with TFO, at any time, by providing advance written notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide Family Office services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will promptly refund any unearned, prepaid advisory fees. E. Compensation for Sales of Securities Tamarisk does not buy or sell securities to earn securities transaction fees and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Certain Advisory Persons are also Registered Representatives of Level Four Financial, LLC. (“Level Four”). Level Four is a registered broker-dealer (CRD No. 13905), member FINRA, SIPC. In one’s separate capacity as a Registered Representative of Level Four, an Advisory Person will implement securities transactions through Level Four and not through Tamarisk. In such instances, the Advisory Person will receive commission- based compensation in connection with the purchase and sale of securities, including 12b-1 fees for the sale of investment company products. Compensation earned by the Advisory Person in one’s capacity as a Registered Representative is separate and in addition to the Advisor’s fees. This practice presents a conflict of interest because the Advisory Person who is a Registered Representative has an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on the Client. Clients are not obligated to implement any recommendation provided by the Advisor nor its Advisory Persons. Neither the Advisor nor Advisory Persons will earn ongoing investment advisory fees in connection with any products or services implemented in the Advisory Person’s separate capacity as a Registered Representative. Please see Item 10 below. Item 6 – Performance-Based Fees and Side-By-Side Management WMA does not charge performance-based fees for its investment advisory services. The fees charged by WMA are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. WMA does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7- Types of Clients A. Advisory Services Offered WMA offers investment advisory services designed to meet the needs of individuals, high net worth individuals, family offices, trusts, estates, charitable organizations and businesses. WMA does not impose a minimum account or relationship size. Tamarisk Financial, LLC 301 Hoover Blvd. Suite 300 Holland MI 49423 Phone: (616) 820-1040 Fax: (616) 205-9250 https://tamariskfinancial.com Page 11 TFO offers investment advisory services designed to meet the needs of high net worth individuals, trusts, estates, charitable organizations, family offices and businesses. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis WMA primarily employs fundamental and technical analysis methods in developing investment strategies for its Clients. Research and analysis from WMA are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria are generally ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in “Item 13 – Review of Accounts”. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that WMA will be able to accurately predict such a reoccurrence. As noted above, WMA generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. WMA will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, WMA may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. WMA will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided Tamarisk Financial, LLC 301 Hoover Blvd. Suite 300 Holland MI 49423 Phone: (616) 820-1040 Fax: (616) 205-9250 https://tamariskfinancial.com Page 12 information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing a Client’s account[s]. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment approach: Market Risks – The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks – The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if an ETF is traded actively and a liquidity risk if the ETF has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond ETFs – Bond ETFs are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as desired if there is no readily available market for the bond. Mutual Fund Risks – The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily; therefore, a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Private Fund Risks - A private fund is an investment vehicle that pools capital from a number of investors and invests in securities and other instruments. In almost all cases, a private fund is a private investment vehicle that is typically not registered under federal or state securities laws. So that private funds do not have to register under these laws, issuers make the funds available only to certain sophisticated or accredited investors and cannot be offered or sold to the general public. Private funds are generally smaller than mutual funds because they are often limited to a small number of investors and have a more limited number of eligible investors. Many but not all private funds use leverage as part of their investment strategies. Private funds management fees typically include a base management fee along with a performance component. In many cases, the fund’s managers may become “partners” with their clients by making personal investments of their own assets in the fund. Most private funds offer their securities by providing an offering memorandum or private placement memorandum, known as “PPM” for short. The PPM covers important information for investors and investors should review this document carefully and should consider conducting additional due diligence before investing in the private fund. The primary risks of private funds include the following: (a) Private funds do not sell publicly and are therefore illiquid. An investor may not be able to exit a private fund or sell its interests in the fund before the fund closes. And (b) Private Tamarisk Financial, LLC 301 Hoover Blvd. Suite 300 Holland MI 49423 Phone: (616) 820-1040 Fax: (616) 205-9250 https://tamariskfinancial.com Page 13 funds are subject to various other risks, including risks associated with the types of securities that the private fund invests in or the type of business issuing the private placement. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving Tamarisk or its management persons. Tamarisk values the trust Clients place in the Advisor. The Advisor encourages Client to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor and its Advisors Persons are on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 312073. Item 10 – Other Financial Industry Activities and Affiliations Broker-Dealer Affiliation As noted in Item 5, certain Advisory Persons are also Registered Representatives of Level Four. In one’s separate capacity as a Registered Representative, an Advisory Person will receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by an Advisory Person. Neither the Advisor nor its Advisory Persons will earn ongoing investment advisory fees in connection with any services implemented in an Advisory Person’s separate capacity as a Registered Representative. Insurance Recommendations The Advisor also serves as a licensed insurance agency, and as such, may offer insurance products on a commissionable basis. The Advisor shall generally introduce the Client to an unaffiliated insurance agency to manage the insurance process. The Advisor shall receive a portion of the insurance commission earned by the unaffiliated insurance agency. No Client shall be under any obligation to purchase any insurance products from the Advisor or such introduced insurance agency. The recommendation by an Advisory Person that a Client purchase an insurance product presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend insurance products based on commissions to be received, rather than based on a particular Client’s need. Clients are reminded that they remain free to purchase insurance products through other insurance agencies. Use of Independent Managers As noted in Item 4, the Advisor may select Independent Managers to assist with the implementation of a Client’s investment strategy. In such arrangements, the Advisor will receive a portion of the investment advisory fees collected by the Independent Manager from the Client. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Tamarisk has implemented a Code of Ethics that defines the Advisor’s fiduciary commitment to each Client. This Code of Ethics applies to all persons associated with Tamarisk (“Supervised Persons”). The Code of Ethics was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the Client. Tamarisk and its personnel owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Tamarisk Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code of Ethics covers a range of topics that Tamarisk Financial, LLC 301 Hoover Blvd. Suite 300 Holland MI 49423 Phone: (616) 820-1040 Fax: (616) 205-9250 https://tamariskfinancial.com Page 14 address employee ethics and conflicts of interest. To request a copy of the Code of Ethics, please contact the Advisor at (616) 8201040. B. Personal Trading with Material Interest Tamarisk allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Tamarisk does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Tamarisk does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Tamarisk allows Supervised Persons to purchase or sale of the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a potential conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted a Code of Ethics, which addresses insider trading (material non-public information controls) and personal securities reporting procedures. When trading for personal accounts, Supervised Persons of Tamarisk have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Tamarisk requiring reporting of personal securities trades by its employees for review by the Chief Compliance Officer (“CCO”). The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While Tamarisk allows Supervised Persons to purchase or sale of the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. At no time will Tamarisk, or any Supervised Person of Tamarisk, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] WMA typically does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize WMA to direct trades to this Custodian as agreed in the investment advisory agreement. Further, WMA does not have the discretionary authority to negotiate commissions on behalf of our Clients on a trade-by-trade basis. For certain Clients, the Advisor may be granted the discretion to select the broker-dealer for the purchase or sale of fixed income instruments traded away from the Advisor’s Custodian. Where WMA does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and executing services. Clients are not obligated to use the Custodian recommended by the Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by WMA. However, if the recommended Custodian is not engaged, WMA may be limited in the services it can provide comparable to other clients. WMA may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its overall reputation. WMA will generally recommend that Clients establish their account[s] at Raymond James & Associates, Inc. (“Raymond James”) or Charles Schwab & Co., Inc. (“Schwab”). Raymond James and Schwab (collectively the “Custodians”) serve as the Client’s “qualified custodian.” WMA maintains an institutional relationship with Raymond James and Schwab, whereby the Advisor receives economic benefits from Raymond James and Schwab. Please see Item 14 below. Tamarisk Financial, LLC 301 Hoover Blvd. Suite 300 Holland MI 49423 Phone: (616) 820-1040 Fax: (616) 205-9250 https://tamariskfinancial.com Page 15 Factors which the Advisor considers in recommending Raymond James or Schwab to Clients include their respective financial strength, reputation, execution, pricing, and research service. The commissions and/or transaction fees charged by Raymond James and Schwab may be higher or lower than those charged by other financial institutions. The Advisor maintains an institutional relationship with Raymond James and Schwab, whereby the Advisor receives certain Benefits. Please see Item 14 below. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with the broker-dealer/custodian in exchange for research and other services. Tamarisk does not participate in soft dollar programs sponsored or offered by any broker- dealer. However, the Advisor does receive certain economic benefits from Raymond James. Please see Item 14 below. 2. Brokerage Referrals - Tamarisk does not receive any compensation from any third party in connection with the recommendation for establishing a brokerage account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Tamarisk will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). In selecting the Custodian, Tamarisk will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the designated Custodian. B. Trade Errors WMA’s goal is to execute trades seamlessly and in the best interests of the client. In the event a trade error occurs, WMA endeavors to identify the error in a timely manner, correct the error so that the client’s account is in the position it would have been had the error not occurred, and, after evaluating the error, assess what action(s) might be necessary to prevent a recurrence of similar errors in the future. Trade errors generally are corrected through the use of a “trade error” account or similar account at Raymond James, Schwab, or another BD, as the case may be. In the event an error is made in a client account custodied elsewhere, WMA works directly with the broker in question to take corrective action. In all cases, WMA will take the appropriate measures to return the client’s account to its intended position. C. