A. Brandon Financial Planning, Inc. (“Brandon Financial” or the “Firm”) is a corporation formed on July 16, 1982, in the State of Tennessee. Brandon Financial has been registered as an Investment Adviser Firm since October 1982. Brandon Financial is principally owned by E. Denby Brandon, III, Vice President and Ray Brandon, President. B. As discussed below, Brandon Financial offers to its clients (individuals, high net worth individuals, pension and profit-sharing plans, and other business entities, etc.) combined comprehensive financial planning and investment advisory services. INVESTMENT ADVISORY SERVICES Combined Comprehensive Financial Planning and Investment Advisory Services The client can determine to engage Brandon Financial to provide combined comprehensive financial planning and discretionary and/or non-discretionary investment advisory services. Brandon Financial’s financial planning process is as follows: 1. A Memorandum of Agreement between Brandon Financial and the client is prepared. Detailed fact-finding is done with respect to the client’s present situation including assets, liabilities, income, expenses, potential income and estate taxes, plans for distribution of assets, existing trust agreements, wills, investments, insurance, personal and family obligations, fringe benefit programs, etc. 2. An analysis is made of the client’s present position in the light of their needs, desires, and objectives. 3. A written “Personal Financial Analysis” (i.e., a financial plan) is created which includes a profile of the client, statement of net worth, distribution and balance of assets, description of current investments and insurance programs, recommendations for meeting short and long term living goals, descriptions of existing estate conditions, recommendations for meeting estate planning goals, summary of estate liquidity needs, etc., with appropriate exhibits. 4. After discussion of the written “Personal Financial Analysis” and upon agreement regarding the various recommendations, a proposed priority list of steps for application of the recommendations is agreed upon with the client. 5. Ongoing consultation is provided to the client regarding applications of the recommendations agreed upon. 6. After an initial consultation period, the clients are encouraged to continue to retain Brandon Financial to furnish on-going consultation regarding their financial planning (See “Review and On-Going Consultation” below). Review and Ongoing Consultation Brandon Financial encourages its clients to continue to retain it to furnish ongoing consultation. If the client agrees to do so, Brandon Financial will review its client’s financial plan on a regular basis. To commence the financial planning and investment advisory process, Registrant will ascertain each client’s investment objective(s) and then allocate the client’s assets consistent with the client’s designated investment objective(s). Once allocated, Registrant provides ongoing supervision of the account(s). Before engaging Registrant to provide financial planning and investment advisory services, clients are required to enter into a Memorandum of Agreement with Brandon Financial setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. Financial Planning for Business Entities In addition to the above-described personal financial planning process, Brandon Financial also performs specialized financial planning services for business entities. In most situations, the financial well-being of the key officers and employees of an entity has a significant effect upon the entity itself. Most successful executives and/or business owners spend their waking hours planning for, and working in, their business, often to the detriment of their personal financial planning. Business entities may retain Brandon Financial to provide financial planning consultation to its employees in addition to, or in conjunction with, providing consultation to the entity itself. In addition, it is often not possible to perform financial planning services for officers or key employees without coordinating such planning with the entity. Financial planning services provided for the entity itself might involve analysis and recommendations regarding some or all of the following: fringe benefits and/or compensation planning, investments, buy/sell or stock/membership interest redemption agreements and qualified and non-qualified retirement programs. Before engaging Brandon Financial to provide financial planning services for business entities, the entity is required to enter into an Memorandum of Agreement with Brandon Financial setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the entity. MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. As indicated above, to the extent requested by a client, Brandon Financial may provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. Brandon Financial will generally provide such consulting services inclusive of its advisory fee set forth at Item 5 below (exceptions could occur based upon assets under management, special projects, stand-alone planning engagements, etc. for which Firm may charge a separate or additional fee). Brandon Financial believes that it is important for the client to address financial planning issues on an ongoing basis. Please Note: We do not serve as an attorney, accountant, or insurance agent and no portion of our services should be construed as providing legal, accounting or insurance services. Accordingly, we do not prepare estate planning documents or tax returns. To the extent requested by a client, we may recommend the services of other professionals for certain non-investment implementation purpose (i.e. attorneys, accountants, insurance agents, etc.), including representatives of Brandon Financial in their separate individual capacities as registered representatives and/or licensed insurance agents of Silver Oak Securities, Inc., an unaffiliated FINRA member broker-dealer and licensed insurance agency (“Silver Oak”). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation made by Brandon Financial and/or its representatives. Please Note: If the client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional[s] (i.e. attorney, accountant, insurance agent, etc.), and not Brandon Financial, shall be responsible for the quality and competency of the services provided. Conflict of Interest: The recommendation by Brandon Financial’s representatives that a client purchase a securities or insurance commission product through Silver Oak presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend investment or insurance products based on commissions to be received, rather than on a particular client’s need. No client is under any obligation to purchase any securities or insurance commission products through such a representative. Clients are reminded that they may purchase securities and insurance products recommended by Brandon Financial through other, non-affiliated broker-dealers and/or insurance agencies. Brandon Financial’s President, Ray Brandon remains available to address any questions that a client or prospective client may have regarding the above conflict of interest. Non-Discretionary Service Limitations.

