WHELAN FINANCIAL

Firm Brochure Part 2A of Form ADV JANUARY 27, 2026  II. Material Changes Whelan Financial 7700 N. Palm Ave., Ste. 201 Fresno, CA 93711 Telephone: 559.228.8002 Email: info@whelanfinancial.com Web Address: www.whelanfinancial.com Material Change to Item IV: Advisory Business 01/27/2026 Effective January 1, 2026, there was a change in principal owner- ship from Vincent J. Whelan, CFP® to Portia L. White, CFP®, Taylor J. Whelan, CFP®, Stephen C. Detweiler, CFP®, and Kasandra A. Dieu. Material Change to Item VIII: Investment Strategies Whelan Financial now offers the WF AI Infrastructure Strategy and the WF AI Aggressive Growth Strategy. This brochure provides information about the qualifications and business practices of Whelan Financial. If you have any questions about the contents of this brochure, please contact us at 559.228.8002 or info@whelanfinancial. com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. The WF AI Infrastructure Strategy is an actively managed portfo- lio of individual stocks providing focused exposure to companies across the AI infrastructure ecosystem, including semiconductors, cloud platforms, data centers, and AI-enabled software. The strat- egy seeks long-term capital appreciation but involves elevated volatility and is intended for investors with a high risk tolerance and long-term investment horizon. Additional information about Whelan Financial is also available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identify- ing number, known as a CRD number. Our firm’s CRD number is 107227. The WF AI Aggressive Growth Strategy is an actively managed, blended portfolio seeking long-term capital appreciation by combining targeted AI exposure with high-quality growth compa- nies. The strategy allocates approximately 50% to the WF AI Infra- structure Strategy and 50% to the WF Quality Stock Sleeve, and is designed for investors with a high risk tolerance who can withstand elevated volatility and market fluctuations over a long-term horizon. Our Firm Brochure may be amended periodically. You may request a copy of our Firm Brochure at any time by contacting us at 559.228.8002.  III. Table of Contents I. Cover Page ...........................................................................................................................................1 II. Material Changes ............................................................................................................................. 2 III. Table of Contents .............................................................................................................................. 3 IV. Advisory Business .............................................................................................................................4 Wealth Management ..........................................................................................................5 Financial Planning ................................................................................................................5 Individual Portfolio Management ...................................................................................6 Retirement Plan Services ...................................................................................................6 3(38) Fiduciary Services......................................................................................................6 Participant Education ..........................................................................................................6 Portfolio Management .......................................................................................................6 Amount of Managed Assets ..............................................................................................6 V. Fees & Compensation...................................................................................................................... 7 Fees Charged by Whelan Financial ................................................................................ 7 For Wealth Management Services ................................................................................. 7 For Qualified Plan Investment Management Services ............................................ 7 For Financial Planning Only Services .............................................................................8 Assessing of Fees ..................................................................................................................8 Third Party Fees ....................................................................................................................8 VI. Performance-Based Fees & Side-By-Side Management .................................................8 VII. Types of Clients ..................................................................................................................................9 VIII. Investment Strategies, Methods of Analysis & Risk of Loss ............................................. 10 Investment Strategies ........................................................................................................ 10 Methods of Analysis ........................................................................................................... 12 Risk of Loss ............................................................................................................................ 13 IX. Disciplinary Information .............................................................................................................. 15 X. Other Financial Industry Activities & Affiliations ................................................................ 15 XI. Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ............................................................................ 16 XII. Brokerage Practices ...................................................................................................................... 17 Brokerage Trade Execution Practices .......................................................................... 17 Potential Conflicts of Interest .......................................................................................... 18 XIII. Review of Accounts ....................................................................................................................... 