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Form ADV Part 2A – Firm Brochure
Item 1 – Cover Page
Warner Financial, Inc.
4550 Montgomery Avenue, Suite 352N
Bethesda, MD 20814
301-961-9505
www.warner-financial.com
Date of Brochure: February 9, 2026
Barbara Warner
Chief Compliance Officer
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_
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This brochure provides information about the qualifications and business practices of Warner Financial,
Inc. If you have any questions about the contents of this brochure, please contact us at 301-961-9505.
The information in this brochure has not been approved or verified by the United States Securities and
Exchange Commission or by any state securities authority.
Additional information about Warner Financial, Inc. is also available on the Internet at
www.adviserinfo.sec.gov. You can view the firm’s information on this website by searching for Warner
Financial (SEC#:801-64223). You may search for information by using Warner Financial’s name or by
using Warner Financial’s CRD number. The CRD number for Warner Financial is 135303.
*Registration as an investment advisor does not imply a certain level of skill or training.
Warner Financial, Inc.
Disclosure Brochure
Item 2 – Material Changes
There have been no material amendments since the filing of our last annual amendment on March
4, 2025.
ANY QUESTIONS: Warner Financial’s Chief Compliance Officer, Barbara Warner, remains
available to address any questions regarding this Part 2A, including the disclosure
additions and enhancements below.
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Item 3 – Table of Contents
Item 1 – Cover Page ...................................................................................................................................... 1
Item 2 – Material Changes ............................................................................................................................ 2
Item 3 – Table of Contents ............................................................................................................................ 3
Item 4 – Advisory Business ........................................................................................................................... 4
Item 5 – Fees and Compensation ................................................................................................................. 9
Item 6 – Performance-Based Fees and Side-By-Side Management ........................................................... 10
Item 7 – Types of Clients ............................................................................................................................. 10
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ...................................................... 11
Item 9 – Disciplinary Information ................................................................................................................. 12
Item 10 – Other Financial Industry Activities and Affiliations ....................................................................... 12
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading ................................ 12
Item 12 – Brokerage Practices .................................................................................................................... 13
Item 13 – Review of Accounts ..................................................................................................................... 15
Item 14 – Client Referrals and Other Compensation ................................................................................... 15
Item 15 – Custody ....................................................................................................................................... 16
Item 16 – Investment Discretion .................................................................................................................. 16
Item 17 – Voting Client Securities ............................................................................................................... 16
Item 18 – Financial Information ................................................................................................................... 16
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Item 4 – Advisory Business
A. Warner Financial, Inc. (“Warner Financial”) is an investment advisor registered with the United States
Securities and Exchange Commission (“SEC”). Our company is a corporation formed under the laws of
the State of Delaware and located in Bethesda, Maryland and has been registered as an investment
adviser since April, 2005
• The firm is owned by Barbara Warner and Christopher Warner.
• We provide fee-based investment advisory services through Warner Financial. The nature and extent
of the specific services provided to Clients, including you, will always depend on each Client’s financial
status, objectives and needs, time horizons, concerns, expectations and risk tolerance.
B. General Description of Primary Advisory Services
The following are brief descriptions of Warner Financial’s primary services. A detailed description of our
services is provided in Item 5 – Fees and Compensation so that Clients and prospective Clients can
review the services and fees.
Financial Planning: To the extent requested to do so, we offer to provide financial planning and related
consulting services to Clients, which services are generally offered in connection with our asset
management services. Financial planning services do not involve the active management of Client
accounts, but instead focus on a Client’s overall financial situation. Financial planning can be described as
helping individuals determine and set their long-term financial goals, through investments, tax planning,
asset allocation, risk management, retirement planning, and other areas. The role of a financial planner is
to find ways to help the Client understand his/her overall financial situation and help the Client set financial
objectives.
Asset Management Services: This is the primary service we offer and most Clients receiving this
Disclosure Brochure will be retaining us for Asset Management Services. The service involves providing
Clients with continuous and on-going supervision over investment accounts. This means that we will
continuously monitor a Client’s account and make trades in Client accounts when necessary.
The Client can determine to engage to receive discretionary and/or non-discretionary investment advisory
services on a fee-only basis. Unless the Client and Warner Financial agree to a fixed-fee arrangement,
Warner Financial’s annual investment advisory fee is based upon a percentage (%) of the market value of
the assets placed under Warner Financial’s management. Prior to engaging to provide investment advisory
services, Clients are required to enter into an Investment Advisory Agreement with Warner Financial setting
forth the terms and conditions of the engagement (including termination), describing the scope of the
services to be provided, and the fee that is due from the Client.
Warner Financial provides investment advisory services specific to the needs of each Client. Before
providing investment advisory services, an investment adviser representative will ascertain each Client’s
investment objectives. Thereafter, Warner Financial will allocate and/or recommend that the Client
allocate investment assets consistent with the designated investment objectives. Once allocated,
Warner Financial provides ongoing monitoring and review of account performance and asset allocation
as compared to Client investment objectives.
When providing Asset Management Services, we typically construct each Client’s account holdings
using no-load mutual funds and ETFs to build diversified portfolios. We do not typically attempt to time
the market but we may increase cash holdings modestly as deemed appropriate, based on your risk
tolerance and our expectations of market behavior. In addition to our investment advisory fees and
transaction and/or custodial fees discussed below, Clients will also incur, relative to all mutual fund and
exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other
fund expenses).
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Retirement Rollovers-Potential for Conflict of Interest: A Client or prospective Client leaving an
employer typically has four options regarding an existing retirement plan (and may engage in a
combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll
over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over
to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending
upon the Client’s age, result in adverse tax consequences). If we recommend that a Client roll over their
retirement plan assets into an account to be managed by us, such a recommendation creates a conflict
of interest if we will earn new (or increase our current) compensation as a result of the rollover. If Warner
Financial provides a recommendation as to whether a Client should engage in a rollover or not (whether
it is from an employer’s plan or an existing IRA), Warner Financial is acting as a fiduciary within the
meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code,
as applicable, which are laws governing retirement accounts. No Client is under any obligation to roll
over retirement plan assets to an account managed by us, whether it is from an employer’s plan or an
existing IRA . Our Chief Compliance Officer, Barbara Warner, remains available to address any
questions that a Client or prospective Client may have regarding the potential for conflict of
interest presented by such rollover recommendation.
Limitations of Financial Planning and Non-Investment Consulting/Implementation Services: To the
extent requested, Warner Financial will generally provide limited planning and consulting services
regarding non-investment related matters, such as tax and estate planning, insurance, etc. The services
will be provided inclusive of its advisory fee set forth at Item 5 below. Exceptions to the stated advisory
fee may occur based upon assets under management, advanced planning needs, preparation of a
comprehensive financial plan, special projects, etc. for which Warner Financial can charge a mutually
agreeable additional fee and/or enter into stand-alone financial planning engagement. Warner Financial
believes that it is important for the Client to address financial planning issues on an ongoing basis.
Warner’s advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not
the Client determines to address financial planning issues with Warner Financial. Warner Financial does
not serve as an attorney, accountant, or insurance agent, and no portion of our services should be
construed as same. Accordingly, Warner Financial does not prepare estate planning or any other type
of legal documents, prepare tax returns, or sell insurance products. To the extent requested by a Client,
we may recommend the services of other professionals for certain non-investment implementation
purposes (i.e. attorneys, accountants, insurance agents, etc.). The Client is under no obligation to engage
the services of any such recommended professional. The Client retains absolute discretion over all such
implementation decisions and is free to accept or reject any of our recommendations. Neither Warner
Financial, nor its investment adviser representatives, assist Clients with the implementation of any financial
plan, unless they have agreed to do so in writing. In addition, Warner Financial does not monitor a Client’s
financial plan, and it is the Client’s responsibility to revisit the financial plan with Warner Financial, if desired.
