Roger Smedley founded Smedley Financial Services, Inc.® in 1982. Under his leadership the Smedley Financial Team has become known for its ability to deliver focused and proven wealth strategies for affluent clients as well as managed investment portfolios. The Smedley Wealth Management Team focuses on building relationships through world class client service, specialized private wealth planning solutions, and proven wealth management offerings. We understand that financial choices abound and work to deliver superior solutions to our clients. As an independent firm, we have the ability to match each product and solution that best meets each client’s unique situation. Our Investment Management Team provides proven investment strategies designed to navigate the changing market environment. Focusing on investment time horizon, diversification, and risk tolerance, each portfolio is designed to provide superior investment opportunities. In today’s financial landscape two things ring true, ethics and integrity are paramount. Smedley Financial applies a company-wide philosophy that centers on putting our client’s needs first in all that we do. Smedley Financial Services, Inc. is an investment advisor registered with the United States Securities and Exchange Commission (“SEC”) and is a Corporation formed under the laws of the State of Utah.
• Roger Smedley is the CEO and majority owner of Smedley Financial Services, Inc. Sharla Jessop is President and a minority owner.
• Smedley Financial Services, Inc. has been registered as an investment advisor since June 1982.
• We provide fee-based investment advisory services through Smedley Financial Services, Inc. The nature and extent of the specific services provided to clients, including you, will always depend on each client’s financial status, objectives and needs, time horizons, concerns, expectations and risk tolerance.
• The advisor representatives of Smedley Financial Services are also licensed as registered representatives with Securities America, Inc. a registered broker/dealer, member FINRA/SIPC, and some of our advisor representatives are also independent insurance agents. When acting in these capacities, our advisor representatives will earn commissions. Our advisory representatives typically spend approximately 15% their time providing commission-based services through Securities America. These conflict of interest situations are discussed in more detail at Item 5, Item 10, Item 12, and Item 14 of this Disclosure Brochure.
• When providing advisory services, we are able to use various programs sponsored by Securities America Advisors, an investment advisor registered with the SEC and an affiliated company of Securities America, Inc. More details are provided at Item 5 of this Disclosure Brochure.
• More information about our investment advisor representatives’ business and education background can be found at the section titled Information Required by Part 2B of Form ADV: Brochure Supplement at the end of this brochure. General Description of Primary Advisory Services The following are brief descriptions of Smedley Financial Services, Inc.’s primary services. A detailed description of Smedley Financial Services, Inc.’s services is provided in Item 5 – Fees and Compensation so that clients and prospective clients can review the description of services and description of fees in a side-by-side manner. Financial Planning Services - Smedley Financial Services, Inc. provides advisory services in the form of financial planning services. Financial planning services do not involve the active management of client accounts, but instead focuses on a client’s overall financial situation. Financial planning can be described as helping individuals determine and set their long-term financial goals, through investments, tax planning, asset allocation, risk management, retirement planning, and other areas. The role of a financial planner is to find ways to help the client understand his/her overall financial situation and help the client set financial objectives. Asset Management Services - Smedley Financial Services, Inc. provides advisory services in the form of Asset Management Services. Asset Management Services involve providing clients with continuous and on-going supervision over client accounts. This means that Smedley Financial Services, Inc. will continuously monitor a client’s account and make trades in client accounts when necessary. Retirement Plan Services - Smedley Financial Services offers retirement plan consulting services to retirement plan sponsors and to individual participants in retirement plans. For a corporate sponsor of a retirement plan, our retirement plan consulting services can include, but are not limited to, the following services: Fiduciary Services - Smedley Financial Services provides the following Fiduciary Retirement Plan Consulting Services:
• Investment Policy Statement Preparation. Smedley Financial Services will help you develop an investment policy statement. The investment policy statement establishes the investment policies and objectives for the Plan. You will have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the investment policy statement.
• Non-Discretionary Investment Advice. Smedley Financial Services may provide you with general, non-discretionary investment advice regarding assets classes and investment options, consistent with your Plan’s investment policy statement.