20 XIV. Client Referrals & Other Compensation ................................................................................ 20 XV. Custody .............................................................................................................................................. 21 XVI. Investment Discretion ................................................................................................................... 21 XVII. Voting Proxy ......................................................................................................................................22 XVIII. Financial Information ....................................................................................................................23  Page 4 IV. Advisory Business Whelan Financial, a California corporation, is an SEC registered investment advisor with its principal place of business located in Fresno, California. Registration does not imply a certain level of skill or training. Whelan Financial was established in 1988 and is owned by Portia L. White, CFP®, Taylor J. Whelan, CFP®, Stephen C. Detweiler, CFP®, and Kasandra A. Dieu. Form ADV Part 2A Page 5 Whelan Financial offers the following services: Wealth Management • Financial Planning • Individual Portfolio Management Retirement Plan Services • 3(38) Fiduciary Services • Participant Education • Portfolio Management Wealth Management In general, the financial plan may address any or all of the following areas: Personal Financial Goals: We help clients identify their short-, intermediate-, and long-term goals and measure their impact on the financial plan. invest- At Whelan Financial, we provide more than ment advice—we provide wealth management, which approaches investing from a financial planning perspec- tive. We understand the entirety of your financial picture and subsequently invest to meet your objectives. Financial Planning Tax & Cash Flow: Taxes are estimated as part of the cash flow projection and in light of financial strategies. We license tax planning software to help guide tax planning strategies. It is the responsibility of the client to verify the accuracy of these strategies with their tax professional and approve the implementation. In addition to individual portfolio management, we offer financial planning services. The combination of these services is referred to as wealth management. Investments: We build our portfolios to meet the return objective of the financial plan. Assets held outside of Whelan Financial are included in the analysis for projection purposes only. Assets held outside of Whelan Financial’s management, however, will not be actively monitored. Financial planning is an evaluation of a client’s current and future financial status by using assumptions to predict future cash flows, asset values, and withdrawal strate- gies. Clients are presented with an analysis that outlines a detailed financial plan designed to assist the client in achieving their financial goals and objectives. A copy of the analysis is provided upon request. Social Security: We evaluate the client’s social security options using information provided. We make a recom- mendation for the most suitable strategy considering personal objectives, goals, and financial needs. Insurance: As part of the process above, we provide obser- vations regarding health, life, disability, and long-term care insurance. We do not provide observations on multiple-line insurance. Clients are referred to their agent/broker for specific advice in this regard. The analysis is intended to measure variables known at the time it is developed. Changes in client circumstances or differences in projected variables could materially affect actual results. As such, we monitor these as part of our wealth management services. The accuracy of these projections is reliant upon information provided by the client on an ongoing basis. It is the responsibility of the client to implement any recommendation made by the advisor in accordance with the plan. Retirement: We analyze current savings strategies, retire- ment plan investment options, expense patterns, and Form ADV Part 2A  Page 6 Retirement Plan Services future income expectations to help the client achieve his or her retirement goals. Estate: We make observations pertaining to estate plan- ning needs and refer the client to an estate planning attor- ney when necessary. Whelan Financial assists companies through manage- ment of 401(k)s, pensions, profit-sharing plans, and other retirement plans. Our team meets with trustees quarterly to review investment performance and changes. Each plan is assigned, at minimum, one dedicated advisor and one client services team member. Individual Portfolio Management 3(38) Fiduciary Services Our firm provides investment management on a discre- tionary basis, which means that clients give Whelan Finan- cial authority to make investment decisions on their behalf. These decisions are guided by an Investment Policy State- ment (IPS). The IPS, with outlined stock-to-bond ratio, is based on the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. The IPS is approved by the client and the stock-to-bond ratio is reviewed during our quarterly meetings. If the client elects not to meet, the stock-to-bond ratio will be reviewed annually. Whelan Financial is a 3(38) fiduciary which helps mitigate the risks associated with being a trustee. We provide initial investment recommendations and ongoing guidance on stock-to-bond ratios tailored to your company’s unique needs. Our discretionary asset management includes investment options, the ongoing selecting participant monitoring of investments, and constructing model port- folios when available. Additionally, we handle proxy voting for all ERISA plans, provided the custodian or recordkeeper integrates with our proxy voting platform. Although we have a broad spectrum of investments avail- able to us, we primarily provide recommendations and advice regarding no-load mutual funds, exchange-traded funds (ETFs), and individual stocks. Participant Education Because some types of investments involve certain addi- tional degrees of risk, such as a concentration in individ- ual