TWEDDELL GOLDBERG LLC

Tweddell Goldberg, LLC FORM ADV Part 2 A CRD Number: 141634 Item 1: Cover Page Tweddell Goldberg, LLC 20320 Midland Drive Sonora, CA 95370-9602 www.tginvesting.com 209-536-9734 (jerry@tginvesting.com) October 13, 2025 This brochure provides information about the qualifications and business practices of Tweddell Goldberg, LLC (the “Firm”, “TGI”, “we”, “us”, “our”). If you have any questions about the contents of this brochure, please contact us telephone or by email. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Registration does not imply a certain level of skill or training. Additional information is also available on the internet at www.adviserinfo.sec.gov our searchable IARD/CRD number is 141634  Tweddell Goldberg, LLC FORM ADV Part 2 A CRD Number: 141634 Item 2: Summary of Material Changes Since the last filing on September 24, 2025, we have the following material changes to report:  We are switching from SEC registration to state registration in California. Whenever you would like to receive a complete copy of our brochure, please contact us by telephone or by email. 2  Tweddell Goldberg, LLC FORM ADV Part 2 A CRD Number: 141634 Item 3: Table of Contents Item 1: Cover Page ........................................................................................................................................1 Item 2: Summary of Material Changes ..........................................................................................................2 Item 3: Table of Contents ..............................................................................................................................3 Item 4: Advisory Business ..............................................................................................................................4 Item 5: Fees and Compensation ....................................................................................................................6 Item 6: Performance-Based Fees and Side-By-Side Management ................................................................8 Item 7: Types of Clients .................................................................................................................................9 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ..........................................................9 Item 9: Disciplinary Information ................................................................................................................ 10 Item 10: Other Financial Industry Activities and Affiliations ...................................................................... 11 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 11 Item 12: Brokerage Practices ..................................................................................................................... 12 Item 13: Review of Accounts ...................................................................................................................... 14 Item 14: Payment for Client Referrals and Other Compensation .............................................................. 15 Item 15: Custody ........................................................................................................................................ 16 Item 16: Investment Discretion .................................................................................................................. 17 Item 17: Voting Client Securities ................................................................................................................ 18 Item 18: Financial Information ................................................................................................................... 18 Item 19: Requirements for State Registered Advisers ............................................................................... 19 Privacy Notice ............................................................................................................................................. 19 3  Tweddell Goldberg, LLC FORM ADV Part 2 A CRD Number: 141634 Item 4: Advisory Business We provide investment management and advisory services to individual clients, as well as trusts, and business entities. We are a fee-only firm. The Firm is an LLC formed in California in August 2006. Advice is provided through consultation with you and may include determination of financial objectives, identification of financial problems, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning. Our main business, however, is investment management. We occasionally provide financial planning services for clients who need advice on a limited scope of work. Financial planning services will be catered to the client’s specific needs, but may include short-term and long-term financial strategies for investment planning, budgeting, taxes, college tuition funding, retirement planning and/or estate planning. Outside consultants may be used for tax planning, estate planning, college tuition funding, insurance needs and other financial planning strategies. For any financial planning services we may provide, we do not receive any fees or compensation from the sale of any securities, insurance, real estate, or other services recommended. Further, the client is under no obligation to act on our recommendations. If the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through our Firm. We provide both discretionary and non-discretionary services. With non-discretionary services, client approval is obtained before entering transactions. When we have discretionary trading authority, we have the authority to determine, without obtaining your specific consent, the securities to be bought or sold. We do not act as a custodian of your assets. You always maintain asset control. We place trades for you under a limited power of attorney. Whenever