• Investment Selection Services. Smedley Financial Services may provide you with recommendations of investment options consistent with ERISA section 404(c).
• Investment Due Diligence Review. Smedley Financial Services may provide you with periodic due diligence reviews of the Plan’s reports, investment options and recommendations.
• Investment Monitoring. Smedley Financial Services will assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement. Smedley Financial Services can make non-discretionary recommendations to maintain or remove and replace investment options.
• Individualized Participant Advice. Upon request, Smedley Financial Services may provide one- on-one advice to Plan participants regarding their individual situations. Smedley Financial Services acknowledges that in performing the Fiduciary Consulting Services listed above that it is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of Employee Retirement Income Security Act of 1974 (“ERISA”) for purposes of providing non-discretionary investment advice only. Smedley Financial Services will act in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause Smedley Financial Services to be a fiduciary as a matter of law. However, in providing the Fiduciary Consulting Services, Smedley Financial Services (a) has no responsibility and will not (i) exercise any discretionary authority or discretionary control respecting management of Client’s retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of Client’s retirement plan, or (iii) have any discretionary authority or discretionary responsibility in the administration of Client’s retirement plan or the interpretation of Client’s retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does not have the power to manage, acquire or dispose of any plan assets, and (c) is not the “Administrator” of Client’s retirement plan as defined in ERISA. Non-Fiduciary Services Smedley Financial Services provides clients with the following Non-Fiduciary Retirement Plan Consulting Services:
• Participant Education. Smedley Financial Services will provide education services to Plan participants about general investment principles and the investment alternatives available under the Plan. Smedley Financial Services’ assistance in participant investment education will be consistent with and within the scope of DOL Interpretive Bulletin 96-1. Education presentations will not take into account the individual circumstances of each participant and individual recommendations will not be provided unless otherwise agreed upon.
• Participant Enrollment. Smedley Financial Services will assist you with group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees.
• Qualified Plan Development. Smedley Financial Services will assist you with the establishment of a qualified plan by working with you and a selected Third Party Administrator. If you have not already selected a Third Party Administrator, we shall assist you with the review and selection of a Third Party Administrator for the Plan.
• Due Diligence Review. Smedley Financial Services will provide you with periodic due diligence reviews of your Plan’s fees and expenses and your Plan’s service providers.
• Fiduciary File Set-up. Smedley Financial Services will help you establish a “fiduciary file” for the Plan which contains trust documents, custodial/brokerage statements, investment performance reports, services agreements with investment management vendors, the investment policy statement, investment committee minutes, asset allocation/asset liability studies, due diligence fields on funds/money managers and monitoring procedures for funds and/or money managers. Although an investment adviser is considered a fiduciary under the Investment Advisers Act of 1940 and required to meet the fiduciary duties as defined by the Advisers Act, the services listed here as non- fiduciary should not be considered fiduciary services for the purposes of ERISA since Advisor is not acting as a fiduciary to the Plan as the term “fiduciary” is defined in Section 3(21)(A)(ii) of ERISA. The exact suite of services provided to a client will be listed and detailed in the Qualified Retirement Plan Consulting Agreement. All recommendations of investment options and portfolios will be submitted to the client for the client’s ultimate approval or rejection. Therefore, it is always the client’s responsibility to accept investment recommendations of Smedley Financial Services and then physically make changes to the plan itself. In the event a client contracts with Smedley Financial Services for one-on-one consulting services with plan participants, such services are consultative in nature and do not involve Smedley Financial Services implementing recommendations in individual participant accounts. It will be the responsibility of each participant to implement changes in the participant’s individual accounts. We can also meet with individual participants to discuss their specific investment risk tolerance, investment time frame and investment selections. Retirement plan consulting services are not management services, and Smedley Financial Services does not serve as administrator or trustee of the plan. Smedley Financial Services does not act as custodian for any client account or have access to client funds or securities (with the exception of, some accounts, having written authorization from the client to deduct our fees). In addition, we do not implement any transactions in a retirement plan or participant’s account. For retirement plan consulting services, the retirement plan or the plan participant who elects to implement any recommendations made by us is solely responsible for implementing all transactions. Smedley Financial Services will disclose, to the extent required by ERISA Regulation Section 2550.408b- 2(c), to you any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b-2(c)(1)(iv) as soon as practicable, but no later