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the broker. Tamarisk will execute its transactions through an unaffiliated broker-dealer selected by the Client. Tamarisk may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This will be done in a way that does not consistently advantage or disadvantage particular Client accounts. Item 13 – Review of Accounts Tamarisk Financial, LLC 301 Hoover Blvd. Suite 300 Holland MI 49423 Phone: (616) 820-1040 Fax: (616) 205-9250 https://tamariskfinancial.com Page 16 Each Client account shall be reviewed at least annually. Reviews may be conducted more or less frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify WMA if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. Additional reporting is provided to clients during review meetings, as needed on an ad hoc basis and on-demand through our client portal. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Tamarisk Participation in Institutional Advisor Platform (Raymond James) Tamarisk has established an institutional relationship with Raymond James to assist the Advisor in managing Client account[s]. Access to the Raymond James platform is provided at no charge to the Advisor. The Advisor receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Raymond James. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish similar software, systems support, or services. Participation in Institutional Advisor Platform (Schwab) Tamarisk has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Tamarisk. As a registered investment advisor participating on the Schwab Advisor Services platform, Tamarisk receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a potential conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Tamarisk Financial, LLC 301 Hoover Blvd. Suite 300 Holland MI 49423 Phone: (616) 820-1040 Fax: (616) 205-9250 https://tamariskfinancial.com Page 17 Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to Tamarisk that may not benefit the Client, including: educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest. Tamarisk believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. Insurance Agency As noted in Item 10, Tamarisk also serves as an insurance agency, where the Advisor may recommend to Clients the purchase of certain insurance products. Tamarisk will benefit from any revenue generated from the sale of a recommended insurance product. Use of Independent Managers The Advisor may be indirectly compensated by an Independent Manager as described in Item 5 above and does not receive any other forms of compensation with such arrangements. B. Client Referrals from Promoters The Advisor does not compensate, either directly or indirectly, any affiliated or unaffiliated parties (“Promoters”) for Client referrals. Item 15 – Custody Advisor does not maintain physical custody of client funds and/or securities, however Advisor is deemed to have custody pursuant to the authority granted by Client to directly deduct the advisor’s fee. All Clients must place their assets with a “qualified custodian”. Clients are required to select their own Custodian to retain their funds and securities and direct Tamarisk to utilize that Custodian for the Client’s security transactions. As described in Item 12, Brokerage Practices, client assets are held at qualified custodians that provide account statements at least quarterly directly to clients at their address of record. Tamarisk encourages Clients to review statements provided by the account Custodian. Additionally, Advisor is also deemed to have custody of client assets to the extent Clients gives the Advisor authority to move money from one account to another account pursuant to the authority granted through a Standing Letter of Authorization “SLOA.” In order to avoid additional regulatory requirements, the Custodian and the Advisor have adopted safeguards to ensure that the money movements are completed in accordance with the the SEC has exempted advisers from the custody audit Client’s instructions. For these types of deemed custody, requirement by rule or no-action relief. Item 16 – Investment Discretion WMA generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by WMA. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by WMA will be in accordance with each Client's investment objectives and goals. Tamarisk Financial, LLC 301 Hoover Blvd. Suite 300 Holland MI 49423 Phone: (616) 820-1040 Fax: (616) 205-9250 https://tamariskfinancial.com Page 18 Item 17 – Voting Client Securities Tamarisk does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither Tamarisk, nor its management, have any adverse financial situations that would reasonably impair the ability of Tamarisk to meet all obligations to its Clients. Neither Tamarisk, nor any of its Advisory Persons, has been subject to a bankruptcy or financial compromise. Tamarisk is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect fees of $1,200 or more for services to be performed six months or more in advance. Tamarisk Financial, LLC 301 Hoover Blvd. Suite 300 Holland MI 49423 Phone: (616) 820-1040 Fax: (616) 205-9250 https://tamariskfinancial.com Page 19 Privacy Policy Effective March 31, 2025 Our Commitment to You Tamarisk Financial, LLC (“Tamarisk” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Tamarisk (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Tamarisk does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Account applications and forms Investment questionnaires and suitability documents Transactional information with us or others Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. Tamarisk Financial, LLC 301 Hoover Blvd. Suite 300 Holland MI 49423 Phone: (616) 820-1040 Fax: (616) 205-9250 https://tamariskfinancial.com Page 20 We require third parties that assist in providing our services to you to protect the personal information they receive from us. How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. Tamarisk shares Client information with Level Four Financial, LLC (“ Level Four”). This sharing is due to the oversight Level Four has over certain Supervised Persons of the Advisor. You may also contact us at any time for a copy of the Level Four Privacy Policy. No Not Shared Marketing Purposes Tamarisk does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Tamarisk or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing Yes Yes Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. No Not Shared Information About Former Clients Tamarisk does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy, and will provide you with a revised Privacy Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non- public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (616) 820-1040 Tamarisk Financial, LLC 301 Hoover Blvd. Suite 300 Holland MI 49423 Phone: (616) 820-1040 Fax: (616) 205-9250 https://tamariskfinancial.com Page 21