If the Client engages any recommended unaffiliated professional, and a dispute arises thereafter relative
to such engagement, the Client agrees to seek recourse exclusively from and against the engaged
professional. If, and when Warner Financial is involved in a specific matter (i.e. estate planning, insurance,
accounting-related engagement, etc.), it is the engaged licensed professionals (i.e. attorney, accountant,
insurance agent, etc.), and not Warner Financial, that is responsible for the quality and competency of the
services provided.
Our Chief Compliance Officer, Barbara Warner, remains available to address any questions that
a Client or prospective Client may have regarding the above conflict of interest.
Cash Positions. Warner Financial continues to treat cash as an asset class. As such, unless
determined to the contrary by Warner Financial, all cash positions (money markets, etc.) shall continue
to be included as part of assets under management for purposes of calculating Warner Financial’s
advisory fee. At any specific point in time, depending upon perceived or anticipated market
conditions/events (there being no guarantee that such anticipated market conditions/events will occur),
Warner Financial may maintain cash positions for defensive purposes. In addition, while assets are
maintained in cash, such amounts could miss market advances. Depending upon current yields, at any
point in time, Warner Financial’s advisory fee could exceed the interest paid by the Client’s money
market fund.
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Charles Schwab & Co., Inc.: As discussed below at Item 12, unless the Client directs otherwise, Warner
Financial shall generally recommend that Charles Schwab & Co., Inc. (“Schwab”) serve as the broker-
dealer/custodian for Client investment management assets. Broker-dealers such as Schwab charge
brokerage commissions, transaction, and/or other type fees for effecting certain types of securities
transactions (i.e., including transaction fees for certain mutual funds, dealer spreads and mark-ups and
mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees,
commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the
broker-dealer/custodian (while certain custodians, including Schwab, do not currently charge fees on
individual equity transactions, others do). Broker-dealers such as Schwab charge transaction fees for
effecting some mutual fund transactions. In addition to Warner Financial’s investment management fee as
described at Item 5 below, and transaction fees, Clients will also incur, relative to all mutual fund and
exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other
fund expenses). Warner Financial does not receive any portion of these fees/charges.
However, Schwab (as do its primary competitors that provide similar pricing arrangements) require that
cash proceeds to be automatically swept into a Schwab proprietary or affiliated money market mutual funds
or cash sweeps accounts, which proprietary/affiliated Schwab funds/accounts do not provide the highest
return available.
Cybersecurity Risk. The information technology systems and networks that Warner Financial and its third-
party service providers use to provide services to Warner Financial’s Clients employ various controls that
are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that
could cause significant interruptions in Warner Financial’s operations and/or result in the unauthorized
acquisition or use of Clients’ confidential or non-public personal information. In accordance with Regulation
S-P, Warner Financial is committed to protecting the privacy and security of its Clients' non-public personal
information by implementing appropriate administrative, technical, and physical safeguards. Warner
Financial has established processes to mitigate the risks of cybersecurity incidents, including the
requirement to restrict access to such sensitive data and to monitor its systems for potential breaches.
Clients and Warner Financial are nonetheless subject to the risk of cybersecurity incidents that could
ultimately cause them to incur financial losses and/or other adverse consequences. Although Warner
Financial has established processes to reduce the risk of cybersecurity incidents, there is no guarantee
that these efforts will always be successful, especially considering that Warner Financial does not control
the cybersecurity measures and policies employed by third-party service providers, issuers of securities,
broker-dealers, qualified custodians, governmental and other regulatory authorities, exchanges, and other
financial market operators and providers. In compliance with Regulation S-P, Warner Financial will notify
Clients in the event of a data breach involving their non-public personal information as required by
applicable state and federal laws.
Borrowing Against Assets/Risks. A Client who has a need to borrow money could determine to do so
by using:
• Margin-The account custodian or broker-dealer lends money to the Client. The custodian charges the
Client interest for the right to borrow money, and uses the assets in the Client’s brokerage account as
collateral; and,
Pledged Assets Loan- In consideration for a lender (i.e., a bank, etc.) to make a loan to the Client,
the Client pledges investment assets held at the account custodian as collateral
These above-described collateralized loans are generally utilized because they typically provide more
favorable interest rates than standard commercial loans. These types of collateralized loans can assist
with a pending home purchase, permit the retirement of more expensive debt, or enable borrowing in lieu
of liquidating existing account positions and incurring capital gains taxes. However, such loans are not
without potential material risk to the Client’s investment assets. The lender (i.e. custodian, bank, etc.) will
have recourse against the Client’s investment assets in the event of loan default or if the assets fall below
a certain level. For this reason, Warner Financial does not recommend such borrowing unless it is for
specific short-term purposes (i.e. a bridge loan to purchase a new residence). Warner Financial does not
recommend such borrowing for investment purposes (i.e. to invest borrowed funds in the market).
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Regardless, if the Client were to decide to utilize margin or a pledged assets loan, Warner Financial would
receive an economic benefit because we would continue to earn a fee on the pledged assets
Socially Responsible (ESG) Investing Limitations. Socially Responsible Investing involves the
incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due
diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential
investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the
manner in which a company manages relationships with its employees, customers, and the communities
in which it operates); and Governance (i.e., company management considerations). The number of
companies that meet an acceptable ESG mandate can be limited when compared to those that do not,
and could underperform broad market indices. Investors must accept these limitations, including potential
for underperformance. Correspondingly, the number of ESG mutual funds and exchange-traded funds are
limited when compared to those that do not maintain such a mandate. As with any type of investment
(including any investment and/or investment strategies recommended and/or undertaken by Warner
Financial), there can be no assurance that investment in ESG securities or funds will be profitable, or prove
successful. Warner Financial does not maintain or advocate an ESG investment strategy, but will seek to
employ ESG if directed by a Client to do so. If implemented, Warner Financial shall rely upon the
assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account
portfolio manager to determine that the fund’s or portfolio’s underlying company securities meet a socially
responsible mandate
Bitcoin, Cryptocurrency, and Digital Assets: . For Clients who have indicated to Warner Financial that
they want exposure to Bitcoin, cryptocurrencies, or digital assets, Warner Financial will advise the Client
to consider a potential investment in corresponding exchange traded securities, or an allocation to separate
account managers and/or private funds that provide cryptocurrency exposure. Bitcoin and cryptocurrencies
are digital assets that can be used for various purposes, including transactions, decentralized applications,
and speculative investments. Most digital assets use blockchain technology, an advanced cryptographic
digital ledger to secure transactions and validate asset ownership. Unlike conventional currencies issued
and regulated by monetary authorities, cryptocurrencies generally operate without centralized control, and
their value is determined by market supply and demand. While regulatory oversight of digital assets has
evolved significantly since their inception, they remain subject to variable regulatory treatment globally,
which may impact their risk profile and liquidity. Given that cryptocurrency investments are speculative and
subject to extreme price volatility, liquidity constraints, and the potential for total loss of principal, Warner
Financial does not exercise discretionary authority to purchase cryptocurrency investments for Client
accounts. Any investment in cryptocurrencies must be expressly authorized by the Client. Warner Financial
does not recommend or advocate for the purchase of, or investment in, Bitcoin, cryptocurrencies, or digital
assets. Such investments are considered speculative and carry significant risk. Clients who authorize the
purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints,
extreme price volatility, regulatory risk, technological risk, security and custody risk, and complete loss of
principal.
Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account
transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated
sweep account. The yield on the sweep account will generally be lower than those available for other
money market accounts. When this occurs, to help mitigate the corresponding yield dispersion, Warner
Financial shall generally (with exceptions) purchase a higher yielding money market fund (or other type
security) available on the custodian’s platform, unless Warner Financial reasonably anticipates that it will
utilize the cash proceeds in the near future to purchase additional investments for the Client’s account.
Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for
various reasons, including, but not limited to the amount of dispersion between the sweep account and a
money market fund, the size of the cash balance, an indication from the Client of an imminent need for
such cash, or the Client has a demonstrated history of writing checks from the account. The Client shall
remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions
for cash balances maintained in any Warner Financial unmanaged accounts.
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Non-Discretionary Service Limitations: Clients that determine to engage Warner Financial on a non-
discretionary investment advisory basis acknowledge that Warner Financial cannot effect any account
transactions without obtaining prior consent to any such transaction(s) from the Client. Thus, in the event
that Warner Financial would like to make a transaction for a Client's account (including in the event of
an individual holding or general market correction), and the Client is unavailable, Warner Financial will
be unable to effect the account transaction(s) (as it would for its discretionary Clients) without first
obtaining the Client’s consent.
Client Obligations: In performing its services, Warner Financial shall not be required to verify any
information received from the Client or from the Client’s other professionals, and is expressly authorized
to rely thereon. Moreover, each Client is advised that it remains their responsibility to promptly notify
Warner Financial if there is ever any change in his/her/its financial situation or investment objectives for
the purpose of reviewing, evaluating, or revising Warner Financial’s previous recommendations and/or
services.
Disclosure Statement: A copy of Warner Financial’s written Brochure as set forth on Part 2 of Form
ADV, along with Form CRS, shall be provided to each Client prior to, or contemporaneously with, the
execution of the applicable form of agreement between Warner Financial and the Client.
limited
to,
investment performance,
fund manager
Portfolio Activity: Warner Financial has a fiduciary duty to provide services consistent with the Client’s
best interest. As part of its investment advisory services, Warner Financial will review Client portfolios
on an ongoing basis to determine if any changes are necessary based upon various factors, including,
tenure, style drift, account
but not
additions/withdrawals, and/or a change in the Client’s investment objective. Based upon these factors,
there may be extended periods of time when Warner Financial determines that changes to a Client’s
portfolio are neither necessary nor prudent. Of course, as indicated below at Item 8, there can be no
assurance that investment decisions made by Warner Financial will be profitable or equal any specific
performance level(s). Clients nonetheless remain subject to the fees described in Item 5 below during
periods of account inactivity.
Trustee-Directed Plans: Warner Financial may be engaged to provide discretionary investment
advisory services to ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with
the investment objective designated by the Plan trustees. In such engagements, Warner Financial will
serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security
Act of 1974 (“ERISA”). Warner Financial will generally provide services on an “assets under
management” fee basis per the terms and conditions of an Investment Advisory Agreement between the
Plan and the Firm.
C. Tailor Advisory Services to Individual Needs of Clients
Our services are always provided based on the individual needs of the individual Client. You are able to
impose restrictions on your accounts including specific investment selections and sectors. We work with
you on a one-on-one basis through interviews and meetings to determine your investment objectives
and suitability information. If you transfer a portfolio to us that has existing assets and tax consequences
if those are sold, we will take that into account in the construction of your portfolio.
D. Warner Financial does not participate in any wrap programs.
E. Client Assets Managed by Warner Financial
The amount of Clients’ assets managed by our firm totaled $851,810,607 as of December 31, 2025.
$840,784,820 is managed on a discretionary basis and $11,025,787 is managed on a non-discretionary
basis (please refer to Item 16 – Investment Discretion for more details regarding discretionary and non-
discretionary services).
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Item 5 – Fees and Compensation
In addition to the information provided in Item 4 – Advisory Business, this section provides details regarding
our services along with descriptions of each service’s fees and compensation arrangements.
A. Description of Compensation
1. Asset Management Services
Warner Financial provides discretionary investment or non-discretionary advisory services on a fee-
only basis, including ongoing advice, management and performance reporting on a specified
portfolio of assets. These services are typically provided for fees based on a percentage of assets
under management. Annual fees are divided and billed quarterly. Fees are negotiable. Our advice
is based upon the financial objectives and risk tolerance of the Client, following thorough interviews
by our employees. Because we are always striving to help Clients achieve their personal objectives,
we will also devote attention to financial planning issues that arise over the course of our
engagement at the Client’s request, covered by the asset management fee.
Warner Financial will be granted trading authorization over the Client’s account(s) on either a
discretionary or non-discretionary basis. See Item 16 of this Brochure for more information regarding
our policy related to discretion.
As discussed below, unless the Client directs otherwise or an individual Client’s circumstances
require, Warner Financial shall generally recommend that Charles Schwab serve as the broker-
dealer/custodian for Client investment management assets. Broker-dealers such as Schwab charge
transaction fees for effecting certain securities transactions (i.e. transaction fees are charged for
certain no-load mutual funds). In addition to Warner Financial’s investment management fee, and
transaction fees, Clients will also incur, relative to all mutual fund and exchange traded fund
purchases, charges imposed at the fund level (e.g. management fees and other fund expenses).
Fees payable for investment management services will be a percentage of the total value of the
account. The maximum fee schedule is as follows:
• 0.90% of the first $250,000
• 0.85% of the next $750,000
• 0.75% from $1 million to $3 million
• 0.65% from $3-million to $5 million
• 0.50% above $5 million
Fee Dispersion: Warner Financial’s investment advisory fee is negotiable at its discretion, depending
upon objective and subjective factors including but not limited to: the amount of assets to be
managed; portfolio composition; the scope and complexity of the engagement; the anticipated
number of meetings and servicing needs; related accounts; future earning capacity; anticipated
future additional assets; prior relationships with Warner Financial and/or its representatives,
competition, and negotiations with the Client. As a result of these factors, similarly situated Clients
could pay different fees, the services to be provided by Warner Financial to any particular Client
could be available from other advisers at lower fees, and certain Clients may have fees different than
those specifically set forth above. Warner Financial’s Chief Compliance Officer, Barbara Warner,
remains available to address any questions that a Client or prospective Client may have
regarding the above fee determination.
B. Ongoing quarterly fees are payable in advance. The fee for the first quarter shall be based on the market
value on the date the asset management agreement is signed. Fees will be calculated quarterly based
on the market value of the assets under management at the end of the preceding quarter. No pro-rata
adjustments are made for assets added to or withdrawn from the account during a quarter, unless the
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Client consents. Upon termination of the account a refund of fees will be pro-rated based on the number
of days remaining during the quarter after the date of effective termination.
