A. Camarda Financial Advisors, LLC, d/b/a Camarda Wealth Advisory Group (the "Registrant") is a limited liability company formed in the state of Florida. Registrant began offering investment advisory services in 1998 and changed its status to a Limited Liability Company on July 1, 2009. Registrant is wholly owned by Singularity One, LLLP, which is wholly owned by Singularity Management, LLC. Registrant remains under the control and ownership of Jeff and Kim Camarda, with approximately 5% owned by the Jeffrey M. Camarda 2012 Irrevocable Trust (Kim Camarda, trustee), approximately 90% owned by the Kim K. Camarda 2012 Irrevocable Trust (Jeff Camarda, trustee), and 1% owned by each of their five children. Jeffrey Camarda is the Registrant’s principal managing member. B. The Registrant offers to its clients a combination of investment management services on a discretionary basis and, to the extent requested by a client, advice with respect to investments, insurance, estate and trust planning, tax advice and tax planning, and retirement and financial planning. The Registrant may also be engaged to provide retirement plan management, retirement plan consulting, and/or standalone investment planning, financial planning, or other consulting services, each are described more fully below. Investment Management and Advisory Services Registrant manages investment advisory accounts using proprietary and sourced research or model portfolios. Each portfolio is designed by Registrant to meet a particular investment strategy. Strategy selection supervision is guided by the stated instructions of the client after a discussion of risk tolerance and alternatives. Through personal discussions with the client in which the client’s goals, objectives, and preferences are discussed, Registrant will aid client in determining which of Registrant’s portfolio(s) seem appropriate to the client's circumstances, then accept client’s instructions on portfolio selection. As appropriate, Registrant may suggest an allocation among the portfolios it believes will more adequately address the client's individual needs, preferences, or instructions. Once the client has instructed Registrant as to portfolio selection, clients will have the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio, including particular securities or funds. Clients will retain individual ownership of all securities. In order to ensure that the account continues to be managed in accordance with client's objectives and instructions, Registrant will seek to maintain client suitability information in the client's file. Consequently, each client is advised to promptly notify the Registrant if there are ever any changes in their financial situation or investment objectives, or if they wish to impose any reasonable restrictions upon Registrant’s management services or modify existing restrictions. Generally, Registrant will manage these advisory accounts on a discretionary basis only. However, certain clients may possess holdings which, for tax purposes or otherwise, the client does not wish to immediately liquidate. Where these assets neither fit within nor conform to an asset category of the selected model portfolio(s) (“Non-conforming Assets”) the client may nonetheless choose to engage the Registrant to manage these assets. Registrant may accept and monitor these Non-conforming Assets under its Legacy Stock Watch program, and report opinions regarding their use and disposition (including, potentially, writing covered calls against such assets) on an ongoing basis separately or in conjunction with its management of model portfolio assets. Non-conforming Assets may also be liquidated in an orderly fashion in order to be deployed to one of Registrant’s portfolios, may be margined in order to facilitate the overlay of options or other strategies, or may be otherwise managed or overseen per specific client instructions. Registrant may also, as appropriate, modify the composition of the client’s model portfolio assets to account for Non-conforming Assets. However, Registrant will not sell or transition Non- conforming Assets into the model portfolio managed on a discretionary basis without first notifying the client and receiving the client’s authorization. Registrant will invest clients’ accounts in one or more of the following in accordance with the selected model portfolio(s): individual equities, bonds or notes, mutual funds, exchange-traded funds (ETFs), cash or cash equivalents, options, and/or other investment products. Registrant will endeavor to allocate the client's assets among various investments, taking into consideration the overall management style and risk tolerance selected by the client. Clients may request to receive a written report or “financial plan” describing how to target client’s stated financial goals and objectives; such reports or plans may be limited to specific areas such as retirement or estate planning depending on clients wishes and needs. In general, and as client needs dictate, the financial planning services may address planning areas such as investment planning, business planning, risk control and insurance planning, tax strategy, titling structure, estate planning, asset protection planning, college planning, and retirement planning. These services do not include tax return preparation, accounting or accounting advice, tax accounting or tax accounting advice or the preparation of legal documents, or other services generally not considered to be “financial planning.” Retirement Plan Management and Consulting The Registrant also provides retirement plan management/consulting services, pursuant to which it assists sponsors of self-directed retirement plans organized under the Employee Retirement Security Act of 1974 (“ERISA”). The terms and conditions of the engagement shall be set forth in a Retirement Plan Services Agreement between the Registrant and the plan sponsor. To the extent that the plan sponsor engages the Registrant in an ERISA Section 3(21) capacity, the Registrant will assist with the selection and/or monitoring of investment options from which plan participants shall choose in self- directing the investments for their individual plan retirement accounts. If the plan sponsor chooses to engage the Registrant in an ERISA Section 3(38) capacity, Registrant may provide the same services as described above, but may also: create specific asset allocation models that Registrant manages on a discretionary basis, which plan participants may choose in managing their individual retirement account; and/or modify the investment options made available to plan participants on a discretionary basis. ERISA Plan and 401(k) Individual Engagements
• Trustee Directed Plans Registrant may be engaged to provide discretionary investment advisory services to ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the investment objective designated by the Plan trustees. In such engagements, Registrant will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). Registrant will generally provide services on an “assets under management” fee basis per the terms and conditions of a Retirement Plan Services Agreement between the Plan and the Firm.