stocks, they will only be implemented or recommended when consistent with the client’s stated investment objec- tives, tolerance for risk, liquidity, and suitability. We provide annual financial wellness seminars, conduct semiannual new enrollment meetings, and work with the plan’s third-party administrator and/or recordkeeper to fulfill plan requirements. Portfolio Management Once the client’s portfolio has been established, it is reviewed no less frequently than annually. When neces- sary, the portfolios are rebalanced to meet their stated objectives. Whelan Financial customizes portfolios to meet your company’s unique needs. When appropriate, we offer custom managed portfolios for participant selection, in addition to a carefully selected panel of investments. Our Investment Committee continually reviews and monitors these recommendations. Amount of Managed Assets As of 12/31/2025, we were actively managing $781,750,987 of clients’ invested assets on a discretionary basis. Form ADV Part 2A Page 7 V. Fees & Compensation Fees Charged by Whelan Financial Whelan Financial’s rates are based upon the amount of money the client has hired us to manage. This is commonly referred to as assets under management (AUM). We may also offer fixed fee financial planning only services for clients without assets under management. For Wealth Management Services (Bundled Financial Planning & Investment Management) When AUM is greater than $500,000: The annual asset management fee will be 1% of assets under management. When AUM is less than $500,000: The annual asset management fee will be 1.5% of assets under management. When AUM is less than $250,000: The annual asset management fee will be 1.5% of assets under management, plus a $1,000 annual financial planning fee. For Qualified Plan Investment Management Services When AUM is greater than $1,000,000: The annual asset management fee will be 1% of assets under management. When AUM is less than $1,000,000: An additional annual service fee will be charged as follows: $5,000 per year until the plan has reached $500,000 in assets under manage- ment; and $2,500 per year thereafter until the plan has reached $1,000,000 in assets under management. Form ADV Part 2A  Page 8 For Financial Planning Only Services outlined in a letter of engagement or included in the Asset Management Agreement. For wealth management clients, financial planning is included in the fee above. For financial planning only services, a fixed fee will apply and be outlined in a letter of engagement. The Asset Management Agreement may be terminated at any time upon written notice by either party to the other. Any fees collected for any period beyond the termination of the contract are refunded to the client on a pro-rata basis. Assessing of Fees Third Party Fees Clients should be aware that there are additional fees related to investing that are not assessed by Whelan Finan- cial. Such fees include: Such fees shall be computed on a quarterly basis and billed in advance at the beginning of each calendar quarter at 0.25 times the annual rate, unless a client elects to use a custodian other than Charles Schwab and they require otherwise. The calculation uses account balances as of the last day of each calendar quarter. Fees may be prorated for partial quarters, including at inception or separation. Fees may also be assessed for mid-quarter contributions, but not reduced for mid-quarter withdrawals. Fees will be disclosed, in writing, to the client each quarter. Mutual Funds, Exchange Traded Funds (ETFs) & Cash Product Fees: Fees are charged by mutual funds and ETFs. These fees are typically referred to as expense ratios and are deducted by the fund company. Such fees are disclosed in fund prospectuses. Whelan Financial does not receive commissions, loads, or indirect fees for trades or investments placed in client accounts. Advisor will sell investments, in a manner consistent with the client’s asset allocation, in an amount sufficient to cover up to one year’s anticipated fees. Fees are debited directly from client accounts. Under no circumstances does Whelan Financial require payment of fees more than six months in advance of services rendered. Whelan Financial retains the discretion to negotiate alter- native fees on a client-by-client basis. We aim to charge reasonable fees for the services provided, however at times clients may request services outside of our stan- dard agreement. As such, we may negotiate fees based on the scope of the client’s needs. Associated fees would be Brokerage Fees: Clients are also responsible for fees and expenses charged by custodians, such as Charles Schwab. When in the client’s best interest, Whelan Financial uses investments that incur a flat fee for trades placed. These fees are generally between $0 and $35 per trade. On occa- sions when a client has an unexpected and immediate cash need, short-term redemption fees may be incurred at up to $50 per trade. Whelan Financial uses these investments when deemed financially in the best interest of the client. Please refer to the “Brokerage Practices” section (Item XII) of this Form ADV for additional information. VI. Performance-Based Fees & Side-by-Side Management Whelan Financial does not charge performance-based fees. Form ADV Part 2A Page 9 VII. Types of Clients Whelan Financial provides advisory services to the following types of clients: • High-net-worth individuals • Those other than high-net-worth individuals subject to special consideration • Trustees of trusts • Defined-contribution plans such as 401(k)s • Defined-benefit plans such as cash balance plans • 501(c)(3) nonprofit organizations • Corporations or other businesses not listed above Form ADV Part 2A  Page 10 VIII. Investment Strategies, Methods of Analysis & Risk of Loss Investment Strategies we deem to be high-quality with sustainable competitive advantages and strong capital allocation strategies. This long-term investment approach emphasizes companies with resilient financials and the ability to maintain market leadership. Due to its focused nature, the strategy may experience higher volatility compared to the S&P 500 and is subject to investment minimums. Whelan Financial (“WF”) provides a range of investment strategies focused