practical, we generally recommend the mutual fund share class with lowest annual expense ratios that your custodian offers. That sometimes includes institutional share classes. At times we may recommend other low-cost investment solutions, such as ETFs, stocks, individual fixed income securities, and other products. For more information on our investment philosophies, and the risks of our strategies and/or specific investments recommended, please refer to Item 8. We actively seek to avoid, or at least minimize, conflicts of interest which may exist between our firm and you. We sell no products. We accept no commissions or other fees. However, all investment advisory firms will likely possess some unavoidable conflicts of interest. In those instances when conflicts of interest arise, we have adopted policies which seek to keep your best interest paramount at all times. See Items 5, 11 and 12 of this Brochure, and other items, which explore in further detail how we act to keep your best interests first at all times during the course of relationship with you. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by you on an as-needed basis. Conflicts of interest will be disclosed to you in the unlikely event they should occur. We often know professionals that we can refer you to; we never accept fees for those referrals. 4  Tweddell Goldberg, LLC FORM ADV Part 2 A CRD Number: 141634 The initial meeting with potential clients, which may be in person or by telephone, is free of charge and is considered an exploratory interview to determine the extent to which investment management may be beneficial to you. Our Principal Owners Jerold Tweddell and Peter Kendall are members and principal owners of the Firm. Asset Management As of June 30, 2025, we manage $$93,577,060 in assets.. The total asset managed consists of $44,916,989 on a discretionary basis, and $48,660,071 on a non-discretionary basis. We provide investment supervisory services, also known as asset management services (discretionary); manage investment advisory accounts not involving investment supervisory services (non-discretionary); and furnish investment advice through consultations. For discretionary accounts, we have discretionary authority to determine the securities and the amount of securities to be bought or sold for a client's account. On an occasional basis, we may provide advice to you on matters not involving securities, such as financial planning matters and taxation issues. Assets are invested primarily in no-load or low-load mutual funds and exchange-traded funds, usually through discount brokers or fund companies. Fund companies charge each fund shareholder annual expenses that are disclosed in the fund prospectus. Discount brokerages charge a transaction fee for the purchase of some funds. We sometimes buy funds with higher expense ratios for you when discount brokerages offer them without charging transaction fees and we are investing a relatively small amount of money in that fund at that time. We always try to act in your best interests in choosing among different share classes of mutual funds. Stocks and bonds may be purchased or sold through a brokerage account when appropriate. The brokerage firm may charge a fee for stock and bond trades. We do not receive any compensation, in any form, from fund companies or brokerages. Investments may also include warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, U. S. government securities, and options contracts. Management of Conflicts of Interest between Clients Our relationship with you is non-exclusive; in other words, we provide investment management and advisory services to multiple clients. We seek to avoid situations in which one client’s interest may conflict with the interest of another of our clients. More information about this policy is found in your Client Agreement. Comparable Services 5  Tweddell Goldberg, LLC FORM ADV Part 2 A CRD Number: 141634 We believe that the charges and fees charged by brokers/custodians we use are competitive with alternative programs available through other firms offering a similar range of services; however, lower fees for comparable services may be available from other sources. Management of Conflicts of Interest Relating to the Fees We Receive, and Receipt of Percentage-Based Compensation. The vast majority of our clients pay us fees based upon a percentage of the assets we advise upon. This is a very common form of compensation for registered investment advisory firms and avoids the multiple inherent conflicts of interest associated with commission-based compensation (we do not accept commission-based compensation of any nature, nor do we accept 12b-1 fees). We endeavor at all times to properly manage potential conflicts of interest. Our goal is that our advice to you remains at all times in your best interests, disregarding any impact of the decision upon our firm. Each time such a potential conflict arises, we will give you notice, usually orally, of the conflict in that given situation if our advice regarding the proposed transaction would impact our compensation. Our Services are Tailored to Meet Your Needs and Investment Restrictions. In general, our advisory services are designed to meet your needs. While model portfolios may be utilized, each investment portfolio is individually tailored. If your circumstances change, it is the client’s responsibility to notify us. During any 12-month period, clients will communicate with us under normal circumstances. If there has been no contact(s), as appropriate, you will confer with us at least annually to review any changes to your financial situation, and your investment portfolio. After consultation with us, you may impose restrictions on investing in certain securities or types of securities. This most often occurs when you request certain social investment needs be addressed, such as through the use of mutual funds which avoid investments in certain companies. Other restrictions may be imposed by you with respect to the (average or longest) maturity or credit quality of fixed income investments. Our Agreement with you may not be assigned without your consent. WRAP Fee Programs The Firm does not participate in WRAP fee programs. Item 5: Fees and Compensation Item 5 A. We base our fees on a percentage of assets under management, and/or hourly charges. 