About Us Davies Financial Advisors is a registered investment adviser offering financial planning and asset management services to clients. Davies Financial Advisors has been in business since 2004, and its principal owner is Andrew J. Davies who began working in the financial services industry in 1999 as a registered representative. The firm was registered with the SEC as an investment adviser in 2022. This brochure is designed to provide detailed and clear information relating to each item noted in the table of contents. Certain disclosures are repeated in one or more items, and/or other items are referred to to be as comprehensive as possible on the broad subject matters discussed. Within this brochure, certain terms in either upper- or lowercase are used as follows:  “We,” “us,” and “our” refer to Davies Financial Advisors.  “Advisor” refers to persons who provide investment recommendations or advice on behalf of Davies Financial Advisors.  “You,” “yours,” and “client” refer to clients of Davies Financial Advisors and its advisors. Description of Services Available Davies Financial Advisors offers to its clients a suite of investment advisory services and programs. Our investment advisory services and programs are designed to accommodate a wide range of client investment philosophies, goals, needs, and investment objectives. Through these various advisory programs and services, clients have access to a wide range of securities products, including, but not limited to, common and preferred stocks; municipal, corporate, and government fixed income securities; mutual funds; exchange-traded products (“ETPs”); options and derivatives; unit investment trusts (“UITs”); and variable and fixed-indexed insurance products, as well as other products and services, including a variety of asset allocation services, financial planning, and consulting services. We also offer advice related to direct participation programs, private placements, and other alternative investments, such as alternative energy programs, research and development programs, leasing programs, real estate programs, private equity funds, and pooled commodities futures programs. Davies Financial Advisors offers the following programs: Individual Financial Planning Services We provide analyses and advice to clients on matters related to finance and securities. Some clients are provided a written plan that may include a personal balance sheet and certain projections. Any reports, financial statement projections, and analyses are intended exclusively for your use in developing and implementing your financial plan. In view of this limited purpose, the statements should not be considered complete financial statements. Davies Financial Advisors will not audit, review, or compile financial statements, and accordingly, we will not express an opinion or other form of assurance on them, including the reasonableness of assumptions and other data on which any prospective financial statements are based. It is likely that there will be material differences between projected and actual results because events vary and circumstances frequently do not occur as expected. Our analyses will be highly dependent on certain economic assumptions about the future. Therefore, you should establish familiarity with historical data regarding key assumptions such as inflation and investment rates of return, as well as an understanding of how significantly these assumptions affect the results of our analyses. We may counsel you as to the consistency of your assumptions with relevant historical data, but we will not express any assurance as to the accuracy or reasonableness of your specific data and assumptions. You are ultimately responsible for the assumptions and personal data upon which our procedures and projections are based. The financial plan assumptions and reports are primarily a tool to alert you to certain possibilities. The reports are not intended to nor do they provide any guarantee about future events including your investment returns. If and where you choose to implement the financial plan we design for you is entirely up to you. The financial plans provided for some of our clients do not address all potential aspects of financial planning. Typically, our plans address various combinations of investment planning, retirement planning, business owner planning, education funding, estate planning analysis, and risk management issues such as life, disability, and long-term care insurance. Property and casualty and other similar risk management issues are not always addressed, and you are encouraged to ask us about these issues. When providing solely financial planning services, Davies Financial Advisors does not manage client investment portfolios or provide investment supervisory services. We do not provide specific securities recommendations or facilitate any transactions on your behalf. We limit our securities recommendations to an asset allocation we believe suitable for your risk tolerance and objective needs. Clients interested in portfolio management services may engage us for one or more of the asset management programs described below but are not required to do so. Davies Financial Advisors Discretionary Investment Management Our firm also offers asset management services. Our asset management program enables you, with the guidance of our advisors, to invest in a wide range of securities products. These products include, but are not limited to, common and preferred stocks, corporate and municipal bonds, mutual funds, exchange-traded products (such as exchange-traded funds), and unit investment trusts. The advisor typically acts as portfolio manager with full investment discretion although clients may elect to have the advisor manage the account on a nondiscretionary basis. When engaged to provide asset management services, our advisors will gather information on a client’s financial history, income and expenses, goals and objectives and assist the client in developing an appropriate asset allocation strategy based on the client’s unique individual needs. In general, clients will provide discretionary authority to Davies Financial Advisors which enables your advisors to place trades in your account in accordance with the established objectives of the account, but without the need for the client to approve each trade in advance. The account is monitored by your advisor on a regular basis, and your advisor will meet with you no less than annually to review the account’s holdings and performance. Fees for our asset management services are described in Item 5 of this brochure and are based on the level of assets in your managed account. Commonwealth Programs