on strategic asset allocation, risk-ad- justed returns, and long-term growth. Our approach integrates diversified portfolio construction, fundamen- tal research, and risk management to meet clients’ finan- cial objectives. The following outlines our core investment strategies: WF Portfolio with Quality Sleeve: This portfolio builds on the core WF Portfolio structure but includes the actively managed stock component of the Quality Sleeve. This strategy prioritizes capital appreciation while managing volatility through strategic asset allocation. Investors should assume this strategy has a higher volatility than that expe- rienced at the same stock-to-bond ratio of the correspond- ing WF Portfolio. WF Portfolios: These diversified portfolios allocate invest- ments across stock and bond funds, tailored to an investor’s risk tolerance. Growth-oriented portfolios (over 60% equity) prioritize capital appreciation while managing volatility, whereas more conservative portfolios (under 60% equity) focus on income generation and risk reduction. Fixed-in- come and cash-only portfolios may not achieve returns above inflation due to market conditions. US Large Cap Strategy: The U.S. Large Cap Strategy provides concentrated exposure to large-cap U.S. stocks through a combination of the WF Quality Sleeve and index- based investments. Designed for investors with higher risk Quality Stock Sleeve: The WF Quality Stock Sleeve is a carefully curated sleeve of individual stocks actively managed by Whelan Financial. Whelan Financial has developed a proprietary method for selecting companies Form ADV Part 2A Page 11 tolerance and long-term horizons, it aims to leverage the United States’ economic advantages while maintaining a level of volatility similar to the S&P 500. Direct Indexing: Whelan Financial offers direct indexing as a tax-efficient investment strategy that allows investors to gain exposure to an index while directly owning the under- lying securities. Unlike traditional index funds or ETFs, direct indexing provides greater flexibility in portfolio construction and tax management. This allows for enhanced tax-loss harvesting opportunities, portfolio customization (e.g., excluding specific sectors or stocks), and cost savings by avoiding fund-level expenses. While the goal is to track the performance of a benchmark index, slight variations may occur. This strategy is suitable for investors with substantial taxable accounts who seek enhanced tax efficiency and/or customization in their equity exposure. WF AI Infrastructure Strategy: The WF AI Infrastructure Strategy is a carefully curated, actively managed portfolio of individual stocks designed to provide focused exposure to companies supporting the artificial intelligence ecosys- tem. The strategy invests across the AI infrastructure supply chain, including semiconductor design and manufactur- ing, cloud platforms, networking, data centers, servers and storage, and AI-enabled software and services. Holdings are selected using defined criteria to ensure meaningful AI exposure and portfolio diversification. Companies generally must derive a significant portion of revenue from AI-related activities (typically 20% or more) and have a minimum market capitalization of approx- imately $5 billion. Individual positions are market-cap weighted and typically capped at approximately 5% of the portfolio. The portfolio is reviewed on an ongoing basis and rebalanced quarterly to maintain alignment with the strategy’s objectives. This strategy seeks long-term capital appreciation simi- lar to a market-cap-weighted index, but with a dedi- cated focus on AI infrastructure, and is benchmarked to the Nasdaq Composite. Due to its concentrated exposure, the strategy may experience elevated volatility, including significant drawdowns, sector concentration risk, valua- tion risk, and sensitivity to macroeconomic and geopolitical factors. The WF AI Infrastructure Strategy is intended for investors with a high risk tolerance and long-term invest- ment horizon who can withstand substantial market value fluctuations that may exceed those of the S&P 500. This strategy is subject to investment minimums. Form ADV Part 2A Page 12 Individual Stock Analysis: Each investment has been selected from a list of potential alternatives. We conduct extensive qualitative and quantitative research in the construction of our portfolios. We consider this research to be exclusive and proprietary. WF AI Aggressive Growth Strategy: The WF AI Aggressive Growth Strategy is an actively managed blended port- folio seeking long-term capital appreciation. The strat- egy allocates approximately 50% to the WF AI Infrastruc- ture Strategy, providing focused exposure to companies across the AI supply chain, and 50% to the WF Quality Stock Sleeve, emphasizing high-quality companies with durable competitive advantages and disciplined capital allocation. Portfolio Analysis: Once the funds have been selected, we leverage third-party software to analyze the composition of the underlying holdings in the construction of the portfo- lio. Each portfolio is designed to meet the client’s individual goals, needs, and objectives using parameters established by the Committee, such as: The portfolio is rebalanced quarterly using tax-efficient methods and is benchmarked to the S&P 500. Due to its growth-oriented and thematic structure, the strategy may experience elevated volatility, sector concentration, valua- tion risk, and sensitivity to market cycles and interest rates. This strategy is intended for investors with a high risk toler- ance and long-term investment horizon who can withstand significant market fluctuations that may exceed those of the S&P 500. This strategy is subject to investment minimums. • Stock-to-bond ratio • Growth vs. value • Fixed income quality, maturity, and duration • Geometric market capitalization • Foreign vs. total stock percentage • Overlap of underlying investments Cash Management: Designed to preserve principal while optimizing yield, this strategy invests in a laddered port- folio of U.S. Treasuries and FDIC-insured Certificates of Deposit (CDs), typically with staggered maturities of 3, 6, 9, and 12 months. This structured approach enhances liquid- ity, enables