6  Tweddell Goldberg, LLC FORM ADV Part 2 A CRD Number: 141634 Fees for investment management services are negotiable subject to a maximum of 1.00% per year. When negotiating the fee for portfolio management services, the Firm considered account size, complexity of services, client type, customization and personalization, and length of relationship. Lower fees for comparable services may be available from other sources. Item 5 B. Depending on the agreement made with clients, investment management fees are billed quarterly or semi-annually, in arrears or in advance, meaning that we invoice you for the three- or six-month billing period that has just ended or is beginning. Payment in full is expected upon invoice presentation. Fees are deducted from an account designated by you to facilitate billing or paid by check from the client. You must consent in advance to direct debiting of your investment account. We will send a statement to you showing the amount of the fee, the value of your assets upon which the fee was based, the time period covered by the fee, and the specific manner in which the fee was calculated. It is your responsibility to verify the accuracy of the fee calculation. The custodian will not determine whether the fee is properly calculated. We will send a bill to the custodian indicating only the amount of the fee to be paid. Hourly Planning Engagements We occasionally provide financial planning services for clients who need advice on a limited scope of work. The rate for limited scope engagements is negotiable. Hourly fees are at the rate of $275 per hour. The client pays this fee via check. Client agrees to pay TGI fees within thirty (30) days after the report is completed and available to the Client. For any financial planning services we may provide, we do not receive any fees or compensation from the sale of any securities, insurance, real estate, or other services recommended. Further, the client is under no obligation to act on our recommendations. If the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through our Firm. How Fees are Calculated Billing amounts are based upon the value (market value or fair market value in the absence of market value) of the client's account(s) (including both securities and cash) at the end of the previous quarter (or, for new clients, upon a date agreed to by us and you). Valuations are derived from recognized and independent pricing sources, such as Charles Schwab Institutional. Other Fees or Expenses Paid in Connection with Our Services 7  Tweddell Goldberg, LLC FORM ADV Part 2 A CRD Number: 141634 Item 5 C. All fees paid to us for investment advisory and management services are separate and distinct from the fees and expenses charged by mutual funds to their shareholders. Mutual fund expenses are described in each fund's prospectus. These expenses will generally include a management fee, other fund expenses, and possibly a distribution fee. In addition, mutual funds incur transaction costs and opportunity costs, which are not disclosed in the fund’s prospectus or Statement of Additional Information, but which may be estimated. You will incur transaction fees or charges but generally no commissions in connection with trading of mutual funds, ETFs, individual stock, and bonds (and/or principal mark-ups and mark-downs for principal trades), which are charged by the custodian (brokerage firm holding your assets for safekeeping). Mutual fund transaction fees charged by our recommended custodian, Charles Schwab Institutional, generally vary from $24 to $31 for each purchase and sale transaction. Costs for bond trades vary. Accordingly, you should review both the fees charged by the funds (including transaction and market-impact costs within funds which are not included in a fund’s annual expense ratio), the transaction fees charged by the custodian, as well as the fees charged by us, to fully understand the total amount of fees and costs paid by you, in connection with any recommended transaction. For a discussion of our practice in recommending brokers (custodians) to you and negotiating brokerage fees on your behalf, please see Item 12. You may also incur “account termination fees” upon the transfer of an account from one brokerage firm (custodian) to another. The range for these account termination fees is believed to range generally from $0 to $200 at present, but at times may be much higher. You should contact your custodians (brokerage firms, bank, or trust company, etc.) to determine the amount of account termination fees which may be charged and deducted from your accounts for any existing accounts which may be transferred. Cancellation and Termination of Agreements Item 5 D. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, with the refund calculations based pro rata to the date of termination. Termination of an agreement will not affect: (a) the validity of any action previously taken by us under the agreement; liabilities or obligations of the parties from transactions initiated before termination of the agreement; or your obligation to pay advisor fees (prorated through the date of termination). Upon the termination of the agreement, we will have no obligation to recommend or take any action with regard to the securities, cash, or other investments in your account. Item 5 E. Neither the Firm nor any of our supervised persons accepts compensation for the sale of securities or other investment products. Item 6: Performance-Based Fees and Side-By-Side Management Our fees are not based on a share of the capital gains or capital appreciation of managed securities. 