Fees are deducted directly from the Client’s account. Clients must provide the custodian with written
authorization to have fees deducted from the account and paid to Warner Financial. The custodian will
send Client statements, at least quarterly, showing all disbursements for the account including the
amount of the advisory fee, if deducted directly from the account. Schwab will assist Warner Financial
with the automatic deduction of the quarterly fee. It is Warner Financial and Client’s responsibility to
verify the accuracy of Warner Financial’s fee and the qualified custodian will not determine whether the
fee has been properly calculated. Upon approval from Warner Financial, Clients may pay fees via direct
invoice. For Clients paying via invoice, fees shall be due upon Client’s receipt of the invoice.
C. Client accounts will also be charged all applicable transaction costs charged by Schwab. Management
fees charged by Warner Financial are separate and distinct from the fees and expenses charged by
investment company securities that may be recommended to Clients. A description of these fees and
expenses are available in each investment company security’s prospectus.
D. Any investment management agreement may be terminated by the Client without penalty upon delivery
of written notification to Warner Financial within five business days after the date of the Client’s execution
of the agreement. After this initial five-day period has elapsed, either party may terminate the contract
upon 30 days’ written notice. All fees paid by the Client will be promptly refunded if the investment
management agreement is terminated during the initial five-day period. After the initial five-day period,
any unearned portion of pre-paid advisory fees will be refunded to the Client within 60 days of the receipt
of that notice.
E. Neither Warner Financial, nor its representatives accept compensation from the sale of securities or
other investment products.
Item 6 – Performance-Based Fees and Side-By-Side Management
Item 6 of the Form ADV Part 2 instructions is not applicable to Warner Financial’s brochure because we
never charge or accept performance-based fees. Performance-based fees are defined as fees based on a
share of capital gains on or capital appreciation of the assets held within a Client’s account.
Item 7 – Types of Clients
Warner Financial generally provides investment advice to the following types of Clients.
Individuals (including Trusts and Estates)
•
• High-Net Worth Individuals
• Pension and profit sharing plans
• Charitable Organizations
All Clients are required to execute an agreement for services in order to establish a Client arrangement with
Warner Financial.
Minimum Investment Amounts Required: Warner Financial typically requires an initial minimum
investment amount of $1,000,000 for its Asset Management Services. Warner Financial, in its sole discretion,
may waive its portfolio minimum, charge a lesser investment advisory fee and/or charge a flat fee based upon
certain criteria (i.e. anticipated future earning capacity, anticipated future additional assets, dollar amount of
assets to be managed, related accounts, account composition, competition, negotiations with Client, etc.). As
result of the above, similarly situated Clients could pay different fees. In addition, similar advisory services
may be available from other investment advisers for similar or lower fees.
ANY QUESTIONS: Warner Financial’s Chief Compliance Officer, Barbara Warner, remains available
to address any questions that a Client or prospective Client may have regarding advisory fees.
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Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. As investment advisors with a fiduciary responsibility to put Clients’ interests above our own, our
approach is to provide investment advice that is independent, objective, skillful and customized. Using
a top-down approach and our understanding of the relationship between asset classes, the economic
environment and market cycles, we develop portfolios that are (1) intended to achieve a Client’s
objectives, and (2) diversified to accommodate our perception of the Client’s tolerance for risk. Using
research supplied by institutional managers and economists, academic and professional journals,
software programs that statistically model future returns, and rating services such as Morningstar, we
recommend an appropriate allocation of assets for a Client, and then select particular securities to satisfy
the allocation.
We incorporate variables into the analysis such as Clients’ ages, capacity to accumulate assets,
proximity to retirement (or to other goals such as college education), spending patterns, liquidity or
illiquidity of assets, likelihood of inheritance or, conversely, chance that assets will need to be devoted
to care of other family members. When possible, we try to assess how Clients behaved in prior market
downturns, and discern whether they are knowledgeable about asset classes, expected returns and
market cycles.
We construct portfolios that are diversified as to the types, maturity and quality of fixed income funds,
and we choose equities of varying market capitalizations, valuations styles (value and growth),
developed and emerging global locations, and management style (passive funds and actively managed
funds.) We are highly attentive to the cost of our portfolios and the tax consequences of the activity in
our accounts, and attempt to produce the highest quality portfolios at reasonable cost.
We measure the success of our portfolios according to whether they allow Clients to achieve particular
objectives. We do not claim to be able to “beat the market,” but rather to develop and monitor portfolios
that allow Clients to be successful without taking unnecessary risks. A properly diversified portfolio is
often unlikely to beat a single benchmark, such as the commonly used S&P 500 Index. Some assets in
a portfolio, whose characteristics are unlike the large cap S&P stocks, will produce returns that are better
or worse than the S&P, so Clients have the risk that the average annual return of a complex portfolio will
be very different from a single benchmark.
We also do not “time” the market, nor make predictions about the directions of stock and bond markets,
so a Client runs the risk that the portfolio may be invested during a downturn in the markets. Depending
on economic changes or periods of unusual volatility, we may adjust and rebalance a Client’s portfolio
to attempt to protect the account from losses, but those results cannot be assured. We avoid short-term
trading in the accounts, and construct the portfolios with the Client’s own time horizon in mind, which is
generally for long periods of time.
In some cases, Clients ask us to develop a portfolio with a specific objective (i.e., a growth portfolio that
is fully invested in equities.) Concentrated portfolios are generally subject to more volatility than fully
diversified portfolios, and these investors must accept the risk that these accounts may not achieve their
high-growth objective, and may lose value.
B. Risk of Loss
Clients must understand that past performance is not indicative of future results. Therefore, current and
prospective Clients should never assume that future performance of any specific investment or
investment strategy will be profitable. Investing in securities (including stocks, mutual funds, and bonds)
involves risk of loss. Further, depending on the different types of investments there may be varying
degrees of risk. Clients and prospective Clients should be prepared to bear investment loss including
loss of original principal.
• Mutual Fund and ETF Risk – We primarily select mutual funds when managing Client accounts.
When investing in a mutual fund or ETF, the investor will bear additional expenses based on its pro
rata share of the mutual fund or ETF’s operating expenses, including the potential duplication of
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management fees. The risk of owning a mutual fund or ETF generally reflects the risks of owning
the underlying securities the mutual fund or ETF. Clients may also incur brokerage costs when
purchasing ETFs and mutual funds.
• Equity (stock) market risk – Common stocks are susceptible to general stock market fluctuations
and to volatile increases and decreases in value as market confidence in and perceptions of their
issuers change. If you held common stock, of any given issuer, you would generally be exposed to
greater risk than if you held preferred stocks and debt obligations of the issuer.
• Company Risk. When investing in stock positions, there is always a certain level of company or
industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk
and can be reduced through appropriate diversification. There is the risk that the company will
perform poorly or have its value reduced based on factors specific to the company or its industry.
For example, if a company’s employees go on strike or the company receives unfavorable media
attention for its actions, the value of the company may be reduced.
• Fixed Income Risk. When investing in bonds, there is the risk that issuer will default on the bond and
be unable to make payments. Further, individuals who depend on set amounts of periodically paid
income face the risk that inflation will erode their spending power. Fixed-income investors receive
set, regular payments that face the same inflation risk. Furthermore, bonds are subject to risk when
interest rates rise because the market values of bonds will fall as rates rise.
• Management Risk – Your investment with our firm varies with the success and failure of our investment
strategies, research, analysis and determination of portfolio securities. If our investment strategies do
not produce the expected returns, the value of the investment will decrease.