reinvestment flexibility, and benefits from a rising interest rate environment. This strategy is intended for investors seeking a low-risk, yield-generating solution, for short-term cash holdings. Methods of Analysis Whelan Financial’s Investment Committee (Committee) is responsible for researching, approving, and monitoring all investments and portfolio designs offered by Whelan Financial. The Committee regularly re-evaluates the list of selected investments to ensure the investments have main- tained their role within the portfolio and their competitive standing against their peer groups. Mutual Fund and/or ETF Analysis: Each investment has been selected from a list of potential alternatives that satisfy the Committee’s research and analysis criteria. Initial search parameters include, but are not limited to: • Expense • Risk • Performance • Rank vs. category • Manager tenure and track record • Underlying holdings • Morningstar® Ratings: Star and analyst ratings Form ADV Part 2A Page 13 Risk of Loss Whelan Financial primarily manages portfolios of mutual funds, ETFs, and individual stocks depending on risk tolerance and investment strategy. The portfolio will be managed through broad diversification in order to mini- mize non-systemic (or “business”) risk. Systemic (market, interest rate, purchasing power, currency, etc.) risk shall be managed via asset allocation which will diversify the client’s portfolio between stock, bond, and other markets as deemed appropriate by the Committee. The objective of a client’s portfolio is to obtain a return, over time, commensurate with the level of risk it has against a suitable and widely used benchmark, such as the Stan- dard & Poor’s 500. Please note that past investment perfor- mance does not guarantee future results. Types of Investment Risks: Investments that we make on behalf of our clients are subject to various types of invest- ment risks. Below is a list, with brief descriptions of some of the more common types of risk. This list is not exhaustive and not every type of risk will apply to every investment. • Individual Business Risk: The risk that individual stocks may experience management changes, product failures, litigation, or competitive pressures. This could lead to substantial losses even in a rising market; diversification may mitigate but not eliminate this risk. • Market Risk: The risk of losses due to movements in market prices. This encompasses the risk of loss due to the movements in prices of securities like equities, bonds, and commodities, reflecting changes in economic factors, market sentiment, and global events that affect the entire market or major segments of it. • Liquidity Risk: The risk of not being able to quickly sell an investment at its current market value due to insufficient market activity, potentially requiring a sale at a signifi- cant discount. • Tax Efficiency Risk: The risk that investment strategies generate taxable income, capital gains, or distribu- tions that are not aligned with an investor’s tax situation, potentially reducing after-tax returns. Portfolio turn- over, asset location decisions, changes in tax laws, or the timing of transactions may result in higher-than-antici- pated tax liabilities. • Inflation Risk: The risk that an investment may not keep pace with inflation, eroding purchasing power over time, especially in low-yield environments or with rising infla- tion rates. • Reinvestment Risk: The risk that proceeds from a matur- ing security are reinvested at lower interest rates, which could reduce overall yields and returns. • Sector Risk: The risk that strategies concentrated in a particular market sector experience heightened vola- tility or losses due to factors affecting that sector, such as economic conditions, industry cycles, technological change, supply chain disruptions, regulatory or legis- lative developments, or shifts in investor sentiment. Concentrated sector strategies may also be adversely impacted by changes in market expectations, valuation compression, or slower-than-anticipated growth, which could result in periods of underperformance relative to more broadly diversified portfolios. • Operational and Cybersecurity Risk: The risk that third- party platforms, such as data providers or technology used for analysis and execution, suffer system failures, data inaccuracies, or cyber threats. This could impact portfolio management or client data security. Form ADV Part 2A Page 14 • Valuation Risk: The risk that an investment is priced above its intrinsic or fundamental value, which may limit future returns or lead to declines in value if market expectations, growth assumptions, or investor sentiment change. Elevated valuations may increase sensitivity to interest rates, earnings disappointments, or broader market corrections, potentially resulting in periods of underperformance or loss. • Foreign Exchange Risk: The risk of loss from unfavorable changes in exchange rates, affecting the value of invest- ments that involve foreign currencies. • Concentration Risk: The risk from significant invest- ment in a particular asset class, sector, or region, lead- ing to increased vulnerability to market, economic, or sector-specific downturns. • Credit Risk: The risk that a borrower will fail to repay a loan or meet contractual obligations, leading to losses for the lender. • Interest Rate Risk: The risk that changes in interest rates will affect the value of investments, especially bonds, as an investment’s value may change due to a change in interest rates. • Behavioral Risk: The risk of investment losses due to psychological biases or irrational behavior, including overconfidence, herd behavior, and loss aversion. Behav- ioral risk highlights the impact of human emotion and psychology on financial decisions and market dynamics. Risks For All Forms of Analysis: All analysis relies upon the accuracy of information provided by third-party research software. • Geopolitical and Supply Chain Risk: The risk that invest- ments with exposure to global operations or supply chains are adversely affected by geopolitical events, trade poli- cies, regulatory actions, natural disasters, or international conflicts. Such disruptions may impair business opera- tions, increase