• Participant Directed Retirement Plans Registrant may also provide investment advisory and consulting services to participant directed retirement plans per the terms and conditions of a Retirement Plan Services Agreement between Registrant and the plan. For such engagements, Registrant shall assist the Plan sponsor with the selection of an investment platform from which Plan participants shall make their respective investment choices (which may include investment strategies devised and managed by Registrant), and, to the extent engaged to do so, may also provide corresponding education to assist the participants with their decision-making process.
• Client Retirement Plan Assets If requested to do so, Registrant shall provide investment advisory services relative to 401(k) plan assets maintained by the client in conjunction with the retirement plan established by the client’s employer. In such event, Registrant shall allocate (or recommend that the client allocate) the retirement account assets among the investment options available on the 401(k) platform. Registrant’s ability shall be limited to the allocation of the assets among the investment alternatives available through the plan. Registrant will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify Registrant of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Unless expressly indicated by the Registrant to the contrary, in writing, the client’s 401(k) plan assets shall be included as assets under management for purposes of Registrant calculating its advisory fee. Investment Planning, Financial Planning, and Other Consulting Services (Standalone) To the extent requested by a client, the Registrant may provide investment planning, financial planning, and/or consulting services on a stand-alone, separate fee basis. Prior to engaging the Registrant to provide investment planning or consulting services, clients are generally required to enter into an Investment Planning and Consulting Agreement with Registrant setting forth the terms and conditions of the engagement prior to Registrant commencing services. In general, and as client requests, investment planning will include analysis and opinion of existing portfolio, potential investment alternatives and their effect on a client's portfolio or the construction of a portfolio and clients’ overall financial strategy. Registrant’s Investment Planning and Consulting Service is limited to investments only and does not include “Financial Planning,” which is described in more detail below. Registrant makes available basic financial planning (including investment and non-investment related matters) services to its clients as part of its quarterly fee, as discussed above. However, its services are available on a on a stand-alone basis when more advanced planning and/or consulting services are requested. Financial planning services may address planning areas such as retirement planning, business planning, risk control and insurance planning, tax strategy, titling structure, estate planning, asset protection planning, and college planning. Clients may also request consulting services to address a specific area(s) of concern. Consulting engagements typically do not result in a written report due to the nature of the service. Registrant typically gathers required information through personal interviews and document reviews. Information gathered includes a client's current financial status, future goals, and attitudes towards risk. Related documents supplied by the client are reviewed and a written report may be prepared. Advisory quality may be limited by the accuracy or completeness of information and documents provided by client.

If requested by the client, Registrant may recommend the services of other professionals or firms for non- investment implementation purposes. These professionals or firms may include affiliates of Registrant, who may share common employees with Registrant. These professionals or firms may or may not share revenue or make referrals to Registrant. At all times, the engaged licensed professional(s), and not Registrant, shall be responsible for the quality and competency of the services provided. The client is under no obligation to engage the services of any such recommended professional or firm. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Registrant. Moreover, each client is advised that it remains their responsibility to notify Registrant promptly if there is ever any change in their financial situation or investment objectives so that it can review, and if necessary, revise its previous advice. For clients who have not entered into a Letter of Agreement, they will generally be required to enter into a Financial Planning and Consulting Agreement with Registrant setting forth the terms and conditions of the engagement, describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to Registrant commencing services. All fees, fixed or hourly, are negotiable at the discretion of the Registrant, and may be reduced or waived depending on the facts and circumstances of the particular relationship. Note that such clients may also be referred to Registrant’s affiliate, TaxMaster.US, LLC (“TaxMaster) or other affiliate or non-affiliates for non-investment advisory and non-financial planning work. See discussion at Item 10. Miscellaneous
• Estate Planning, Tax Planning, and other Non-Investment Consulting/Implementation Services To the extent requested and separately engaged by a client to do so, Registrant may provide consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. Registrant does not serve as an attorney, accountant, or insurance agent, and no portion of Registrant’s services should be construed as legal or accounting services. To the extent requested by a client, Registrant may recommend for non-investment implementation purposes (i.e. attorneys, accountants, insurance, etc.), professionals and firms, including its affiliate, TaxMaster.US, LLC - see Item 10 below. No client is under any obligation to engage the services of any such recommended professional or firm. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Registrant and/or its representatives. If the client engages any such recommended professional or firm, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional or firm. At all times, the engaged licensed professional(s), and not Registrant, shall be responsible for the quality and competency of the services provided.