Item 9 – Disciplinary Information
This item is not applicable to our brochure because there are no legal or disciplinary events listed at Item 9
of the Form ADV Part 2 instructions that are material to a Client’s or prospective Client’s evaluation of our
business or the integrity of the firm’s management (i.e. Barbara and Christopher Warner).
Item 10 – Other Financial Industry Activities and Affiliations
Neither Warner Financial, nor its representatives, are registered or have an application pending to
register, as a broker-dealer or a registered representative of a broker-dealer.
Neither Warner Financial, nor its representatives, are registered or have an application pending to
register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or
a representative of the foregoing.
Warner Financial is not and does not have a related financial institution or company that requires
disclosure at Item 10.
Warner Financial does not receive, directly or indirectly, compensation from investment advisors that it
recommends or selects for its Clients.
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading
Code of Ethics Summary: Warner Financial has established a Code of Ethics that will apply to all of its
employees. An investment advisor is considered a fiduciary according to the Investment Advisers Act of
1940. As a fiduciary, it is an investment advisor’s responsibility to provide fair and full disclosure of all material
facts and to act solely in the best interest of each of our Clients at all times. Warner Financial has a fiduciary
duty to all Clients. This fiduciary duty is considered the core underlying principle for the advisor’s Code of
Ethics which also covers its Insider Trading and Personal Securities Transactions Policies and Procedures.
Warner Financial requires all of its employees to conduct business with the highest level of ethical standards
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and to comply with all federal and state securities laws at all times.
Upon employment or affiliation and when changes occur, all employees will sign an acknowledgement that
they have read, understand and agree to comply with the advisor’s Code of Ethics. Warner Financial has
the responsibility to make sure that the interests of all Clients are placed ahead of Warner Financial’s or its
supervised persons’ own investment interest. Full disclosure of all material facts and potential conflicts of
interest will be provided to Clients prior to any services being conducted. Warner Financial and its employees
must conduct business in an honest, ethical and fair manner and avoid all circumstances that might
negatively affect or appear to affect our duty of complete loyalty to all Clients.
The preceding is intended to be a summary of our Code of Ethics. You can contact our office to request
a complete copy of our Code of Ethics. Please refer to the Cover Page of this brochure for our contact
information.
Affiliate and Employee Personal Securities Transactions Disclosure: Our employees may buy and sell
for themselves the same types of securities we recommended to Clients. Although this could potentially
create a conflict of interest, securities that our employees may personally own that are also recommended
to Clients will be widely held stock, bonds or mutual funds. The total market value of these holdings by our
staff is relatively small and we do not have any expectation that actions taken by our personnel will have an
impact upon the market value of the particular securities. We have established procedures under our Code
of Ethics requiring all employees to report their personal securities holdings and transactions to the Firm.
Item 12 – Brokerage Practices
This section provides information about our brokerage practices in addition to the information detailed in
Item 5 – Fees and Compensation.
A. In the event that the Client requests that Warner Financial recommend a broker-dealer/custodian for
execution and/or custodial services, Warner Financial recommends that investment management
accounts be maintained at Schwab which is a SEC and FINRA-registered broker-dealer, member SIPC,
as the qualified custodian. Prior to engaging Warner Financial to provide investment management
services, the Client will be required to enter into a formal Investment Advisory Agreement with Warner
Financial setting forth the terms and conditions under which Warner Financial will provide investment
advisory services, and a separate custodial/clearing agreement with the designated broker-
dealer/custodian. Warner Financial does not maintain custody of your assets (although we may be
deemed to have custody of your accounts if you give us authority to withdraw assets from your account
-see Item 15-Custody, below). We are independently owned and operated and not affiliated with
Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we
instruct them to.
We seek to recommend a custodian/broker who will hold your assets and execute transactions on terms
that are overall most advantageous when compared with other available providers and their services.
Factors that Warner Financial may consider in recommending Schwab (or any other broker-
dealer/custodian to Clients) include, among others:
•
•
•
combination of transaction execution services along with asset custody services (generally without
a separate fee for custody);
capability to execute, clear and settle trades (buy and sell securities for Clients’ accounts);
capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests,
bill payment, etc.);
• breadth of investment products made available (stocks, bonds, mutual funds, exchange traded
funds, etc.);
• availability of investment research and tools that assist Warner Financial in making investment
decisions;
competitiveness of the price of those services (commission rates, margin interest rates, other fees,
• quality of services;
•
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•
•
etc.) and willingness to negotiate them;
reputation, financial strength and stability of the provider;
their prior service to Warner Financial and Warner Financial’s other Clients; and availability of other
products and services that benefit Warner Financial, as discussed below.
For our Clients’ accounts that it maintains, Schwab generally does not charge you separately for custody
services, but is compensated by charging you commissions or other fees on trades that it executes or
that settle in your Schwab account. To the extent that a transaction fee will be payable by the Client to
Schwab, the transaction fee shall be in addition to Warner Financial’s investment advisory fee referenced
in Item 5 above.
To the extent that a transaction fee is payable, Warner Financial shall have a duty to obtain best
execution for such transaction. However, that does not mean that the Client will not pay a transaction
fee that is higher than another qualified broker-dealer might charge to effect the same transaction where
Warner Financial determines, in good faith, that the transaction fee is reasonable. In seeking best
execution, the determinative factor is not the lowest possible cost, but whether the transaction represents
the best qualitative execution, taking into consideration the full range of a broker-dealer’s services,
including the value of research provided, execution capability, transaction rates, and responsiveness.
1. Research and Additional Benefits
Although not a material consideration when determining whether to recommend that a Client utilize
the services of a particular broker-dealer/custodian, Warner Financial may receive from Schwab (or
product/fund sponsor) without cost (and/or at a discount) support services and/or products, certain
of which assist Warner Financial to better monitor and service Client accounts maintained at such
institutions. The support services that Warner Financial may obtain could include: investment-related
research, pricing information and market data, software and other technology that provide access to
Client account data, compliance and/or practice management-related publications, discounted or
gratis consulting services, discounted and/or gratis travel and attendance at conferences, meetings,
and other educational and/or social events, marketing support, computer hardware and/or software
and/or other products used by Warner Financial in furtherance of its investment advisory business
operations.
Warner Financial’s Clients do not pay more for investment transactions effected and/or assets
maintained at Schwab as a result of this arrangement. There is no corresponding commitment made
by Warner Financial to Schwab or any other entity to invest any specific amount or percentage of
Client assets in any specific mutual funds, securities or other investment products as a result of the
above arrangement.
Warner Financial’s Chief Compliance Officer, Barbara Warner, is available to address any
questions that a Client or prospective Client may have regarding the above arrangements
and the corresponding conflict of interest presented by such arrangements.
2. Warner Financial does not receive referrals from broker-dealers.
B.
Directed Brokerage: Warner Financial does not accept directed brokerage arrangements (when a
Client requires that account transactions be effected through a specific broker-dealer).
Trading Policy: Our trading policy is to implement all Client orders on an individual basis. Therefore,
we do not aggregate or “block” Client transactions. Considering the types of investments we hold in
advisory Client accounts, we do not believe Clients are hindered in any way because we trade
accounts individually. The investments we are responsible for trading in Client accounts are typically
limited to mutual funds, and other broadly traded positions. Our strategies are primarily developed
for the long-term and minor differences in price execution are not material to our overall investment
strategy.