costs, or negatively impact market valua- tions, potentially resulting in material declines in portfolio value. Material Risks of Investing: Investment in securities involves the potential for loss, which clients should be prepared to bear. A fund may offer several share classes for investment at varying expenses. Whelan Financial may be limited in our ability to select the lowest costing share class. Investors in higher costing share classes generally experience lower returns than investors in lower costing share classes. Whelan Financial is not responsible for the taxes generated from the sale of investments, which may lower a client’s net investment gain. • Tracking Error Risk: The risk that efforts to replicate an index (such as our direct indexing strategy) may result in performance deviations due to bid-ask spreads, tax-loss harvesting, custom exclusions, or trades placed at disad- vantageous times, potentially causing the portfolio to underperform its benchmark. Form ADV Part 2A Page 15 IX. Disciplinary Information Whelan Financial has no reportable legal or disciplinary events to disclose. X. Other Financial Industry Activities & Affiliations Our firm and our related persons are not engaged in other financial industry activities and have no other industry affiliations. Form ADV Part 2A Page 16 XI. Code of Ethics, Participation or Interest in Client Transactions & Personal Trading the various provisions of the Advisors Act and also requires that all supervised persons comply with the various appli- cable provisions of the Investment Company Act of 1940, as amended, the Securities Act of 1933, as amended, the Securities Exchange Act of 1934, as amended, and appli- cable rules and regulations adopted by the Securities and Exchange Commission (SEC). Whelan Financial places the highest priority on maintaining its reputation for integrity and professionalism. That repu- tation is a vital business asset. The confidence and trust placed in our firm and its employees by our clients is some- thing we value and endeavor to protect. Whelan Financial and our personnel owe a duty of loyalty, fairness, and good faith towards our clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics (Code) but to the general principles that guide the Code. Our firm has adopted a Code which sets forth high ethi- cal standards of business conduct that we require of our employees, including compliance with applicable federal securities laws. Whelan Financial’s Code sets forth policies and procedures to achieve these goals. The Code is intended to comply with Form ADV Part 2A Page 17 employees to invest for their own accounts. Our firm and/or individuals associated with our firm may buy or sell, for their personal accounts, securities identical to or different from those recommended to our clients. The Code includes policies and procedures for the review of employee quarterly securities transactions reports, as well as initial and annual securities holdings reports that must be submitted by the firm’s access persons. Among other things, the Code prohibits any acquisition of securities in a limited offering (e.g., private placement) or an initial public offering (IPO) unless prior authorization is received. The Code also provides for oversight, enforcement, and record-keeping provisions. Additionally, any related person(s) may have an interest or position in certain securities which may also be recom- mended to a client. All security recommendations, however, must first be approved by the Whelan Financial Investment Committee. The Code further includes the firm’s policy prohibiting the use of material non-public information. All employees are reminded that such information may not be used in a personal or professional capacity. It is the expressed policy of our firm that no person employed by us may knowingly purchase or sell any secu- rity prior to a transaction(s) being implemented for an advisory account, thereby preventing such employee(s) from benefiting from transactions placed on behalf of advisory accounts. Whelan Financial and individuals associated with our firm are prohibited from engaging in principal transactions and in agency cross transactions. A copy of the Code is available to our advisory clients and prospective clients. You may request a copy by email sent to info@whelanfinancial.com, or by calling us at 559.228.8002. The Code is designed to assure that the personal securities transactions, activities, and interests of Whelan Financial employees will not interfere with our ability to make deci- sions and implement strategies that are in the best inter- est of advisory clients while, at the same time, allowing XII. Brokerage Practices Brokerage Trade Execution Practices needs. Although we suggest that clients establish accounts at Charles Schwab, it is ultimately their decision. Whelan Financial is not a custodian. Client assets must be maintained in an account at a “qualified custodian,” gener- ally a broker-dealer or bank. Whelan Financial is inde- pendently owned and operated, and not affiliated with any broker-dealer. Whelan Financial has evaluated Charles Schwab and believes that it will provide our clients with a blend of execu- tion services, competitive commission costs, and profes- sionalism that will assist our firm in meeting our fiduciary obligations to clients. Not all advisors recommend that their clients use one custodian over another. We are not required to select the broker or dealer that charges the lowest transaction costs, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades There are various broker-dealer institutions at which our clients’ assets are custodied. These custodians include, but are not limited to, Charles Schwab and Capital Group. However, we are best equipped to manage client accounts held at Charles Schwab, a FINRA registered broker-dealer and SIPC member. As such, we recommend that clients hold (custody) assets there. This allows us to affect trades, assist with account maintenance and facilitate client service Form ADV Part 2A Page 18 Certain trades (for example, many mutual fund and ETF trades) may not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in client accounts by utilizing Schwab’s Cash Features Program. through Schwab, we