Description of the Advisory Firm Penney Financial, LLC is a registered investment advisor firm domiciled in Texas and has been conducting advisory business since January 2016. Cameron J. Penney, CFP® is the sole owner and Managing Partner of the firm. The firm is not a subsidiary of another legal entity, and it does not own another legal entity. Description of Advisory Services Offered Penney Financial, LLC is a fee-only financial advisory firm. Our advisors are required to act as a fiduciary – meaning, we are legally required to act in our clients’ best interest. Initially, we generally provide a Comprehensive Financial Plan to individuals or families for a flat fee. Following a Financial Plan, clients may choose to work with us in one of three ways: 1) Contributor Level -- hourly, as needed; 2) Consultant Level – ongoing advice only; 3) Confidant Level -- ongoing asset management and financial planning. Comprehensive Financial Planning and Hourly Consultations Our financial planning services may be general or broad-based in nature, or more narrowly focused on a particular area of interest or need -- depending on the client's unique circumstances and desires. Needed services may be addressed as one project or several projects contingent on the agreement of the client and advisor. Our Comprehensive Financial Plans generally include all the following:
• Retirement and retirement income planning
• Asset allocation and investment advice
• Tax planning
• Education planning
• Cash flow planning
• Strategic financing
• Insurance planning
• Estate planning
• Philanthropic planning Our process, utilized in working with our clients, is as follows: 1. First, we gather information about your situation and the advice being sought. If at the end of this meeting we agree on the extent and content of the advice needed, you are provided a Client Service Agreement that identifies the scope of our services. A signed Agreement is required prior to any work being done for you. In most cases, the initial fee is required also. 2. We will likely need to ask for additional documentation and detailed information about your specific situation. Once you return the additional documentation and/or detailed information, we will then analyze your current financial situation and create a Comprehensive Financial Plan. 3. Depending on your situation and needs, one or more meetings may be necessary in order to present our findings and recommendations. Prior to the meeting, interim meeting(s) may be necessary to clarify goals, data, assumptions, scenarios and strategies. Meetings may be held face-to-face or virtually utilizing technology of phone and/or the internet. We write and present advice containing observations, assumptions and recommendations. If needed, we can assist in a limited basis with implementation. The service for hourly and flat-fee financial planning is generally concluded upon completion of the presentation. You, the client, always have full discretion over all implementation decisions and are free to accept or reject any recommendation we make. You may re-engage us as needed or choose one of our Ongoing Service Options. Ongoing Service Options After we complete a Comprehensive Financial Plan, many clients will prefer an ongoing, advisory relationship. Our clients can choose from one of the following: 1) Contributor – We contribute to our client’s financial advisory needs and we are paid hourly, as needed. This is ideal for do-it-yourself investors who have a simpler and more manageable financial situation; therefore, we will normally not make this option available to clients with a net worth of $2 million or greater. 2) Consultant – We consult with our clients on an ongoing basis and are paid a fee based on the client’s net worth. This is generally for clients who prefer autonomy in managing their assets, but still desire a long-term, ongoing financial advisory relationship. This level of service includes an annual planning agenda tailored to a client’s financial situation. Typical services will include ongoing advice on almost every facet of a client’s financial life,

including tax-efficient cash flow, distribution planning, executive compensation strategies, annual enrollment changes, charitable/gift planning, retirement plan updates, progress towards goals, and periodic analysis of investment assets. 3) Confidant – We serve as our client’s trusted confidant. This level of service is generally for clients who have accumulated wealth and prefer a professional to manage and supervise their portfolio so that our clients can spend time on the activities they enjoy. In addition to professional Asset Management and an annual planning agenda, these clients receive ongoing financial planning and advice on nearly every facet of their financial lives. We provide asset management services on an ongoing, discretionary basis, as a percentage of assets under management. Asset Management Services (Confidant) Our Asset Management services are typically an extension of our financial planning services. During implementation of a Financial Plan and the client’s preference for us to manage their assets, we create and provide an Investment Policy Statement (IPS) that defines the objectives, scope, and parameters for how we manage assets in respect to the client’s goals, values and tolerance for risk that was previously discussed during the data gathering section of the engagement. Once the client and investment advisor have agreed and signed the client’s IPS, we will assist in setting up accounts to manage the client’s assets. Once we have begun managing a client’s assets, we are assigned discretion and authority to buy, sell, exchange, and rebalance the portfolio on our client’s behalf while adhering to the client’s IPS. In some situations, a client may choose to move forward with our Asset Management services before engaging in a Financial Plan. A similar data gathering process will occur. In other instances, Penney Financial, LLC maintains the authority and ability to charge additionally for financial planning fees on an hourly or flat-fee basis should it be necessary. Clients will always be notified in advance of incurring these fees. Generally, we primarily invest client assets in mutual funds and ETFs (Exchange Traded Funds); however, we can use ETNs (Exchange Traded Notes), individual stocks and individual bonds if deemed appropriate. The client may terminate an Asset Management engagement at any time. When we are notified of a termination of this service, we will stop the investment management fee and cease ongoing financial planning and ancillary services. We will keep the holdings as-is (we will not sell your holdings unless specifically instructed), but we will not be held responsible for the ongoing supervision and management of these holdings once a client has notified us (in writing) of a terminated Asset Management (Confidant) engagement. Wrap Fee Programs Penney Financial, LLC does not participate in or sponsor wrap fee investment management programs. Additional Information We do not provide legal, accounting or insurance services. We may work with other advisors such as attorneys, insurance professionals, tax professionals, with your permission, in the planning and implementation of your financial plan. If you are not currently working with an advisor, we may provide you with referrals or selection of other advisors at your request. You are not obligated in any way to work with any professional referred by us. These other advisors will charge you separately for their services and these fees will be in addition to our advisory fees. Our firm will use its best judgment and good faith effort in providing its services. In recognition of “Past performance is not a guarantee of future performance,” we cannot and do not warrant or guarantee any specific or general performance or profitability over any period or time of recommended investment strategies. Nothing in our client agreement is intended to diminish in any way our fiduciary obligation to act in your best interest or in any way limit or waive your rights under federal or state securities laws. As of December 31, 2023, Penney Financial, LLC managed $185,855,222 of client assets under discretionary authority. We had no client assets managed on a non-discretionary basis.