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Trade Error Policy: Warner Financial has implemented procedures designed to prevent trade
errors; however, trade errors in Client accounts cannot always be avoided. Consistent with its
fiduciary duty, it is the policy of Warner Financial to correct trade errors in a manner that is in the
best interest of the Client. In cases where the Client causes the trade error, the Client will be
responsible for any loss resulting from the correction. Depending on the specific circumstances of
the trade error, the Client may not be able to receive any gains generated as a result of the error
correction. In all situations where the Client does not cause the trade error, the Client will be made
whole and any loss resulting from the trade error will be absorbed by Warner Financial if the error
was caused by Warner Financial. If the error is caused by the broker-dealer, the broker- dealer will
be responsible for covering all trade error costs. If an investment gain results from the correcting
trade, the gain will remain in the Client’s account unless it is not permissible for Clients to retain the
gain. Warner Financial may also confer with Clients to determine if the Client should forego the gain
(e.g., due to tax reasons).
Warner Financial will never retain any portion of any gains made as a result of trade error corrections
or profit in any way from trade errors. Further, our personnel are not permitted to make payments to
Clients or to Client accounts.
Item 13 – Review of Accounts
Account Reviews and Reviewers: The principal planners and investment advisor representatives of the
firm, Barbara Warner CFP®, David Warner CFA, Christopher Warner CFA, CFP® and Kevin Jarcho, CFP®
review all accounts. They have experience in security analysis, financial planning, and offer advice on
financial issues and investment planning that is unique to each Client's situation.
For Financial Planning Clients, reviews are performed on an intermittent basis as requested by the Client or
as recommended (usually annually) by the planner. Reviews are intended to examine a Client's progress
toward goals and to update plan recommendations, if warranted by changes in Client's circumstances. For
Asset Management Clients, portfolios are generally reviewed annually for rebalancing purposes, and
performance reports are monitored on a quarterly basis. More frequent reviews may be performed if
warranted by the Client’s situation.
Statements and Reports: Warner Financial provides written performance reports to the Clients that have
contracted with Warner Financial for Asset Management Services. Performance reports detail the Client’s
portfolio performance over relevant time periods. You are urged to compare the reports provided by
Warner Financial against the account statements you receive directly from your account custodian.
The custodian for the individual Client’s account also provides the Client with an account statement at least
quarterly and the Client may be able to view the account online. For Clients whose funds are held directly
with mutual fund companies, separate from Schwab, the periodic account statements will be sent directly
from the fund companies.
Item 14 – Client Referrals and Other Compensation
A. As indicated at Item 12 above, Warner Financial receives from Schwab without cost (and/or at a
discount), support services and/or products. Warner Financial’s Clients do not pay more for
investment transactions effected and/or assets maintained at Schwab (or any other institution) as
result of this arrangement. There is no corresponding commitment made by Warner Financial to
Schwab, or to any other entity, to invest any specific amount or percentage of Client assets in any
specific mutual funds, securities or other investment products as a result of the above arrangement.
ANY QUESTIONS: Warner Financial’s Chief Compliance Officer, Barbara Warner, remains
available to address any questions that a Client or prospective Client may have regarding the
above arrangements and the corresponding conflict of interest presented by such
arrangements.
B. Warner Financial does not maintain solicitor arrangements. Warner Financial does not
compensate third parties for Client introductions.
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Item 15 – Custody
Warner Financial is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client
must place all assets with a “qualified custodian”. The Client is required to engage the Custodian to retain
all funds and securities and direct Warner Financial to utilize that Custodian for security transactions in the
account[s]. The Client should review statements provided by the Custodian, as the Custodian does not
perform this review. For more information about custodians and brokerage practices, see Item 12 –
Brokerage Practices.
If the Client gives Warner Financial authority to move money from one account to another account, Warner
Financial may have custody of those assets. In order to avoid additional regulatory requirements, the
Custodian and Warner Financial have adopted safeguards to ensure that the money movements are
completed in accordance with the Client’s instructions.
Item 16 – Investment Discretion
Asset Management Services: Through our asset management program, we will maintain trading
authorization over Client accounts. Upon receiving written authorization from the Client, we may implement
trades on a discretionary basis (as detailed in our agreement for services). When discretionary authority is
granted by a Client, we will have the authority to determine the type of securities and the amount of securities
that can be bought or sold for the Client’s portfolio without obtaining the Client’s consent for each transaction.
However, it is our policy to consult with the Client prior to making significant changes in the account even
when discretionary trading authority is granted by the Client.
If trading authorization is provided on a non-discretionary basis, we will be required to contact you prior to
implementing changes in your account. Therefore, you will be contacted and required to accept or reject our
investment recommendations including:
• The security being recommended
• The number of shares or units
• Whether to buy or sell
Once the above factors are agreed upon, we will be responsible for making decisions regarding the timing
of buying or selling an investment and the price at which the investment is bought or sold. If your accounts
are managed on a non-discretionary basis, you need to know that if you are not able to be reached or are
slow to respond to our request, it can have an adverse impact on the timing of trade implementations and
we may not achieve the optimal trading price.
Item 17 – Voting Client Securities
Warner Financial does not vote proxies on behalf of its Clients. Therefore, it is the responsibility of Warner
Financial Clients to vote all proxies for securities held in their accounts.
You will receive proxies directly from your custodian or transfer agent and such documents will not be
delivered by or from Warner Financial. Although we do not vote Client proxies, if you have a question about
a particular proxy feel free to contact us.
Item 18 – Financial Information
This item is not applicable to Warner Financial’s brochure. We never require Clients to prepay more than
$1,200 in fees, six months or more in advance. Therefore, Warner Financial is not required to include a
balance sheet for its most recent fiscal year. Warner Financial is not subject to a financial condition that is
reasonably likely to impair its ability to meet contractual commitments to Clients. Finally, we have not been
the subject of a bankruptcy petition at any time.
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Item 1 – Cover Page
Warner Financial, Inc.
4550 Montgomery Ave.
Suite 352 North
Bethesda, MD 20814
301-961-9505
Part 2B of Form ADV
Brochure Supplement
February 9, 2026
Barbara A. Warner, CFP ®
This brochure supplement provides information about Barbara A. Warner that supplements the
Warner Financial, Inc. brochure. You should have received a copy of that brochure. Please call the
office at 301-961-9505 if you did not receive the Warner Financial brochure or if you have any
questions about the contents of this supplement.
Additional information about the above-named professional is available on the SEC’s website at
www.adviserinfo.sec.gov.
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Item 2 – Educational Background and Business Experience
Barbara A. Warner, CFP®, Born: 1955
Education: Bachelor of Arts degree in Speech Communications, State University of New York, College at
Oneonta
Business Background
April 2005 to Present – Warner Financial, Inc. Owner, Officer and Investment Advisor Representative
August 2009 to September 2017 – Cambridge Investment Research, Inc., Registered Representative
January 2003 to April 2005- Windsor Financial, LLC, Owner, Officer and Investment Advisor
Representative
Sept 1987 to January 2003- Windsor Financial Group, Inc, Owner, Officer and Investment Advisor
Representative
Sept 1987 to August 2009- Mutual Service Corp., Registered Representative
Ms. Warner has been a CERTIFIED FINANCIAL PLANNER™ since 1985. The CERTIFIED
FINANCIAL PLANNER™, CFP® and federally registered CFP (collectively, the “CFP® marks”) are
professional certification marks granted in the United States by Certified Financial Planner Board of
Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial
planners to hold CFP® certification. It is recognized in the United States and a number of other countries for
its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and
(3) ethical requirements that govern professional engagements with Clients. Currently, more than 76,000
individuals have obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must currently satisfactorily fulfill the following
requirements:
• Education – Complete an advanced college-level course of study addressing the financial planning
subject areas that CFP Board’s studies have determined as necessary for the competent and
professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally
accredited United States college or university (or its equivalent from a foreign university). CFP
Board’s financial planning subject areas include insurance planning and risk management, employee
benefits planning, investment planning, income tax planning, retirement planning, and estate
planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The examination,
administered in 6 hours, includes case studies and Client scenarios designed to test one’s ability to
correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real
world circumstances;
• Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements
in order to maintain the right to continue to use the CFP® marks:
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• Continuing Education – Complete 30 hours of continuing education hours every two years, including
two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary
standard of care. This means CFP® professionals must provide financial planning services in the best
interests of their Clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP
Board’s enforcement process, which could result in suspension or permanent revocation of their CFP®
certification.