have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of clients’ trades. Best execution means the most favorable terms for a transaction based on all rele- vant factors, including those listed above. By using another broker or dealer one may pay lower transaction costs. It is Whelan Financial’s policy to periodically review Charles Schwab’s best execution practices against other custodi- ans to ensure that clients are receiving reasonable value for custodian rates. Our review includes comparing overall services received for fees charged. Whelan Financial will execute block trades of ETFs and securities where possible. This blocking of trades permits the aggregation of securities comprised of assets from multiple client accounts. Block trading may allow us to execute equity trades in a timelier, more equitable manner, so that the client receives a pro-rata share of the aver- age share price. Please contact us for a copy of our block trading policy. At present, there are no transaction fees incurred when purchasing exchange-traded equities through Schwab. However, Schwab may assess other fees; please see the Charles Schwab Pricing Guide for additional information (www.schwab.com/pricingguide). For our clients’ accounts that Schwab maintains, Schwab generally does not charge separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the Schwab account. Potential Conflicts of Interest Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like Whelan Finan- cial. They provide us and our clients with access to their institutional brokerage services (trading, custody, report- ing, and related services), many of which are not typically available to Schwab retail customers, and are known as soft dollar arrangements. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis and at no charge to us. The following is a more detailed description of Schwab’s support services. Services that Directly Benefit Clients: Schwab’s institu- tional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products avail- able through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit clients and their accounts. Form ADV Part 2A Page 19 Services That Generally Benefit Only Whelan Finan- cial: Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs Services That Indirectly Benefit Clients: Schwab also makes available to us other products and services that benefit Whelan Financial but do not directly benefit clients or their accounts. These products and services assist us in managing and administering our clients’ accounts and operating our firm. They include investment research, both Schwab’s own and that of third parties. We use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Schwab. • Publications and conferences on practice manage- ment and business succession In addition to investment research, Schwab also makes available software and other technology that: • Provide access to client account data (such as dupli- cate trade confirmations and account statements) In evaluating whether to recommend that clients custody their assets at Charles Schwab, we do not take into account these benefits. We consider the nature, cost, and quality of custody and brokerage services provided by Charles Schwab. • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data We recognize that discounts on various Charles Schwab and other products may create a potential for conflict of interest. Whelan Financial’s code of ethics requires that client transactions take priority over any personal transac- tions for employees at Whelan Financial. • Facilitate payment of our fees from our clients’ accounts • Assist with back-office functions, recordkeeping, and client reporting We reserve the right to decline acceptance of any client account for which the client directs the use of a broker other than Charles Schwab, if we believe that this choice would hinder our fiduciary duty to the client and/or our ability to service the account. Form ADV Part 2A Page 20 XIII. Review of Accounts portfolios are also monitored by the Whelan Financial Investment Committee. Reviews: All portfolios are reviewed with clients on a quar- terly basis, provided they elect to meet with their advi- sor. Each review considers the client’s stated risk toler- ance, investment objectives, investment policy statement (IPS), and financial plan, where sufficient documentation has been provided. If a client chooses not to attend their quarterly meeting(s), their portfolio will still be reviewed at least annually. More frequent reviews may be triggered by material changes in the client’s individual circumstances. Reports: Clients with assets held at Whelan Financial’s recommended custodian, Charles Schwab, will receive quarterly statements at a minimum. Should an account have qualifying transactions, such as deposits or with- drawals, they will receive a monthly statement including transaction confirmations. Monthly statements are avail- able online at Schwab Alliance (https://www.client.schwab. com). Additionally, Whelan Financial will provide quarterly reports online, which summarize balances, holdings, and performance net of expense. Additionally, Whelan Financial’s trading software enables the trading team to monitor client accounts daily to confirm that portfolio allocations align with the approved IPS. Investments and investment strategies within client XIV. Client Referrals & Other Compensation It is Whelan Financial’s policy not to pay related or non-related persons for referring potential clients to our firm or to accept any form of compensation for referring clients to outside firms. It is Whelan Financial’s policy not to accept or allow our Investment Advisors or any staff to accept any form of compensation, including cash, from a non-client in conjunction with the advisory services we provide to our clients. Form ADV Part 2A Page 21 XV. Custody In accordance with SEC guidance issued in 2017, Whelan Financial is considered to have custody in certain client accounts, as explained below. Whelan Financial and Charles Schwab collectively satisfy all necessary require- ments to preclude annual surprise audits. Schwab does not calculate the amount of the fee to be deducted. Although we make every effort to ensure the accuracy of our billing, we encourage