8  Tweddell Goldberg, LLC FORM ADV Part 2 A CRD Number: 141634 We do not use a performance-based fee structure because of the potential conflict of interest. Performance-based compensation may create an incentive for the adviser to recommend an investment that may carry a higher degree of risk to you. Item 7: Types of Clients We provide investment advice primarily to individuals and their families, including high net worth individuals. The Firm does not have any requirements for opening or maintaining an account, such as a minimum account size. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss General We use a combination of fundamental and technical analysis to pick funds. We review data on Morningstar, interview fund managers and fund salespeople, consider what various market strategists are saying, and examine valuations. For REITs, we rely almost entirely on an outside research service. For individual stocks, we rely heavily on Morningstar research. The main sources of information include research services paid for by us, financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Methods of Analysis; Sources of Information Our security analysis is based upon a number of factors including those derived from securities rating services, general economic and market and financial information, due diligence reviews, and specific investment analyses that clients may request. The main sources of information include commercially available investment information and evaluation services, financial newspapers and journals, academic white papers, and periodicals. Prospectuses, statements of additional information, other issuer-prepared information, and data aggregation services are also utilized. Types of Investments Clients’ investment portfolios are typically invested in stock and bond mutual funds, individual stocks, real estate investment trusts, CD’s, and money market funds. Insurance products such as annuities and various types of life insurance products may also be evaluated. Recommendations may be made for you to invest in low-cost, no-load (no commission) variable or fixed deferred or immediate annuities when appropriate to your circumstances and tax situation. Your existing investments are evaluated in light of the desired investment policy objectives. We collaborate with you to develop a plan to transition from your existing portfolio to the desired portfolio. Investment advice may be offered on any investments held by you at the 9  Tweddell Goldberg, LLC FORM ADV Part 2 A CRD Number: 141634 start of the advisory relationship. Your portfolio holdings and strategic asset allocation are then monitored periodically, taking into account your cash flow needs. Review meetings with you are being held regarding your investment assets under management. Risk of Loss, Generally Investing in securities involves a risk of loss that you should be prepared to bear. The investment recommendations seek to limit risk through broad global diversification in equities (through broadly diversified stock mutual funds and/or stocks) investments in fixed income securities or diversified bond funds and commodity-based instruments. However, the investment methodology will still subject you to decline in the value of your portfolios, which can at times be dramatic. Investing is inherently uncertain as to future returns. While both macroeconomic and microeconomic risks are evaluated, for purposes of weighing risks and returns, there can be no assurance that we will get it right. While we seek to reduce non-compensated risks to which you may be exposed, other risks (including but not limited to the risk of a general stock market decline) may be assumed in order to seek to attain the client’s longer-term financial goals and objectives; however, we cannot provide any guarantee that the client’s goals and objectives will be achieved. More recently a new risk has materially affected markets: large-scale outbreaks of infectious diseases that can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries, and causing significant economic, social, and political disruption. Risk of Loss, Certain Higher-Risk Securities Certain securities recommended, such as emerging markets stock and bond funds and U.S. small cap value and mid cap value stock mutual funds possess higher levels of volatility than the overall stock market. We may employ these securities as part of an overall strategic asset allocation for you, and when such is undertaken, we possess a reasonable belief that the risk- return relationship for these securities will likely be beneficial to you over the long term. Cash Balances in Client Accounts Cash in your investment accounts are typically swept into the bank or money market mutual fund accounts of the institution (Charles Schwab). We discuss with you, during the time of review conferences and at other times, upcoming cash flow needs and seek to plan accordingly to meet those needs. While it is not our practice to encourage you to maintain a large amount of cash in your accounts, such may be undertaken at your request, to facilitate our billing of periodic fees, or for other reasons. Upon your request, cash balances will be maintained for temporary or short-term purposes. Item 9: Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events of their firm or certain management personnel which would be material to your evaluation of us or our integrity in management of your investment portfolio. 