A. Description of the Advisory Firm Ketron Financial LLC (hereinafter “KF LLC”) is a Limited Liability Company organized in the State of California. The firm became registered as an investment adviser in 2024. The principal owners are Courtenay Wise and Ruth Aguirre. B. Types of Advisory Services Portfolio Management Services KF LLC offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. KF LLC creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring KF LLC evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. KF LLC will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. KF LLC seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of KF LLC’s economic, investment or other financial interests. To meet its fiduciary obligations, KF LLC attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, KF LLC’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is KF LLC’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Financial Planning & Estate Transition Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; education planning; and debt/credit planning. Estate transition planning may include counseling and estate consulting concerning assets, preparing paperwork, assisting with distribution, and the process of arranging assets and other affairs, both during life and after death, in a way that accomplishes objectives for the disposition of assets and the management of personal concerns. Selection of Other Advisers KF LLC may direct clients to third-party investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, KF LLC will always ensure those other advisers are properly licensed or registered as an investment adviser. KF LLC conducts due diligence on any third-party investment adviser, which may involve one or more of the following: phone calls, meetings and review of the third-party adviser's performance and investment strategy. KF LLC then makes investments with a third-party investment adviser by referring the client to the third-party adviser. KF LLC will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Pension Consulting Services KF LLC offers consulting services to pension

or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to: • identifying investment objectives and restrictions • providing guidance on various assets classes and investment options
• recommending money managers to manage plan assets in ways designed to achieve objectives
• monitoring performance of money managers and investment options and making recommendations for changes
• recommending other service providers, such as custodians, administrators and broker-dealers • creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Services Limited to Specific Types of Investments KF LLC generally limits its investment advice to mutual funds, fixed income securities, insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, non-U.S. securities and private placements, although KF LLC primarily recommends fundamental growth. KF LLC may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions KF LLC offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent KF LLC from properly servicing the client account, or if the restrictions would require KF LLC to deviate from its standard suite of services, KF LLC reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. KF LLC does not participate in wrap fee programs. E. Assets Under Management KF LLC has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $0 $0 March 2024