Davies Financial Advisors has entered into an agreement to offer clients access to certain programs offered by Commonwealth Financial Network (“Commonwealth”), an SEC-registered investment adviser. Specifically, Commonwealth’s Retirement Plan Consulting program, PPS Custom and PPS Select account programs are available to our clients. Retirement Plan Consulting The Retirement Plan Consulting program allows our advisors to provide a fee-for-service consulting program whereby advisors offer onetime or ongoing advisory services to qualified retirement plans. Clients may engage our advisors for Retirement Plan Consulting services on a negotiated hourly, flat, fixed, or asset-based fee basis. The maximum annual consulting fee, when stated as a percentage of assets, is 1.40% and is negotiable. Fees may be paid at the time of service, in advance of service, or after service has been rendered. If fees are being charged on an hourly basis, they may not exceed $500 per hour. Through the Retirement Plan Consulting Program, advisors assist plan sponsors with their fiduciary duties and provide individualized advice based upon the needs of the plan and/or plan participants regarding investment management matters, such as:  Investment policy statement support  Investment selection and monitoring  Overall portfolio composition  Participant advice programs PPS Custom and PPS Select Our firm offers Commonwealth’s PPS Custom and PPS Select programs as noted above. Within the PPS Custom program, Davies Financial Advisors will assist clients in the development of personalized asset allocation programs. In the case of the PPS Select program, Davies Financial Advisors will assist clients in selecting a portfolio option appropriate for the client’s risk tolerance, while portfolio management is provided by Commonwealth’s Investment Management and Research team. Clients who participate in one or more of Commonwealth’s programs will receive Commonwealth’s Form ADV Part 2 and/or Wrap Fee Brochure, in addition to Davies Financial Advisors’ Form ADV Part 2. Clients should refer to Commonwealth’s Form ADV Part 2 and/or Wrap Fee Brochure for detailed information about Commonwealth and Commonwealth’s programs. The specific advisory program selected by the client may cost the client more or less than purchasing program services separately. Factors that bear upon the cost of a particular advisory program in relation to the cost of the same services purchased separately include, but may not be limited to, the type and size of the account; the historical or expected size or number of trades for the account; the types of securities and strategies involved; the amount of fees, commissions, and other charges that apply at the account or transaction level; and the number and range of supplementary advisory and client-related services provided to the account. Lower fees for comparable services may be available from other sources. Investment recommendations and advice offered by Davies Financial Advisors and its advisors do not constitute legal, tax, or accounting advice. Clients should coordinate and discuss the impact of the financial advice they receive from their advisor with their attorney and accountant. Clients should also inform their advisor promptly of any changes in their financial situation, investment goals, needs, or objectives. Failure to notify the advisor of any material changes could result in investment advice not meeting the changing needs of the client. IRA Rollover Considerations As part of our financial planning and advisory services, we may provide you with recommendations and advice concerning your employer retirement plan or other qualified retirement account. When appropriate, we may recommend that you withdraw the assets from your employer’s retirement plan or other qualified retirement account and roll the assets over to an individual retirement account (“IRA”) to be managed by our firm or a Third-Party Manager that we recommend. If you elect to roll the assets to an IRA under our management, we will charge you an asset-based

fee as described in Item 5. This practice presents a conflict of interest because our Advisory Representative has an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if you do complete the rollover, you are under no obligation to have your IRA assets managed under our program or a Third-Party Managed Program. You have the right to decide whether to complete the rollover and the right to consult with other financial professionals. Some employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of each. An employee will typically have four options: 1. Leave the funds in your employer’s (former employer’s) plan. 2. Roll over the funds to a new employer’s retirement plan. 3. Cash out and take a taxable distribution from the plan. 4. Roll the funds into an IRA rollover account. Each of these options has advantages and disadvantages. Before making a change, we encourage you to speak with your financial advisor, CPA and/or tax attorney. Before rolling over your retirement funds to an IRA for us to manage or to a Third-Party Managed Program, carefully consider the following. NOTE: This list is not exhaustive. 1. Determine whether the investment options in your employer’s retirement plan address your needs or whether other types of investments are needed. a. Employer retirement plans generally have a more limited investment menu than IRAs. b. Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. 2. Your current plan may have lower fees than our fee and/or the Third-Party Manager’s fee combined. a. If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer’s retirement plan and how the costs of those share classes compare with those available in an IRA. b. You should understand the various products and services available through an IRA provider and their costs. c. It is likely you will not be charged a management fee and will not receive ongoing asset management services unless you elect to have such services. If your plan offers management services, the fee associated with the service may be more or less than our fee 3. Our management strategy may have higher risk than the options provided to you in your plan. 4. Your current plan may offer financial advice, guidance, management and/or portfolio options at no additional cost. 5. If you keep your assets titled in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state varies. Generally, Federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies; however, there can be exceptions. Consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire us or another firm as the manager and keep the assets titled in the plan name. It is important