than sixty (60) days from the date on which we are informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclose as soon as practicable). In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or Plan Administrator (unless such disclose is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable) all information related to the Qualified Retirement Plan Consulting Agreement and any compensation or fees received in connection with the Agreement that is required for the Plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued thereunder. If we make an unintentional error or omission in disclosing the information required under ERISA Regulation Section 2550.408b-2(c)(1)(iv) or (vi), we will disclose to you the correct information as soon as practicable, but no later than thirty (30) days from the date on which we learn of such error or omission. Retirement Plan Rollover Recommendations - When Smedley Financial Services provides investment advice about your retirement plan account or individual retirement account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan account, roll over such investment/proceeds from the retirement plan account to a IRA or make a distribution from the retirement plan account, we acknowledge that Smedley Financial Services is a “fiduciary” within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”) as applicable, which are laws governing retirement accounts. The way Smedley Financial Services makes money creates conflicts with your interests so Smedley Financial Services operates under a special rule that requires Smedley Financial Services to act in your best interest and not put our interest ahead of you. Under this special rule’s provisions, Smedley Financial Services must as a fiduciary to a retirement plan account or IRA under ERISA/IRC:
• Meet a professional standard of care when making investment recommendations (e.g., give prudent advice);
• Never put the financial interests of Smedley Financial Services ahead of you when making recommendations (e.g., give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that Smedley Financial Services gives advice that is in your best interest;
• Charge no more than is reasonable for the services of Smedley Financial Services; and
• Give Client basic information about conflicts of interest. To the extent We recommend you roll over your account from a current retirement plan account to an individual retirement account managed by Smedley Financial Services, please know that Smedley Financial Services and our investment adviser representatives have a conflict of interest. We can earn increased investment advisory fees by recommending that you roll over your account at the retirement plan to an IRA managed by Smedley Financial Services. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by Smedley Financial Services. Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA which is a conflict of interest because our recommendation that you open an IRA account to be managed by our firm can be based on our economic incentive and not based exclusively on whether or not moving the IRA to our management program is in your overall best interest. We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in Smedley Financial Services receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by Smedley Financial Services and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to you regarding a retirement plan account or IRA, our investment advisor representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of Smedley Financial Services or our affiliated personnel. Referral of Third-Party Money Managers - Smedley Financial Services offers advisory services by referring clients to a third-party money manager offering asset management and other investment advisory services. The third-party managers are responsible for continuously monitoring client accounts and making trades in client accounts when necessary. As a result of the referral, we are paid a portion of the fee charged and collected by the third-party money managers in the form of solicitor fees. Each solicitation arrangement is performed pursuant to a written solicitation agreement and is in compliance with SEC Rule 206(4)-3 and applicable state securities rules and regulations. Under this program, we assist you with identifying your risk tolerance and investment objectives. We recommend third-party money managers in relation to your stated investment objectives and risk tolerance, and you may select a recommended third-party money manager or model portfolio based upon your needs. You must enter into an agreement directly with the third-party money manager who provides your designated account with asset management services. We are available to answer questions that you may have regarding your account and act as the communication conduit between you and the third-party money manager. The third-party money manager may take discretionary authority to determine the securities to be purchased and sold for your account. We do not have any trading authority with respect to your designated account managed by the third-party money manager. Although we review the performance of numerous third-party investment adviser firms, we enter into only a select number of relationships with third-party investment adviser firms that have agreed to pay us a portion of the overall fee charged to our clients. Therefore, Smedley Financial Services has a conflict of interest in that it will only recommend third-party investment advisors that will agree to compensate us for referrals of our clients. Clients are advised that there may be other third-party managed programs not recommended by our firm, that are suitable for the client and that may be more or less costly than arrangements recommended by our firm. No guarantees can be made that a client’s financial goals or objectives will be achieved by a third-party investment adviser recommended by our firm. Further, no guarantees of performance can ever be offered by our firm (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more details.) Specialization Smedley Financial Services, Inc. specializes in lifetime income investment planning. Retirees and pre- retirees need a solution that will help increase the probability of providing an income that will last throughout their lives. The solution must address the following goals:
• Deliver a stream of income over a period of years that will keep pace with inflation.