10  Tweddell Goldberg, LLC FORM ADV Part 2 A CRD Number: 141634 We have had no legal or disciplinary events to disclose. More specifically, neither the Firm nor any management person has been involved in any criminal or civil actions, administrative proceedings, or self-regulatory organization (SRO) proceedings. Item 10: Other Financial Industry Activities and Affiliations Financial Industry Activities We are not involved in any other financial industry activities. Neither the Firm nor any management person has an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. Neither the Firm nor any management person has an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. Affiliations We have no arrangements that are material to our advisory business or you with any other entity. Selection of Other Investment Advisers The Firm does not recommend or select other investment advisers. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Our Code of Ethics We have adopted a Code of Ethics, to which all investment advisor representatives and employees are bound to adhere. The key component of our Code of Ethics states: We and its investment advisor representatives and employees shall always:  Act in the best interests of each and every client;  Act with integrity and dignity when dealing with clients and prospective clients;  Seek at all times to preserve our firm's independence and to maintain our complete objectivity with respect to our advisory services and each recommendation made to our clients. We further adopted a detailed Code of Ethics expressing our commitment to ethical conduct, and which is utilized to guide our personal conduct. This detailed Code of Ethics describes our fiduciary duties and responsibilities to you and sets forth our practice of supervising the personal securities transactions of employees with prior or concurrent access to client trade information. 11  Tweddell Goldberg, LLC FORM ADV Part 2 A CRD Number: 141634 A copy of the Code of Ethics is available to you and prospects upon request. Conflicts of Interest We seek to avoid material conflicts of interest. Accordingly, we do not receive any third party direct monetary compensation (i.e., 12b-1 fees, or other fees) from brokerage firms (custodians) or mutual fund companies. The Firm does not recommend, buy or sell securities in which it has a material financial interest. Although we believe that our business methodologies, ethics rules, and adopted policies are appropriate to eliminate, or at least minimize, potential material conflicts of interest, and to manage appropriate any material conflicts of interest that may remain, you should be aware that no set of rules can possibly anticipate or relieve all potential material conflicts of interest. Please refer to the additional discussion under Item 12 Brokerage Practices. Participation or Interest in Client Transactions and Personal Trading Our Code of Ethics provides that individuals associated with our firm may buy or sell securities for their personal accounts identical or different than those recommended to you. However, it is the expressed policy of our firm that no person employed by the firm shall prefer his or her own interest to yours. To supervise compliance with the Code of Ethics, we require that anyone associated with this advisory practice and who possesses access to advisory recommendations (before or at the time they are entered into) (“access persons”) have his or her securities holdings reviewed annually, and transactions reviewed quarterly by our Chief Compliance Officer or his designee. We also require access persons to receive advance approval from our Chief Compliance Officer or his designee prior to investing in any initial public offerings or private placements, and with regard to trading of certain individual securities. The Code of Ethics further includes our policy prohibiting the use of material non-public information and protecting the confidentiality of client information. We require that all individuals act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. Any individual not in observance of the above may be subject to discipline. Item 12: Brokerage Practices Use of Brokerage Firms (Custodians), Generally We participate in the institutional advisor program offered by Charles Schwab & Co., Inc. Schwab Advisor Services is a division of Charles Schwab & Co., Inc. member FINRA/SIPC/NFA (“Charles Schwab”), an unaffiliated SEC-registered broker-dealer and 12  Tweddell Goldberg, LLC FORM ADV Part 2 A CRD Number: 141634 FINRA member. Charles Schwab offers to independent investment advisors services that include custody of securities, trade execution, clearance, and settlement of transactions. We receive some benefits from Charles Schwab through our participation in the Program. (Please see the disclosure under Item 14 below.) We also participate in the institutional advisor program offered by Fidelity National Financial and BNY Mellon Corporation. We recommend that you use Charles Schwab, Inc. ("Charles Schwab") as your broker. The services provided by Charles Schwab are a factor in our suggestion that you use Charles Schwab, whose services will ordinarily include monthly or at least quarterly account statements to you. Charles Schwab will also provide us with computer software services whereby we can place orders and obtain up to date review of your accounts. TGI does not receive referrals from broker-dealers. Discussion of Benefits to Adviser from Custodians We receive a benefit because we do not have to produce or pay for the research, products or services. The benefits provided by Charles Schwab also include assistance with practice management and assistance with the management of client accounts, including but not limited to: (a) receipt of duplicate client confirmations; (b) receipt of electronic duplicate statements; (c) access to a trading desk serving investment adviser firm