that you understand your options, their features, and their differences, and decide whether a rollover is best for you. If you have questions, contact us at our main number listed on the cover page of this brochure. Department of Labor Prohibited Transaction Exemption 2020-02 The Department of Labor has adopted a five-part test that defines when a firm or financial professional is acting as an investment advice fiduciary under Title I of the Employee Retirement Income Security Act (ERISA) and the Internal Revenue Code. Specially, an investment professional will be deemed to be an investment advice fiduciary when they render advice 1) to a plan, plan fiduciary, or IRA owner regarding the value of securities or property or make recommendations; 2) on a regular basis: 3) pursuant to a mutual agreement or understanding; 4) that will serve a primary basis for an investment decision; and 5) that is individualized to the particular needs of a plan or IRA. Based on this five-part test, Davies Financial Advisors acts as an ERISA investment advice fiduciary to the extent the firm and its advisor(s) make a recommendation to move assets from a plan to another plan or IRA, from an IRA to another IRA or plan, or to change the type of account the Retirement Investor is currently invested (e.g., advisory to brokerage or vice versa). To allow the receipt of compensation on this advice, the DOL issued Prohibited Transaction Exemption 2020-02 Improving Investment Advice for Workers & Retirees (PTE 2020-02). Davies Financial Advisors and our advisors can provide this advice on a variety of products or services, for compensation, provided the following conduct standards and conditions of this exemption are met: 1. Impartial Conduct Standards. Investment advice must be in the “best interest” of the retirement investor. This is defined as advice that reflects care, skill, prudence, and diligence based on investment objectives, risk tolerance, financial circumstances, and needs of the retirement investor. Further, our advisors owe a duty of loyalty to the retirement investor in that the investment advice cannot place the interests of the advisor or our firm ahead of the retirement investor. 2. Disclosure Requirements. The firm must provide retirement investors the following written disclosures and information prior to engaging in a covered transaction or recommendation: o Acknowledgement of acting as an ERISA fiduciary in writing; o Description of services provided and material conflicts of interest; and o For rollover recommendations, the specific reasons for why the AP believes the rollover recommendation is in the best interest of the retirement investor including providing a detailed costs and services comparison between the current and proposed account. This brochure provides information regarding material conflicts of interest and services offered. To the extent that we recommend, as part of our financial planning services, that you engage in a rollover transaction, you will receive a Rollover Recommendation Summary form. The Rollover Recommendation Summary form includes sections for your advisor to provide the rationale for why they believe the rollover recommendation is in your best interest, disclosures around services and costs, and evidence of form delivery. 3. Policies and Procedures. Davies Financial Advisors is required to establish, maintain, and enforce written policies and procedures for compliance with the conditions of PTE 2020-02. This includes complying with the Impartial Conduct Standards, providing required disclosures, and documenting and maintaining the specific reasons for rollover recommendations. Individualized Services and Client-Imposed Restrictions The investment advisory services provided by our advisors depend largely on the personal information the client provides to the advisor. In order for our advisors to provide appropriate investment advice to, or, in the case of discretionary accounts, make tailored investment decisions for, the client, it is very important that clients provide accurate and complete responses to their advisor’s questions about their financial condition, needs, goals, and objectives and notify the advisor of any reasonable restrictions they wish to apply to the securities or types of securities to be bought, sold, or held in their managed account. It is also important that clients promptly inform their advisor of any changes in their financial condition, investment objectives, personal circumstances, or reasonable investment restrictions pertaining to the management of their account, if any, that may affect their overall investment goals and strategies or the investment advice provided or investment decisions made by their advisor. In general, the client’s advisor is responsible for delivering investment advisory services to clients, and clients generally deal with matters relating to their accounts by contacting their advisor directly. Of course, clients may contact Davies Financial Advisors directly with questions about the advisory services offered by our firm. Wrap Fee Programs Davies Financial Advisors does not offer wrap fee programs. Assets Under Management As of December 31, 2023, Davies Financial Advisors manages $165,308,484.08 in assets, all of which is managed on a discretionary basis. Program Choices and Conflicts of Interest Clients should be aware that the compensation to Davies Financial Advisors and your advisor will differ according to the specific advisory program chosen. This compensation to us and your advisor may be more than the amounts we would otherwise receive if you participated in another program or paid for investment advice, brokerage, and/or other relevant services separately. As a result of the differences in fee schedules and other sources of compensation that exist among the various advisory programs and services offered by our firm and your advisor, Davies Financial Advisors and your advisor have a financial incentive to recommend a particular program or service over other programs or services. Lower fees for comparable services may be available from other sources. Davies Financial Advisors and your advisor have a financial incentive to recommend advisory programs or services that provide us higher compensation over other comparable programs or services available elsewhere that may cost you less. It is important to understand all the associated costs and benefits of each option so you can decide which types of accounts and services may be best suited for your unique financial goals, investment objective, and time horizon. Davies Financial Advisors encourages you to review its Form CRS and to discuss your options with your advisor.