• Implement a strategy that offers the potential to reach long-term investment goals.
• Help preserve principal to either offset increased life expectancy or provide a legacy.
• Reduce risk based on an investment time-frame.
• Manage the emotional side of investing and the impact it has on reaching financial goals. One solution is lifetime income investment planning. Segmenting assets into separate phases or time horizons is the backdrop of lifetime income investment planning. Each income phase is invested based on a specific group of factors and criteria. The goal is to provide an income distribution level that will keep pace with inflation and will continue throughout the client’s lifetime. Limits Advice to Certain Types of Investment Smedley Financial Services, Inc. provides investment advice on the following types of investments:
• No-Load (i.e. no trading fee) and Load-Waived (i.e. trading fee waived) Mutual Fund Shares
• Exchange-listed securities (i.e. stocks)
• Securities traded over-the-counter (i.e. stocks)
• Fixed income securities (i.e. bonds)
• Closed-End Funds and Exchange Traded Funds (ETFs)
• Foreign Issues
• Warrants
• Corporate debt securities (other than commercial paper)
• Certificates of deposit
• Municipal securities
• Variable life insurance
• Variable annuities
• United States government securities
• Interests in partnerships investing in real estate Smedley Financial Services, Inc. does not provide advice on commercial paper, options contracts on securities and commodities, futures contracts on tangibles and intangibles, interests in partnerships investing in oil and gas interests, hedge funds and other types of private (i.e. non-registered) securities. When providing asset management services, Smedley Financial Services, Inc. typically constructs each client’s account holdings using Mutual Funds, Stocks, Bonds, ETFs, as well as Variable Annuity and Variable Life sub accounts to build diversified portfolios. It is not Smedley Financial Services, Inc.’s typical investment strategy to attempt to time the market but we may increase cash holdings or change allocation weightings as deemed appropriate, based on your risk tolerance, investment models, 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.) Participation in Wrap Fee Programs Smedley Financial Services, Inc. offers services through both wrap-fee programs and non-wrap fee programs. A wrap fee program is defined as any advisory program under which a specified fee or fees not based directly upon transactions in a client’s account is charged for investment advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and the execution of client transactions. Whenever a fee is charged to a client for services described in this brochure (whether wrap fee or non-wrap fee), Smedley Financial Services, Inc. will receive all or a portion of the fee charged. Tailor Advisory Services to Individual Needs of Clients Smedley Financial Services, Inc.’s services are always provided based on the individual needs of each client. This means, for example, that you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with each client on a one- on-one basis using a consultative process which includes interviews and questionnaires to determine the client’s values, goals, important relationships, income needs, investment objectives, and suitability information. When managing client accounts through the firm’s Asset Management Services program, we may manage a client’s account in accordance with one or more investment models. When client accounts are managed using models, investment selections are based on the underlying model and we do not develop customized (or individualized) portfolio holdings for each client. However, the determination to use a particular model or models is always based on each client’s individual investment goals, objectives and mandates. Client Assets Managed by Smedley Financial Services, Inc. The amount of client assets managed by Smedley Financial Services, Inc. totaled $277,685,520 as of June 30, 2023. $277,685,520 are managed on a discretionary basis and $0.00 are managed on a non- discretionary basis.