participants exclusively, and providing research, pricing information, and other market data; (d) access to the investment advisor portion of their web sites which includes practice management articles, compliance updates, and other investment related information and research materials (including, for example, rating reports on individual companies from Standard and Poor’s or other sources); (e) access to other vendors (such as insurance or compliance providers, or providers of research or other materials) on a discounted fee basis through discounts arranged by the custodians; (f) permitting us to access an electronic communication network for client order entry and to access clients’ account information and which may otherwise assist us with its back-office functions, including recordkeeping and client reporting; and (g) conferences at which advisors and employees of our firms may attend (with no registration fees) and receive education on issues such as practice management, marketing, investment theory, financial planning, business succession, regulatory compliance, and information technology. Generally, many of these services may be utilized to service all or a substantial number of our clients’ accounts. Educational, research, or other services provided by custodians (i.e., Charles Schwab) or mutual fund companies may benefit all of our clients or may benefit only some clients. We may have an incentive to select or recommend a broker-dealer based on our interest in receiving the research or other products or services, rather than on your interest in receiving most favorable execution. Our Recommendations of Brokerage Firms You are permitted to direct us to utilize your desired brokers. However, if such brokers are utilized, we may not possess access to certain lower-cost mutual funds and other investments 13  Tweddell Goldberg, LLC FORM ADV Part 2 A CRD Number: 141634 that are generally available only to institutional investors or which would require a significantly higher minimum initial investment. While as a fiduciary, we endeavor to act in your best interests. Our desire that you maintain much of your assets in accounts at Charles Schwab may be based in part on the benefit to our firm of the availability of some products and services (previously described) at no cost to us, or at reduced costs, and not solely on the nature, cost, or quality of custody and brokerage services provided by the brokers; this may create a potential conflict of interest. Please note that we prefer to recommend custodians who possess significant size and financial resources. Additional factors of consideration include execution quality, commission rates, financial stability, access to market liquidity, and the range of services provided, including custody and reporting. We review whether the custodian’s compensation is reasonable in relation to the overall value of services received, not just the lowest possible cost. Best Execution We review the execution of trades at the custodian annually. Soft Dollars We do not receive any soft dollar benefits from broker/dealers acting as custodian for your accounts. Order Aggregation We may aggregate sales and purchases of securities for all client accounts and our employee accounts if, in our reasonable judgment, such aggregation will result in some overall economic benefit and/or no economic detriment to Client(s). In accounting for such aggregated transactions, prices will be averaged on a per unit basis daily, subject to minimum transaction charges that may be imposed by the account custodians. Any employee transaction will occur only after Client(s) orders are completed, or at the same time, or not on terms that would jeopardize the price received by Client(s). Most trades are mutual funds or exchange-traded funds where trade aggregation does not garner any client benefit. Item 13: Review of Accounts Portfolio reviews are performed by Jerold Tweddell and Peter Kendall. Portfolio Reviews: your portfolio for the assets held under management with us will be undertaken: (1) periodically; (2) upon request, and (3) during times of high market volatility, under adopted policies and procedures. Additional Portfolio Reviews: are undertaken upon your request, such as when special cash needs arise or when additional cash or securities are added to the investment portfolio. We will respond to such requests within a reasonable period of time. 14  Tweddell Goldberg, LLC FORM ADV Part 2 A CRD Number: 141634 We may also undertake sales and purchases during this time to effect tax loss harvesting, in addition to rebalancing actions. Financial Plans will be reviewed and updated upon request. Regular Reports Quarterly or Semi-Annual Reports written by include a more thorough analysis of your investment portfolio and its performance than the reports you receive from Charles Schwab. We may also offer periodic data for other investment accounts upon which we provide advice, not held at the foregoing custodians, if such information can be obtained from our account aggregation services, and provided your consent is obtained to furnish such account aggregation service with any account passwords required to access account information. While we are hopeful that the information supplied by custodians and data aggregation services is reliable, we cannot guarantee its accuracy. Clients may also directly access account information at the custodians with which the accounts are held online (Charles Schwab) virtually anytime via the secure web site. Monthly or Quarterly Statements Directly from Account Custodians are sent to you directly from the corresponding brokers and mutual funds which hold your investments. These statements reflect the assets in the custodian’s custody, together with confirmations of each transaction executed in the account(s). For some