Sandy Morris Financial is an investment adviser registered with the Securities and Exchange Commission (“SEC”) and is a limited liability company (LLC) formed under the laws of the State of Florida.
• Sandeva O'Bryan Morris is the Managing Member and Owner of Sandy Morris Financial. Sandeva O'Bryan Morris owns 100.00% of Sandy Morris Financial.
• Sandy Morris Financial filed its initial application to become registered as an investment adviser in June 2015. Introduction The investment advisory services of Sandy Morris Financial are provided to you through an appropriately licensed and qualified individual who is an investment adviser representative of Sandy Morris Financial (referred to as your investment adviser representative throughout this brochure). Description of Advisory Services The following are descriptions of the primary advisory services of Sandy Morris Financial. Please understand that a written agreement, which details the exact terms of the service, must be signed by you and Sandy Morris Financial before we can provide you the services described below. Model Portfolio Management - Sandy Morris Financial offers model portfolio management to help manage customer accounts. Sandy Morris Financial has established a series of models that are invested products to meet the needs of the model and the objectives of the client. Sandy Morris Financial collects information from its clients such as financial information, investment objective and risk tolerance in the form of an Investment Policy Statement (“ISP”) to determine which models to place each client in. Sandy Morris Financial regularly monitors the models and rebalances the models quarterly if necessary. Asset Management Services – Sandy Morris Financial may offer asset management services, which involves Sandy Morris Financial providing clients with continuous and ongoing supervision over specified accounts. You must appoint our firm as your investment adviser of record on specified accounts (collectively, the “Account”). The Account consists only of separate account(s) held by qualified custodian(s) under your name. The qualified custodians maintain physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account. The Account is managed by us based on your financial situation, investment objectives and risk tolerance. We actively monitor the Account and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Account. We will need to obtain certain information from you to determine your financial situation and investment objectives. You will be responsible for notifying us of any updates regarding your financial situation, risk tolerance or investment objective and whether you wish to impose or modify existing investment restrictions; however, we will contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance or investment objectives. Sandy Morris Financial Page 5 Form ADV Part 2A Disclosure Brochure It is important that you understand that we manage investments for other clients and may give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you or actions we take for you. We are not obligated to buy, sell or recommend to you any security or other investment that we may buy, sell or recommend for any other clients or for our own accounts. Conflicts may arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed to be appropriate for your account(s) and other accounts advised by our firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit. Sandy Morris Financial may provide recommendations to Client to utilize specific sub-adviser(s) (individually “Sub-Adviser” and collectively Sub-Advisers) to manage Account or a portion of the assets of Account. Sandy Morris Financial will conduct due diligence

of any recommended Sub-Adviser and monitor the performance of Sub-Adviser with respect to the Sub-Advisor’s management of the designated assets of Account relative to appropriate peers and/or benchmarks. Sandy Morris Financial will be available to answer questions Client may have regarding any portion of Client’s Account managed by a Sub-Adviser and will act as the communication conduit between Client and the Sub-Adviser. Newsletters Sandy Morris Financial occasionally prepares general, educational and informational newsletters. Newsletters are always offered on an impersonal basis and do not focus on the needs of a specific individual. Seminars / Workshops Sandy Morris Financial offers educational, informative and motivational seminars / workshops to the public as well as to associations, family foundations and employers. Workshops are always offered on an impersonal basis and do not focus on the individual needs of the participants. Tailor Advisory Services to Individual Needs of Clients Sandy Morris Financial’s advisory services are always provided based on your individual needs. This means, for example, that when we provide asset management services, you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. Our consulting services are always provided based on your individual needs. When providing consulting services, we work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. We will not enter into an investment adviser relationship with a prospective client whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. Limits Advice to Certain Types of Investments Sandy Morris Financial Page 6 Form ADV Part 2A Disclosure Brochure Sandy Morris Financial typically provides investment advice on the following types of investments:
• Mutual Funds
• Exchange-listed Securities
• Variable Annuities
• Variable Life Insurance Although we generally provide advice on the products previously listed, we reserve the right to offer advice on any investment product that may be suitable for each client’s specific circumstances, needs, goals and objectives. It is not our typical investment strategy to attempt to time the market, but we may increase cash holdings modestly as deemed appropriate based on your risk tolerance and our expectations of market behavior. We may modify our investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.) Administrative Services Provided by Unaffiliated Service Providers Sandy Morris Financial may engage at its discretion unaffiliated service provider(s) to provide certain administrative and back-office services related to the asset management services provided Sandy Morris Financial to the Account. Such services provided by service provider(s) may include, but are not necessarily limited to, access to service provider’s technology platform and/or assistance with data reconciliation, performance and/or position reporting, fee calculation and billing, marketing and presentation materials, client database maintenance, quarterly performance evaluations, payable reports, web site administration, order entry, and other functions related to the administrative tasks of providing investment advisory services to the Account. Due to these arrangements, such service provider(s) will have access to the Account and/or Client’s information but will not serve as an investment advisor to Client. Service provider(s) will charge a fee to Sandy Morris Financial for providing administrative and back-office services, which may be based upon the value of the Account; however, any such fee is paid by Sandy Morris Financial from the portion of the overall investment advisory fee charged by Sandy Morris Financial. Client Assets Managed by Sandy Morris Financial As of December 31, 2023, Sandy Morris Financial had $137,599,857 in discretionary assets under management to report.