Ms. Warner is a past president of the Financial Planning Association of the National Capital Area, and a
member of the Washington DC Estate Planning Council. She is active as a volunteer with the National Park
Service in Washington DC.
Item 3 – Disciplinary Information
Ms. Warner has no legal or disciplinary events to report.
Item 4 – Other Business Activities
Ms. Warner does not participate in any other investment-related business activities.
Item 5 – Additional Compensation
None.
Item 6 – Supervision
Barbara Warner is the Chief Compliance Officer of Warner Financial and ultimately responsible for Warner
Financial’s compliance program including establishing procedures designed to monitor and supervise the
activities and services provided by the firm and its supervised persons. Ms. Warner can be reached at 301-
961-9505.
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Item 1 – Cover Page
Warner Financial, Inc.
4550 Montgomery Ave.
Suite 352 North
Bethesda, MD 20814
301-961-9505
Part 2B of Form ADV
Brochure Supplement
February 9, 2026
Christopher M. Warner, CFA, CFP ®
This brochure supplement provides information about Christopher M. Warner that supplements the
Warner Financial, Inc. brochure. You should have received a copy of that brochure. Please call the
office at 301-961-9505 if you did not receive the Warner Financial brochure or if you have any
questions about the contents of this supplement.
Additional information about the above-named professional is available on the SEC’s website at
www.adviserinfo.sec.gov.
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Item 2 – Educational Background and Business Experience
Christopher M. Warner, CFA, CFP® Born: 1985
Education: Bachelor of Science degree in Mechanical Engineering, University of Maryland, College Park,
MD
Business Background
January 2008 to Present – Warner Financial, Inc., Owner, Officer and Investment Advisor Representative
August 2009 to September 2017– Cambridge Investment Research, Inc., Registered Representative
January 2008 to August 2009- Mutual Service Corp., Registered Representative
September 2007 to December 2007- Gurtz, Yurachek, Brostrom and Associates, Financial Planning
Assistant
Mr. Warner has been a CERTIFIED FINANCIAL PLANNER™ since 2009. The CERTIFIED
FINANCIAL PLANNER™, CFP® and federally registered CFP (collectively, the “CFP® marks”) are
professional certification marks granted in the United States by Certified Financial Planner Board of
Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial
planners to hold CFP® certification. It is recognized in the United States and a number of other countries for
its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and
(3) ethical requirements that govern professional engagements with Clients. Currently, more than 76,000
individuals have obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must currently satisfactorily fulfill the following
requirements:
• Education – Complete an advanced college-level course of study addressing the financial planning
subject areas that CFP Board’s studies have determined as necessary for the competent and
professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally
accredited United States college or university (or its equivalent from a foreign university). CFP
Board’s financial planning subject areas include insurance planning and risk management, employee
benefits planning, investment planning, income tax planning, retirement planning, and estate
planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The examination,
administered in 6 hours, includes case studies and Client scenarios designed to test one’s ability to
correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real
world circumstances;
• Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements
in order to maintain the right to continue to use the CFP® marks:
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• Continuing Education – Complete 30 hours of continuing education hours every two years, including
two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary
standard of care. This means CFP® professionals must provide financial planning services in the best
interests of their Clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP
Board’s enforcement process, which could result in suspension or permanent revocation of their CFP®
certification.
Mr. Warner has been a CFA® Charter Holder since 2016. CFA® designates an international professional
certificate that is offered by the CFA Institute.
The Chartered Financial Analyst (CFA) charter is a globally respected, graduate-level investment credential
established in 1962 and awarded by CFA Institute — the largest global association of investment
professionals.
There are currently more than 120,000 CFA charter holders working in 135 countries. To earn the CFA
charter, candidates must: (1) pass three sequential, six-hour examinations; (2) have at least four years of
qualified professional investment experience; (3) join CFA Institute as members; and (4) commit to abide
by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional
Conduct.
High Ethical Standards
The CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an active
professional conduct program, require CFA charter holders to:
• Place their Clients’ interests ahead of their own
• Maintain independence and objectivity
• Act with integrity
• Maintain and improve their professional competence
• Disclose conflicts of interest and legal matters
Global Recognition
Passing the three CFA exams is a difficult feat that requires extensive study (successful candidates report
spending an average of 300 hours of study per level). Earning the CFA charter demonstrates mastery of
many of the advanced skills needed for investment analysis and decision making in today’s quickly evolving
global financial industry. As a result, employers and Clients are increasingly seeking CFA charterholders—
often making the charter a prerequisite for employment. Additionally, regulatory bodies in 23
countries/territories recognize the CFA charter as a proxy for meeting certain licensing requirements, and
more than 125 colleges and universities around the world have incorporated a majority of the CFA Program
curriculum into their own finance courses.
Comprehensive and Current Knowledge
The CFA Program curriculum provides a comprehensive framework of knowledge for investment decision
making and is firmly grounded in the knowledge and skills used every day in the investment profession. The
three levels of the CFA Program test a proficiency with a wide range of fundamental and advanced
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investment topics, including ethical and professional standards, fixed-income and equity analysis, alternative
and derivative investments, economics, financial reporting standards, portfolio management, and wealth
planning.
The CFA Program curriculum is updated every year by experts from around the world to ensure that
candidates learn the most relevant and practical new tools, ideas, and investment and wealth management
skills to reflect the dynamic and complex nature of the profession.
Mr. Warner is a member of the Financial Planning Association of the National Capital Area, the CFA
Society Washington DC, and the Washington DC Estate Planning council.
Item 3 – Disciplinary Information
Mr. Warner has no legal or disciplinary events to report.
Item 4 – Other Business Activities
Mr. Warner has no other investment-related business activities to report.
Item 5 – Additional Compensation
None.
Item 6 – Supervision
Barbara Warner is the Chief Compliance Officer of Warner Financial and has supervisory responsibility for
the activities of the firm. She can be reached at 301-961-9505. Ms. Warner regularly reviews meeting and
presentation materials, Client correspondence and emails, the suitability of investment recommendations,
fee billing calculations, performance reports and employee trading activities.
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Item 1 – Cover Page
Warner Financial, Inc.
4550 Montgomery Ave.
Suite 352 North
Bethesda, MD 20814
301-961-9505
Part 2B of Form ADV
Brochure Supplement
February 9, 2026
David S. Warner, CFA
This brochure supplement provides information about David S. Warner that supplements the
Warner Financial, Inc. brochure. You should have received a copy of that brochure. Please call the
office at 301-961-9505 if you did not receive the Warner Financial brochure or if you have any
questions about the contents of this supplement.