• MoneyGuidePro Registrant may provide its clients with access to an online platform hosted by MoneyGuidePro (the “Platform”). The Platform may allow a client to view their complete asset allocation, including those assets that Registrant does not manage (the “Excluded Assets”). Registrant does not provide investment management, monitoring, or implementation services for the Excluded Assets. Unless otherwise specifically agreed to, in writing, Registrant’s service relative to the Excluded Assets is limited to reporting only. Therefore, Registrant shall not be responsible for the investment performance of the Excluded Assets. Rather, the client and/or their advisor(s) that maintain management authority for the Excluded Assets, and not Registrant, shall be exclusively responsible for such investment performance. Without limiting the above, the Registrant shall not be responsible for any reporting or implementation error (timing, trading, etc.) relative to the Excluded Assets. The client may choose to engage Registrant to manage some or all of the Excluded Assets pursuant to the terms and conditions of a Letter of Agreement between Registrant and the client. The Platform also provides access to other types of information and applications including financial planning concepts and functionality, which should not, in any manner whatsoever, be construed as services, advice, or recommendations provided by Registrant. Finally, Registrant shall not be held responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the Platform without Registrant’s assistance or oversight.
• Cash Positions Registrant continues to treat cash as an asset class. As such, unless determined to the contrary by Registrant, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Registrant’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), Registrant 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, Registrant’s advisory fee could exceed the interest paid by the client’s money market fund.
• Retirement Rollovers 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 Registrant recommends that a client roll over their retirement plan assets into an account to be managed by Registrant, such a recommendation creates a conflict of interest if Registrant will earn new (or increase its current) compensation as a result of the rollover, as is generally the case for asset transfers from other advisors or custodians. If Registrant provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), 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 or other assets to an account managed by Registrant. Registrant’s Chief Compliance Officer, Ashley Howard, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation.
• Use of Publicly Available Investments Most investments utilized in client portfolios are available directly to the public. Thus, a prospective client can obtain many of the investment holdings that may be utilized by Registrant independent of engaging Registrant as an investment advisor. However, if a prospective client determines to do so, he/she will not receive Registrant’s initial and ongoing investment advisory services. Registrant uses investment securities from a variety of sources, and may use investments that are only available to registered investment advisors. Thus, if the client holding such funds was to terminate Registrant’s services, and not transition to another adviser who utilizes those same funds, restrictions regarding additional purchases of or reallocation among other funds will generally apply. In addition to Registrant’s investment advisory fee described below, and potential transaction and/or custodial fees, clients may 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).
• Portfolio Activity As part of its investment advisory services, Registrant will review client portfolios on an ongoing basis to determine if any changes are suggested based upon various factors, including, but not limited to, investment performance, internal investment or market research, recommendations provided by a third-party investment research firm, perception of market conditions, style drift, account additions/withdrawals or balance, and/or a change in the client’s investment objective. Based upon these factors, at times portfolios may be traded more frequently, as guided by each portfolio’s stated methodology. Clients should be aware that portfolios are generally not optimized for tax efficiency and should be aware that brokerage transaction costs and taxes could affect net investment performance. Alternatively, it is possible that there may be extended periods of time when Registrant determines that changes to a client’s portfolio are neither necessary nor prudent. The Registrant’s fee remains payable during such periods of account inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by Registrant will be profitable or equal any specific performance level(s).
• Trade Error Policy Registrant shall reimburse accounts for losses resulting from the Registrant’s trade errors but shall not credit accounts for such errors resulting in market gains. The gains and losses are reconciled within the Registrant’s custodian firm account and Registrant retains the net gains and losses.
• Client Obligations In performing its services, Registrant 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 his/her/its responsibility to promptly notify the Registrant if there is any change in his/her/its financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Registrant’s previous recommendations and/or services. In addition, Registrant has a duty to inform client of the most appropriate risk tolerance strategies for client’s situation and goals as best Registrant can ascertain, but client is advised that any deviations in client-selected strategies from those suggested by advisor may increase client’s risk of loss or underperformance, and that client retains responsibility for such instructed deviations. C. For information on how the Registrant tailors its services, clients and prospective clients should review the Registrant’s services. D. The Registrant does not participate in a wrap fee program. E. As of December 31, 2023, the Registrant had $331,147,948 in regulatory assets under management; $316,171,929 of which was managed on a discretionary basis and $14,976,019 of which was managed on a non-discretionary basis.