WHALEN WEALTH MANAGEMENT INC.

Whalen Wealth Management DBA Whalen Financial Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Whalen Wealth Management DBA Whalen Financial. If you have any questions about the contents of this brochure, please contact us at (702) 878-3900 or by email at: info@whalenfinancial.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Whalen Wealth Management DBA Whalen Financial is also available on the SEC’s website at www.adviserinfo.sec.gov. Whalen Wealth Management DBA Whalen Financial’s CRD number is: 311869. 7160 Rafael Rivera Way, Suite 220 Las Vegas, NV 89113 (702) 878-3900 info@whalenfinancial.com https://www.whalenfinancial.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 10/22/2025 i  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of Whalen Wealth Management DBA Whalen Financial on 01/30/2025. are described below. Material changes relate to Whalen Wealth Management DBA Whalen Financial’s policies, practices or conflicts of interests. ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ....................................................................................................................................... ii Item 3: Table of Contents ...................................................................................................................................... iii Item 4: Advisory Business ......................................................................................................................................2 Item 5: Fees and Compensation .............................................................................................................................5 Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................7 Item 7: Types of Clients ..........................................................................................................................................8 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ...............................................................8 Item 9: Disciplinary Information .........................................................................................................................11 Item 10: Other Financial Industry Activities and Affiliations .........................................................................11 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...............13 Item 12: Brokerage Practices ................................................................................................................................14 Item 13: Review of Accounts ................................................................................................................................15 Item 14: Client Referrals and Other Compensation ..........................................................................................16 Item 15: Custody ....................................................................................................................................................17 Item 16: Investment Discretion ............................................................................................................................17 Item 17: Voting Client Securities (Proxy Voting) ..............................................................................................17 Item 18: Financial Information .............................................................................................................................17 iii  Item 4: Advisory Business A. Description of the Advisory Firm Whalen Wealth Management DBA Whalen Financial (hereinafter “Whalen Financial”) is a Corporation organized in the State of Nevada. The firm was formed in November 2020, and the principal owner is Andrew Joseph Whalen. B. Types of Advisory Services Portfolio Management Services Whalen Financial offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Whalen Financial creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring Whalen Financial evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Whalen Financial will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Whalen Financial seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of Whalen Financial’s economic, investment or other financial interests. To meet its fiduciary obligations, Whalen Financial attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Whalen Financial’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is Whalen Financial’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Held Away Assets – Pontera We use a third party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct 2  access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least annually and allocation changes will be made as deemed necessary. Altruist Financial LLC Platform Whalen Financial offers investment advisory services through the custodial platform offered by Altruist Financial LLC (“Altruist”), an unaffiliated SEC registered broker dealer and FINRA/SIPC member. Custody, clearing and execution services are provided by Altruist Financial LLC as a self-clearing broker-dealer. Whalen Financial’s clients establish brokerage accounts through Altruist. Whalen Financial maintains an institutional relationship with Altruist whereby Altruist provides certain benefits to Whalen Financial, including a fully digital account opening process, a variety of available investments, and integration with software tools that can benefit Whalen Financial and its clients. Whalen Financial is not affiliated with Altruist. Altruist does not supervise Whalen Financial, its agents, activities, or its regulatory compliance. Model Marketplace Whalen Financial participates in the Model Marketplace and/or uses tax management tools of Altruist LLC, an SEC-registered investment adviser and affiliate of Altruist Financial LLC. Through the Model Marketplace, Whalen Financial has access to model portfolios including Altruist LLC-generated portfolios and Third-Party Portfolios, to assist it in managing or advising Whalen Financial client accounts. Whalen Financial also has the ability to create custom model portfolios and has access to tax management tools for use with Altruist LLC-generated portfolios, Third-Party Portfolios, and custom model portfolios, to assist Whalen Financial in managing or advising its client accounts. Altruist LLC’s Model Marketplace fees and tax management tool fees – each of which range between 0.00% and 1.00% and are listed in the Altruist LLC Fee Schedule available at altruist.com/legal – are automatically deducted from Whalen Financial’s house account or passed through to and debited from clients’ accounts, according to the instruction of Whalen Financial. Altruist LLC and its affiliates do not act as investment advisers or fiduciary to Whalen Financial clients. Whalen Financial is responsible for suitability of all investment decisions and transactions for client accounts subscribed to model portfolios through the Model Marketplace. Selection of Other Advisers Whalen Financial may direct clients to third-party investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, Whalen Financial 3  will always ensure those other advisers are properly licensed or registered as an investment adviser. Whalen Financial conducts due diligence on any third-party investment adviser, which may involve one or more of the following: phone calls, meetings and review of the third-party adviser's performance and investment strategy. Whalen Financial then makes investments with a third-party investment adviser by referring the client to the third-party adviser. Whalen Financial will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Services Limited to Specific Types of Investments Whalen Financial generally limits its investment advice to mutual funds, fixed income securities, equities and ETFs (including ETFs in the gold and precious metal sectors). Whalen Financial may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions Whalen Financial offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. Whalen Financial does