custodians, you may elect to receive these statements by e-mail rather than U.S. mail. You are strongly encouraged to compare the monthly or quarterly statements you receive from custodians with the written reports you receive from us. Despite the best efforts of any firm to safeguard client’s assets, fraud could still occur. While we hope that you trust our firm, and we have never had an instance of theft of client funds, we believe it is nevertheless important for you to verify your investment holdings. Item 14: Payment for Client Referrals and Other Compensation The Firm does not directly or indirectly compensate any person who is not a supervised person for client referrals. No person who is not a client provides an economic benefit to the Firm for providing investment advice or other advisory services to clients. As referenced in Item 12, we do receive economic benefits from Charles Schwab & Co., Inc. (“Schwab”) through our participation in the Schwab Advisor Services institutional program. Schwab provides independent investment advisors with services that include custody of securities, trade execution, clearance, and settlement of transactions. These benefits are not based on the number of client accounts or assets maintained at Schwab, but they may include access to certain tools and services intended to support our firm in managing client accounts. Schwab is an unaffiliated SEC-registered broker-dealer. 15  Tweddell Goldberg, LLC FORM ADV Part 2 A CRD Number: 141634 Item 15: Custody Custody – Fee Debiting Clients may authorize us to debit fees directly from their account at the broker dealer, bank or other qualified custodian (“custodian”). The custodian is advised in writing of the limitation of our access to the account. The custodian sends a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of advisory fees paid directly to the Firm. Some states consider direct fee debiting a form of constructive custody, therefore the Firm is considered to have custody but maintains the below safeguards to avoid a surprise exam. Custody – First Party Money Transfers Clients may provide us with written ongoing authorization to wire money between the client’s accounts held with the custodian directly to an outside financial institution (i.e., a client’s bank account). A copy of this authorization is provided to the custodian. The authorization includes the client’s account number(s) at the outside financial institution(s) as required. Custody – Third Party Money Transfers & SLOAs Clients may provide us with a standing letter of authorization (SLOA) (or similar asset transfer authorization) which allows us to disburse funds on behalf of clients to third parties. We ensure the following conditions/safeguards are in place when deemed to have custody via third party money movement: The client provides a Written Authorization to the custodian that includes all 1. appropriate information as to how the transfer should be directed; The Written Authorization includes instruction to direct transfers to the third party 2. either on a specified schedule or from time to time; 3. Appropriate verification is performed by the custodian, along with a transfer of funds notice to the client promptly after each transfer; 4. The client may terminate or change the instruction to the custodian; 5. We have no authority or ability to designate or change any information about the third party contained in the instruction; 6. We maintain records showing that the third party is not a related party of the Firm or located at the same address as the Firm; and The custodian sends the client a written initial notice confirming the instruction and an 7. annual written confirmation thereafter. Custody – Account Statements 16  Tweddell Goldberg, LLC FORM ADV Part 2 A CRD Number: 141634 Clients receive at least quarterly statements from the custodian that holds and maintains client’s investment assets. Clients are urged to carefully review such statements and compare such official custodial records to the reports that we provide. Our reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. In addition, Clients should understand that it is their responsibility, not the custodian’s, to ensure that the fee calculation is correct. If Client funds or securities are inadvertently received by our Firm, they will be returned to the sender immediately, or as soon as practical. Certain states take the position that Firms that directly deduct fees from client accounts (authority to make withdrawals from client accounts to pay its advisory fee) are deemed to have custody of client assets; however, the Firm is not required to comply with the surprise examination, net capital, bonding, or audit requirements of said state due to the following safeguards the Firm has put in place. 1. the adviser has written authorization from the client to deduct advisory fees from the account held with a qualified custodian; 2. each time a fee is directly deducted from a client’s account, the adviser concurrently a. sends the qualified custodian notice of the amount of the fee to be deducted from the client's account, and b. sends the client an invoice itemizing the fee including the formula used to calculate the fee, the amount of assets under management upon which the fee is based, and the time period covered by the fee; The custodian sends statements, on at least a quarterly basis, to your client showing all disbursements for the custodian account, including the amount of the advisory fees. We encourage our clients to raise any questions with us about the custody, safety, or security of their assets. The custodians we do business with will send you independent account statements listing your account balance(s), transaction history and any fee debits or other fees taken out of your account. Item 16: Investment Discretion We accept limited forms of discretion over your accounts, as follows, with your consent. Your grant of discretion is evidenced in the client services agreement (or addendums thereto) signed by you and is further evidenced by the custodians through a limited power of attorney contained in the account establishment form signed by you or a separate limited power of attorney document signed by you. You approve the custodian to be used, and the commission rates paid to the custodian. We do not receive any portion of the transaction fees or other charges paid by you to the custodian on certain trades. You may limit our investment selection universe to socially responsible investments. 