Additional information about the above-named professional is available on the SEC’s website at
www.adviserinfo.sec.gov.
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Item 2 – Educational Background and Business Experience
David S. Warner, CFA, Born: 1953
Education: Bachelor of Arts degree in Sociology from the College of William and Mary, Williamsburg, VA
Business Background
April 2005 to Present – Warner Financial, Inc., Investment Advisor Representative
August 2009 to September 2017 – Cambridge Investment Research, Inc., Registered Representative
January 2003 to April 2005- Windsor Financial, LLC, Owner, Officer and Investment Advisor
Representative
January 2001 to January 2003- Windsor Financial Group, Inc, Owner, Officer, Investment Advisor
Representative
Mr. Warner has been a CFA® Charter Holder since 2000. CFA® designates an international professional
certificate that is offered by the CFA Institute.
The Chartered Financial Analyst (CFA) charter is a globally respected, graduate-level investment credential
established in 1962 and awarded by CFA Institute — the largest global association of investment
professionals.
There are currently more than 120,000 CFA charter holders working in 135 countries. To earn the CFA
charter, candidates must: (1) pass three sequential, six-hour examinations; (2) have at least four years of
qualified professional investment experience; (3) join CFA Institute as members; and (4) commit to abide
by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional
Conduct.
High Ethical Standards
The CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an active
professional conduct program, require CFA charter holders to:
• Place their Clients’ interests ahead of their own
• Maintain independence and objectivity
• Act with integrity
• Maintain and improve their professional competence
• Disclose conflicts of interest and legal matters
Global Recognition
Passing the three CFA exams is a difficult feat that requires extensive study (successful candidates report
spending an average of 300 hours of study per level). Earning the CFA charter demonstrates mastery of
many of the advanced skills needed for investment analysis and decision making in today’s quickly evolving
global financial industry. As a result, employers and Clients are increasingly seeking CFA charterholders—
often making the charter a prerequisite for employment. Additionally, regulatory bodies in 23
countries/territories recognize the CFA charter as a proxy for meeting certain licensing requirements, and
more than 125 colleges and universities around the world have incorporated a majority of the CFA Program
curriculum into their own finance courses.
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Comprehensive and Current Knowledge
The CFA Program curriculum provides a comprehensive framework of knowledge for investment decision
making and is firmly grounded in the knowledge and skills used every day in the investment profession. The
three levels of the CFA Program test a proficiency with a wide range of fundamental and advanced
investment topics, including ethical and professional standards, fixed-income and equity analysis, alternative
and derivative investments, economics, financial reporting standards, portfolio management, and wealth
planning.
The CFA Program curriculum is updated every year by experts from around the world to ensure that
candidates learn the most relevant and practical new tools, ideas, and investment and wealth management
skills to reflect the dynamic and complex nature of the profession.
Mr. Warner is a member of the CFA Society of Washington DC.
Item 3 – Disciplinary Information
Mr. Warner has no legal or disciplinary events to report.
Item 4 – Other Business Activities
Mr. Warner has no outside investment-related business activities to report.
Item 5 – Additional Compensation
None.
Item 6 – Supervision
Barbara Warner is the Chief Compliance Officer of Warner Financial and has supervisory responsibility for
the activities of the firm. She can be reached at 301-961-9505. Ms. Warner regularly reviews meeting and
presentation materials, Client correspondence and emails, the suitability of investment recommendations,
fee billing calculations, performance reports and employee trading activities.
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Item 1 – Cover Page
Warner Financial, Inc.
4550 Montgomery Ave.
Suite 352 North
Bethesda, MD 20814
301-961-9505
Part 2B of Form ADV
Brochure Supplement
February 9, 2026
Kevin S. Jarcho, CFP ®
This brochure supplement provides information about Kevin S. Jarcho that supplements the Warner
Financial, Inc. brochure. You should have received a copy of that brochure. Please call the office at
301-961-9505 if you did not receive the Warner Financial brochure or if you have any questions
about the contents of this supplement.
Additional information about the above-named professional is available on the SEC’s website at
www.adviserinfo.sec.gov.
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Item 2 – Educational Background and Business Experience
Kevin S. Jarcho, CFP®, Born: 1986
Education: MS in Sustainability Management, American University; Bachelor of Business Administration
and Bachelor of Science in Environmental Science and Policy, The College of William and Mary;
Business Background
May 2021 to Present – Warner Financial, Inc. Investment Advisor Representative
October 2016 to May 2021 – Intact Technology, Project Manager
May 2012 to – October 2016 – Kemtah Group, Project Manager
January 2011 to April 2012 – Triton Federal Solutions, Senior Associate
September 2009 to January 2011 – Booz Allen Hamilton, Consultant
Mr. Jarcho has been a CERTIFIED FINANCIAL PLANNER™ since 2023. The CERTIFIED FINANCIAL
PLANNER™, CFP® and federally registered CFP (collectively, the “CFP® marks”) are professional
certification marks granted in the United States by Certified Financial Planner Board of Standards, Inc.
(“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial
planners to hold CFP® certification. It is recognized in the United States and a number of other countries for
its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and
(3) ethical requirements that govern professional engagements with Clients. Currently, more than 76,000
individuals have obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must currently satisfactorily fulfill the following
requirements:
• Education – Complete an advanced college-level course of study addressing the financial planning
subject areas that CFP Board’s studies have determined as necessary for the competent and
professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally
accredited United States college or university (or its equivalent from a foreign university). CFP
Board’s financial planning subject areas include insurance planning and risk management, employee
benefits planning, investment planning, income tax planning, retirement planning, and estate
planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The examination,
administered in 6 hours, includes case studies and Client scenarios designed to test one’s ability to
correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real
world circumstances;
• Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements
in order to maintain the right to continue to use the CFP® marks:
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• Continuing Education – Complete 30 hours of continuing education hours every two years, including
two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary
standard of care. This means CFP® professionals must provide financial planning services in the best
interests of their Clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to the
CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP®
certification.
Mr. Jarcho is also a certified Project Management Professional (PMP).
Item 3 – Disciplinary Information
Mr. Jarcho has no legal or disciplinary events to report.
Item 4 – Other Business Activities
Mr. Jarcho does not participate in any other investment-related business activities.
Item 5 – Additional Compensation
None.
Item 6 – Supervision
Barbara Warner is the Chief Compliance Officer of Warner Financial and ultimately responsible for Warner
Financial’s compliance program including establishing procedures designed to monitor and supervise the
activities and services provided by the firm and its supervised persons. Ms. Warner can be reached at 301-
961-9505.
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Privacy Policy
Effective: February 9, 2026
Our Commitment to You
Warner Financial, Inc. (“Warner Financial” 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. Warner Financial (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.
Warner Financial 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?
Date of birth
Assets and liabilities
Income and expenses
Social security or taxpayer identification
number
Name, address and phone number[s]
Investment activity
E-mail address[es]
Investment experience and goals
Account information (including other
institutions)
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment questionnaires and suitability
documents
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
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responsibilities to protect Client’s personal information.
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
No
Not Shared
Yes
Yes
No
Not Shared
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.
Marketing Purposes
Warner Financial 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 Warner Financial 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 purposes.
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].
Information About Former Clients
Warner Financial 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 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
301-961-9505.
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