OWNERSHIP/ADVISORY HISTORY Western New York Financial Group, LLC (“We”) was founded in October 2019 by Michael Aquino. In January 2020, Mark Narby became our co-owner. We are a New York Limited Liability Company that is registered as an investment adviser with the Securities and Exchange Commission. We have two managing members, Mr. Aquino and Mr. Narby. Mr. Narby is also our Chief Compliance Officer. Additional information about Mr. Aquino and Mr. Narby can be found in their Supplemental Brochures. ADVISORY SERVICES OFFERED FINANCIAL PLANNING SERVICES We offer comprehensive financial planning and financial consulting services as well as estate settlement services. COMPREHENSIVE SERVICES Our comprehensive financial planning service involves a review of your financial situation, goals and risk tolerance. Through a series of personal interviews and the use of risk tolerance questionnaires we collect pertinent data, identify goals, objectives, financial problems, and potential solutions. With this information, we tailor your financial plan and our advice to you. Our advice may cover any of the following topics: net worth statement, cash flow analysis, tax analysis, insurance and long-term care analysis, tax planning strategies, retirement planning, 401k review, financial goal setting, risk management, college savings, and other needs identified during our meetings with you. You will receive a written financial plan following our meetings. FINANCIAL CONSULTING SERVICES With our financial consulting services, we focus on single topic or certain specific topics as identified between us and you. The chosen topics are written in the financial planning and consulting agreement. Typically, we do not provide a written financial plan for this service. ESTATE SETTLEMENT SERVICES We assist in the settlement of estates. We bring organization and peace of mind to a very difficult time. We do not take over the position of authority of the executor. Rather, we work with the executor to organize assets that could include the following services: gathering documents, assisting with filling out and filing documents, or assisting with insurance claims. PORTFOLIO MANAGEMENT Our portfolio management services include creating a tailor-made financial plan and providing ongoing investment management services. Through a series of personal interviews and the use of questionnaires, we will collect pertinent data and identify goals, objectives, financial problems, and potential solutions. With this information, we tailor your financial plan and our advice to you. Once you are satisfied with the financial plan, we will begin managing your account(s) and charging our management fee. Western New York Financial Group, LLC Page 6 ADV Part 2A – 3/26/2024 We manage your account based on our proprietary investment model. However, we adjust the management based on your financial situation, investment objectives and risk tolerance. We actively monitor your accounts and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the account. RECOMMENDATION OF THIRD-PARTY INVESTMENT ADVISERS We recommend and monitor third-party investment advisers (“Third-Party Advisers”). We may recommend one or more Third-Party Advisers to you. The recommendation will

depend on your circumstances, goals and objectives, desired strategy, account size, risk tolerance, and other factors. We work with you to determine which Third-Party Adviser may be appropriate. You are never obligated to use a recommended Third-Party Adviser. We review each Third-Party Advisers before making a recommendation to you. We consider the following factors during our review: fees, reputation, performance, financial strength, management, price, reporting capabilities, and your financial situation, goals, needs, and investment objectives. After our review, we will present you with one or more recommendations. If the you wish to proceed with the recommendation, we enter into a relationship with the recommended Third-Party Adviser. Under this relationship, the Third-Party Adviser is responsible for portfolio management, best execution, portfolio reporting, trading, trade error resolution, management fee collections and custodian reconciliations. We maintain our relationship with you by monitoring the status of your accounts with the Third-Party Adviser, making recommendations about the Third-Party Adviser, typically meeting with you either in person or by telephone on an annual basis, and acting as your primary financial adviser. You should direct all questions regarding the Third-Party Adviser’s services and performance to us. If you are referred to a Third-Party Adviser, you will receive full disclosure, including services rendered and management fee schedules. At the time of the referral we deliver a copy of the Third-Party Adviser’s Form ADV Part 2A or equivalent disclosure document. RETIREMENT PLAN CONSULTING We also provide retirement plan consulting services to qualified plans. Our services include participant enrollment and participant education. Addition services are negotiable based on the needs of the qualified plan. PONTERA (FORMERLY FEEX) 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 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 quarterly and allocation changes will be made as deemed necessary. Western New York Financial Group, LLC Page 7 ADV Part 2A – 3/26/2024 TAILORED SERVICES We document your goals and objectives before any investing takes place. You may impose restrictions on investing in certain securities or types of securities. WRAP PROGRAM We do not sponsor a wrap program. CLIENT ASSETS MANAGED As of December 31, 2023, we manage $51,190,823 in discretionary assets and $22,475,344 in non-discretionary assets.