17  Tweddell Goldberg, LLC FORM ADV Part 2 A CRD Number: 141634 Item 17: Voting Client Securities As a matter of firm policy and practice, we do not accept authority to vote proxies on your behalf. You retain the responsibility for receiving and voting proxies for any and all securities maintained in your portfolios. Generally, you will receive their proxies or other solicitations directly from the custodian or transfer agent. However, you may call or e-mail us with questions regarding a particular proxy or other solicitation, and we may provide advice to you regarding your voting of proxies or such solicitations, upon your request. You should note that we will not advise nor act on your behalf in legal proceedings involving companies whose securities are held or previously were held in your account(s), including, but not limited to, the filing of “Proofs of Claim” in class action settlements. If desired, you may direct us to transmit copies of class action notices to you or a third party. Upon such direction, we will make commercially reasonable efforts to forward such notices in a timely manner. Item 18: Financial Information Tweddell Goldberg, LLC does not require or solicit prepayment of more than $500 in fees per Client, six months or more in advance and therefore is not required to provide, and has not provided, a balance sheet. Tweddell Goldberg, LLC does not have any financial commitments that impair its ability to meet contractual and fiduciary obligations to Clients and has not been the subject of a bankruptcy proceeding. 18  Tweddell Goldberg, LLC FORM ADV Part 2 A CRD Number: 141634 Item 19: Requirements for State Registered Advisers Educational Background and Business Experience of Principal Officer(s) The Firm’s principal officers include Jerry Twedell, CEO and CCO, and Peter Kendall, President. Clients can refer to Part 2B of Form ADV - Investment Adviser Brochure Supplement for their formal education and business background. Other Business Activities of Principal Officer(s) Neither the Firm nor any principal officers are actively engaged in any business other than giving investment advice. See response to Form ADV Part 2A, Item 10 – Other Financial Industry Activities and Affiliations. Performance-Based Fees Neither the Firm nor any employees are compensated by performance-based fees. Disciplinary Information and Disclosures Neither the Firm nor a management person has been involved in any arbitration claim, civil, self-regulatory organization, or administrative proceeding. Material Relationships with Issuers of Securities Neither the Firm nor any employees have any relationships or arrangements with any issuer of securities. California Code of Regulations Section 260.238(k) provides that failing to disclose to a client in writing before entering or renewing an advisory agreement with that client any material conflicts of interest regarding the investment adviser, its representatives or any of its employees, which could be reasonably expected to impair the rendering of unbiased and objective advice does not promote ''fair, equitable or ethical principles.'', thus any material conflicts of interest have been disclosed Privacy Notice We are committed to maintaining the confidentiality, integrity and security of the personal information that is entrusted to us. The categories of nonpublic information that we collect from you may include information about your personal finances, information about your health to the extent that it is needed for the financial planning process and information about transactions between you and third parties, We use this information solely to help you meet your personal financial goals. With your permission, we disclose limited information to attorneys, accountants, and mortgage lenders with whom you have established a relationship. You may opt out from our sharing information with these nonaffiliated third parties by notifying us at any time by 19  Tweddell Goldberg, LLC FORM ADV Part 2 A CRD Number: 141634 telephone, mail, fax, email, or in person. With your permission, we share a limited amount of information about you with your brokerage firm in order to execute securities transactions on your behalf. We maintain a secure office to ensure that your information is not placed at unreasonable risk. We employ a firewall barrier, secure data encryption techniques and authentication procedures in our computer environment. We do not provide your personal information to mailing list vendors or solicitors. We require strict confidentiality in our agreements with unaffiliated third parties that require access to your personal information, including financial service companies, consultants, and auditors. Federal and state securities regulators may review our Company records, and your personal records as permitted by law. Personally identifiable information about you will be maintained while you are a client, and for the required period thereafter that records are required to be maintained by federal and state securities laws. After that time, the information will be destroyed. We will notify you in advance if our privacy policy is expected to change. 20