not participate in any wrap fee programs. E. Assets Under Management Whalen Financial has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 192,271,610 $ 0.00 December 31, 2024 4  Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees $0 - $2,000,000 1.20% $2,000,001 - $5,000,000 1.00% $5,000,001 - $10,000,000 0..5% $10,000,001 – And Up 0..35% Whalen Financial uses an average of the daily balance in the client's account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. The final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of Whalen Financial's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. Selection of Other Advisers Fees Whalen Financial will receive its standard fee on top of the fee paid to the third party adviser. This relationship will be memorialized in each contract between Whalen Financial and each third-party adviser. The fees will not exceed any limit imposed by any regulatory agency. Whalen Financial may engage in the selection of third-party money managers, but does not have any such arrangements in place at this time. This service may be canceled immediately upon written notice. Financial Planning Fees Fixed Fees The fixed rate for creating client financial plans is $3300. This fee includes: Comprehensive Planning & Asset Layout Savings Plan 5  Investment Model Assistance with outside professionals Dedicated Operation Staff # of outbound calls (4) Annual in-person/zoom meeting In addition, there is an annual $550 fee that is due at the annual scheduled meeting. Clients may terminate the agreement without penalty, for full refund of Whalen Financial’s fees, within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally upon written notice. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a monthly basis. Fees are paid in arrears. Payment of Selection of Other Advisers Fees The timing, frequency, and method of paying fees for selection of third-party managers will depend on the specific third-party adviser selected. Payment of Financial Planning Fees Financial planning fees are paid 50% in advance, but never more than six months in advance, with the remainder due upon presentation of the plan. Fees are paid via AdvicePay. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by Whalen Financial. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees Fixed fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination. 6  E. Outside Compensation For the Sale of Securities to Clients Andrew Joseph Whalen is a registered representatives of a broker-dealer. Andrew Joseph Whalen is also an insurance agent. In these roles, they accept compensation for the sale of investment products to Whalen Financial clients. 1. This is a Conflict of Interest Supervised persons may accept compensation for the sale of investment products, including asset based sales charges or service fees from the sale of mutual funds to Whalen Financial's clients. This presents a conflict of interest and gives the supervised person an incentive to recommend products based on the compensation received rather than on the client’s needs. When recommending the sale of investment products for which the supervised persons receives compensation, Whalen Financial will document the conflict of interest in the client file and inform the client of the conflict of interest. 2. Clients Have the Option to Purchase Recommended Products From Other Brokers Clients always have the option to purchase Whalen Financial recommended products through other brokers or agents that are not affiliated with Whalen Financial. 3. Commissions are not Whalen Financial's primary source of compensation for advisory services Commissions are not Whalen Financial’s primary source of compensation for advisory services. 4. Advisory Fees in Addition to Commissions or Markups Advisory fees that are charged to clients are not reduced to offset the commissions or markups on investment products recommended to clients. Item 6: Performance-Based Fees and Side-By-Side Management Whalen Financial does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. 7  Item 7: Types of Clients Whalen Financial generally provides advisory services to the following types of clients: ❖ ❖ Individuals High-Net-Worth Individuals ❖ Pension and profit sharing plans ❖ Charitable organizations ❖ Corporations or other businesses There is no account minimum for any of Whalen Financial’s services. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis Whalen Financial’s methods of analysis include Fundamental analysis and Modern portfolio theory. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Investment Strategies Whalen Financial uses long term trading and short term trading. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in 8  stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Investment Strategies Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Selection of Other Advisers: Although Whalen Financial will seek to select only money managers who will invest clients' assets with the highest level of integrity, Whalen Financial's selection process cannot ensure that money managers will perform as desired and Whalen Financial will have no control over the day-to-day operations of any of its selected money managers. Whalen Financial would not necessarily be aware of certain activities at the underlying money manager level, including without limitation a money manager's engaging in unreported risks, investment “style drift” or even regulatory breaches or fraud. Short term trading risks include liquidity, economic stability, and inflation, in addition to the long term trading risks listed above. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment 9  returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Risks in investing in ETFs include trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-participation of authorized participants, risks that trading price differs from indicative net asset value (iNAV), or price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds cost to your portfolio thus counteracting the low fees that one of the typical benefits of ETFs. Additionally, regular trading to beneficially “time the market” is difficult to achieve. Even paid fund managers struggle to do this every year, with the majority failing to beat the relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading conditions are more accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks of their underlying securities, which may include the risks associated with investing in smaller companies, foreign securities, commodities, and fixed income investments (as applicable). Foreign securities in particular are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. ETFs that target a small universe of securities, such as a specific region or market sector, are generally subject to greater market volatility, as well as to the specific risks associated with that sector, region, or other focus. ETFs that use derivatives, leverage, or complex investment strategies are subject to additional risks. Precious Metal ETFs (e.g., Gold, 10  Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. The return of an index ETF is usually different from that of the index it tracks because of fees, expenses, and tracking error. An ETF may trade at a premium or discount to its net asset value (NAV) (or indicative value in the case of exchange-traded notes). The degree of liquidity can vary significantly from one ETF to another and losses may be magnified if no liquid market exists for the ETF’s shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its prospectus, offering circular, or similar material, which should be considered carefully when making investment decisions. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither Whalen Financial nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. 