Clients that determine to engage Brandon Financial on a non-discretionary investment advisory basis must be willing to accept that Brandon Financial cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event that Brandon Financial would like to make a transaction for a client’s account (including in the event of an individual holding or general market correction), and the client is unavailable, Brandon Financial will be unable to effect any account transactions (as it would for its discretionary clients) without first obtaining the client’s consent. Retirement Plan Rollovers-No Obligation/Conflict of Interest. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Brandon Financial recommends that a client roll over their retirement plan assets into an account to be managed by Brandon Financial, such a recommendation creates a conflict of interest if Brandon Financial will earn a new (or increase its current) compensation as a result of the rollover. If Registrant provides a recommendation as to whether a client should engage in a rollover or not, Registrant is acting as a fiduciary 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. No client is under any obligation to roll over retirement plan assets to an account managed by Brandon Financial. Brandon Financial’s President, Ray Brandon, remains available to address any questions that a client or prospective client may have regarding its prospective engagement and the potential for conflict of interest presented by such rollover recommendation. Fiduciary Status: Per the DOL: “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.” Accordingly, relative to retirement accounts, “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.” Portfolio Activity. Registrant has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Registrant will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, mutual fund manager tenure, style drift, and/or a change in the client’s investment objectives. Based upon these factors, there may be extended periods of time when Registrant determines that changes to a client’s portfolio are neither necessary nor prudent. Notwithstanding, there can be no assurance that investment decisions made by Registrant will be profitable or equal any specific performance level(s). Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Use of Mutual Funds. Brandon Financial utilizes mutual funds and exchange traded funds for its client portfolios. In addition to Brandon Financial’s investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). If a client or prospective client determines to allocate investment assets to publicly available mutual funds without engaging Brandon Financial as an investment advisor, the client or prospective client would not receive the benefit of Brandon Financial’s initial and ongoing investment advisory services with respect to management of the asset. Please Note: Cash Positions. Brandon Financial continues to treat cash as an asset class. As such, unless determined to the contrary by Brandon Financial, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Brandon Financial’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Brandon Financial may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Brandon Financial’s advisory fee could exceed the interest paid by the client’s money market fund. ANY QUESTIONS: Registrant’s President , Ray Brandon, remains available to address any questions that a client or prospective may have regarding the above fee billing practice. Client Obligations. In performing its services, Brandon Financial shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify Brandon Financial if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Brandon Financial’s previous recommendations and/or services. Disclosure Statement. A copy of Brandon Financial’s written Privacy Notice and Form ADV Brochure as set forth on Parts 2A and 2B shall be provided to each client prior to, or contemporaneously with, the execution of the Memorandum of Agreement, Renewal Memorandum of Agreement or Modification and Extension of Renewal Memorandum of Agreement. Brandon Financial will also provide a copy of its Client Relationship Summary (“Form CRS”) to clients and prospective clients before or at the time they enter an investment advisory contract with the Firm. Specifically, Form CRS must be delivered before or at the earliest of: (i) a recommendation of an account type, a securities transaction, or an investment strategy involving securities; (ii) placing an order for the retail investor; or (iii) the opening of a brokerage account for the retail investor. C. Brandon Financial shall provide investment advisory services specific to needs of each client. Prior to providing investment advisory services, an investment adviser representative will discuss with each client, their particular investment objective(s). Brandon Financial shall allocate each client’s investment assets consistent with their designated investment objective(s). Clients may, at any time, impose restrictions, in writing, on Brandon Financial’s services. D. Brandon Financial does not participate in a wrap fee program. E. As of December 31, 2023, Brandon Financial had $18,237,717 in assets under management on a discretionary basis and $309,459,807 in assets under management on a non-discretionary basis.