clients to review their custodial statements to verify the accuracy of the calcu- lation. We send remittance invoices on a quarterly basis. Clients should contact us directly if they believe that there is an error. Our firm directly debits advisory fees from client accounts. As part of this billing process, the client’s actual custodian (Charles Schwab) is advised of the amount of the fee to be deducted from that client’s account. On at least a quarterly basis, the custodian is required to send to the client a state- ment showing all transactions within the account during the reporting period. In addition to the periodic brokerage statements that clients receive directly from their custodians, we provide invest- ment performance reports to our clients on a quarterly basis. We notify our clients in writing to carefully compare the information provided in these reports to the statements provided by their custodian(s) to ensure that all account transactions, holdings, and values are accurate. XVI. Investment Discretion The advisor will propose an initial portfolio design based on the client’s needs and risk tolerance. Based on the client’s feedback, the advisor may revise the proposed portfolio. Our firm provides investment management on a discre- tionary basis, which means that clients give Whelan Finan- cial authority to make investment decisions on their behalf formalized by the asset management agreement. Investment discretion is attained through the custo- dian’s Limited Power of Attorney signed by the client. These authorities and limitations may be changed and/ or amended by providing the custodian with written instructions. Whelan Financial’s Investment Committee is responsible for researching, approving, and monitoring all investments and portfolio designs offered by Whelan Financial. These investments will be primarily, but not limited to, no-load mutual funds, ETFs, and individual securities. All invest- ments will be made pursuant to the IPS and into specific investments recommended by the advisor and approved by the Committee. At times, a client may request a specific investment to be held in their portfolio in which case the monitoring of such investment will be limited to concentra- tion risk. Whelan Financial also specializes in providing discretionary investment management services to qualified plans (i.e. 401(k)s) and defined-benefit plans (i.e. cash balance plans) The client gives the advisor the discretion to rebalance, reallocate, add or remove investment categories, and add or remove investments. Changes must be consistent with the client’s stock-to-bond ratio and tolerance for risk as outlined within the client’s Investment Policy Statement (IPS). The IPS is based on the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. The IPS is approved by the client. Form ADV Part 2A Page 22 under ERISA (Employee Retirement Income and Securities Act). For these plans we act as a 3(38) fiduciary, unless otherwise indicated by the service agreement. While Whelan Finan- cial is deemed to be a fiduciary to all of our advisory clients, we are also an investment manager (as defined in section 3(38) of ERISA) with respect to certain clients’ employee benefit plans. A fiduciary is held to a higher standard than a suitability standard and is required to give advice in the best interest of the client. A 3(38) fiduciary, specifically, acts in the client’s best interest when selecting, monitoring, and replacing investments. As such, our firm is subject to specific duties and obligations under ERISA and the Internal Reve- nue Code that include, among other things, restrictions concerning certain forms of compensation. XVII. Voting Proxy proxies were voted. We will promptly provide the requested information to the client. Whelan Financial votes proxy for all clients provided that their accounts integrate with our proxy voting platform, unless otherwise indicated in the Client’s Asset Manage- ment Agreement. Clients who wish to retain proxy voting responsibilities may also do so by instructing us in writing not to vote proxy on their behalf. With respect to ERISA accounts, we will vote proxy unless we are advised by the client that the plan documents specifically reserve the plan sponsor’s right to vote proxy. To direct us to vote proxy in a particular manner, clients should contact info@whelanfinancial.com. For accounts where we do not vote proxy and our firm provides investment advisory services, clients maintain exclusive responsibility for: (1) directing the manner in which proxy statements solicited by issuers of securities beneficially owned by the client shall be voted, and We have contracted Institutional Shareholder Services (ISS) to vote proxy in the best interest of our clients and in accor- dance with our established policies and procedures. Our policy is to instruct ISS to vote in a manner consistent with maximizing long-term shareholder value. As part of their service, ISS will retain all proxy voting books and records for the requisite period of time, including a copy of each proxy statement received, a record of each vote cast, and the rationale for decisions on how to vote proxy. We will maintain a copy of each written client request for informa- tion on how the advisor voted proxy. If ISS has a conflict of interest in voting on a particular action, we will notify the client of the conflict and give them the opportunity to vote the proxy themselves. (2) making all elections relative to any mergers, acquisi- tions, tender offers, bankruptcy proceedings, or other types of events pertaining to the client’s investment assets. Clients are responsible for instructing each custodian of the assets to forward to the client copies of all proxy and shareholder communications relating to the clients’ investment assets. Clients may also request, in writing, information on how Form ADV Part 2A Page 23 XVIII. Financial Information Whelan Financial has no adverse financial circumstances to report. Under no circumstances do we require or solicit payment of fees more than six months in advance of services rendered. Therefore, we are not required to include a financial statement. Whelan Financial has not been the subject of a bankruptcy petition at any time. Form ADV Part 2A