11  B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither Whalen Financial nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Andrew Whalen is an insurance agent with Whalen & Associates Insurance, Inc. From time to time, he will offer clients advice or products from those activities. Clients should be aware that these services pay a commission and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. Whalen Wealth Management DBA Whalen Financial always acts in the best interest of the client, including the sale of commissionable products to advisory clients. Clients always have the right to decide whether or not to utilize the services of any representative of Whalen Wealth Management DBA Whalen Financial in such individual’s outside capacities. Andrew Whalen is the CEO of The Whalen Group, Inc., a tax and accounting preparation firm. Clients may pay separate fees to The Whalen Group for tax preparation, tax filing, tax advisory or bookkeeping services. Clients always have the right to decide whether or not to utilize the services of any Whalen Wealth Management DBA Whalen Financial representative in such individual’s outside capacities Andrew Whalen is the CEO of CWM Publishing Inc., a publishing company which retains revenue from the sale of the book Confessions of a Wealth Manager. CWM Publishing will also retain merchandise sales of SWAG related to Confessions of a Wealth Manager and will collect the revenue related to the book and merchandise sales. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections Whalen Financial may direct clients to third-party investment advisers to manage all or a portion of the client's assets. Clients will pay Whalen Financial its standard fee in addition to the standard fee for the advisers to which it directs those clients. This relationship will be memorialized in each contract between Whalen Financial and each third-party advisor. The fees will not exceed any limit imposed by any regulatory agency. Whalen Financial will always act in the best interests of the client, including when determining which third- party investment adviser to recommend to clients. Whalen Financial will ensure that all recommended advisers are licensed or notice filed in the states in which Whalen Financial is recommending them to clients. 12  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Whalen Financial has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. Whalen Financial's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests Whalen Financial does not recommend that clients buy or sell any security in which a related person to Whalen Financial or Whalen Financial has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of Whalen Financial may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of Whalen Financial to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. Whalen Financial will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of Whalen Financial may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of Whalen Financial to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, Whalen Financial will never engage in trading that operates to the client’s disadvantage if representatives of Whalen Financial buy or sell securities at or around the same time as clients. 13  Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on Whalen Financial’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and Whalen Financial may also consider the market expertise and research access provided by the broker-dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in Whalen Financial's research efforts. Whalen Financial will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker-dealer/custodian. Whalen Financial will require clients to use Schwab Institutional, a division of Charles Schwab & Co., Inc. 1. Research and Other Soft-Dollar Benefits While Whalen Financial has no formal soft dollars program in which soft dollars are used to pay for third party services, Whalen Financial may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). Whalen Financial may enter into soft- dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and Whalen Financial does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. Whalen Financial benefits by not having to produce or pay for the research, products or services, and Whalen Financial will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that Whalen Financial’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals Whalen Financial receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use Whalen Financial will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. 14  B. Aggregating (Block) Trading for Multiple Client Accounts If Whalen Financial buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, Whalen Financial would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. Whalen Financial would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for Whalen Financial's advisory services provided on an ongoing basis are reviewed at least Quarterly by Andrew J Whalen, President, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at Whalen Financial are assigned to this reviewer. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Andrew J Whalen, President. Financial planning clients are provided a one- time financial plan concerning their financial situation. After the presentation of the plan, there are no further reports. Clients may request additional plans or reports for a fee. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). With respect to financial plans, Whalen Financial’s services will generally conclude upon delivery of the financial plan. C. Content and Frequency of Regular Reports Provided to Clients Each client of Whalen Financial's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. 15  Each financial planning client will receive the financial plan upon completion. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) Whalen Financial does not receive any economic benefit, directly or indirectly from any third party for advice rendered to Whalen Financial's clients. With respect to Schwab, Whalen Financial receives access to Schwab’s institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Schwab Advisor Services. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For Whalen Financial client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab also makes available to Whalen Financial other products and services that benefit Whalen Financial but may not benefit its clients’ accounts. These benefits may include national, regional or Whalen Financial specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits may include occasional business entertainment of personnel of Whalen Financial by Schwab Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist Whalen Financial in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of Whalen Financial’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of Whalen Financial’s accounts. Schwab Advisor Services also makes available to Whalen Financial other services intended to help Whalen Financial manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, 16  regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services rendered to Whalen Financial by independent third parties. Schwab Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to Whalen Financial. Whalen Financial is independently owned and operated and not affiliated with Schwab. B. Compensation to Non – Advisory Personnel for Client Referrals Whalen Financial does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, Whalen Financial will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Item 16: Investment Discretion Whalen Financial provides discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, Whalen Financial generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. Item 17: Voting Client Securities (Proxy Voting) Whalen Financial will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet 17  Whalen Financial neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Whalen Financial nor its management has any financial condition that is likely to reasonably impair Whalen Financial’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years Whalen Financial has not been the subject of a bankruptcy petition in the last ten years. 18