The Putney Financial Group, a limited liability company is an SEC-registered investment advisor with its principal place of business located in California. Raymond L. Lent began conducting business in San Rafael in 1997. The Putney Financial Group LLC is wholly owned by Raymond L. Lent. Mr. Lent controls 100% of the company. The Putney Financial Group LLC offers the following advisory services to its clients: INVESTMENT SUPERVISORY SERVICES ("ISS") INDIVIDUAL PORTFOLIO MANAGEMENT Our Firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment portfolio based on that policy. During our data-gathering process, we determine the client's individual objectives, time horizons, risk tolerance, and liquidity needs. When appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We manage our advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, socially responsible industries, or general industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker- dealer or insurance company and will generally include advice regarding the following securities:
• Exchange-listed securities
• Securities traded over-the-counter
• Corporate debt securities (other than commercial paper)
• Variable life insurance
• Variable annuities
• Mutual funds shares
• United States government securities
• Options contracts on securities
• Interests in partnerships investing in real estate or equipment leasing companies, both publicly and non-publicly traded
• Exchange-traded funds
• Exchange-traded notes
• Municipal securities
• Certificates of deposit, non-publicly traded securities, alternative investments
• Fixed Income Investments
• Structured Notes Page 5 of 19 Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity, and suitability. FINANCIAL PLANNING We provide financial planning services. Financial planning is a comprehensive evaluation of a client's current and future financial state using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information, and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service receive a written report which provides the client with a detailed financial plan designed to assist the client in achieving his or her financial goals and objectives. In general, the financial plan can address any or all of the following areas:
• PERSONAL: We review family records, budgeting, personal liability, estate information and financial goals.
• TAX & CASH FLOW: We analyze the client's income tax and spending habits along with current and future cash flow requirements. Future projections are then illustrated based on assumed rates for portfolio returns, inflation and withdrawal rates. Projections for government benefits (e.g., Social Security) and private pension plans are included, if appropriate.
• INVESTMENTS: We analyze investment alternatives and their effect on the client's portfolio.
• INSURANCE: We review existing policies to ensure proper coverage for life, health, disability, and long-term care.
• RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals. We will recommend appropriate modifications

which, in our opinion, are necessary to achieve those goals.
• DEATH & DISABILITY: We review the client's cash needs at death, income needs of surviving dependents, estate planning and disability income.
• ESTATE: We assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid, and elder law. Additionally, we help our clients develop strategies appropriate to meeting their philanthropic and legacy aspirations. We gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the client’s discretion. Page 6 of 19 We also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning, which may include
• Exchange-listed securities
• Securities traded over-the-counter
• Corporate debt securities (other than commercial paper)
• Variable life insurance
• Variable annuities
• Mutual funds shares
• United States government securities
• Options contracts on securities
• Interests in partnerships investing in real estate or equipment leasing companies, both publicly and non-publicly traded
• Exchange-traded funds
• Exchange-traded notes
• Municipal securities
• Fixed Income Investments
• Certificates of deposit, non-publicly traded securities, alternative investments Typically, the financial plan is presented to the client within three months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. Financial Planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. All recommendations are of a generic nature. IRA ROLLOVER RECOMMENDATIONS For the purpose of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020- 02") when applicable, we are providing the following acknowledgment to clients. When we provide investment advice to clients regarding their retirement plan account or individual retirement account, we are 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. The way we make money creates some conflicts with your interests, so we operate under an exemption that requires us to act in the clients’ best interest and not put our interest ahead of the clients. Under this exemption, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of the clients 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 the clients’ best interest;
• Charge no more than is reasonable for our services; and
• Give the clients basic information about conflicts of interest. Page 7 of 19 We benefit financially from the rollover of the clients’ assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in the clients’ best interest. AMOUNT OF MANAGED ASSETS As of 12/31/23, we have $177,105,756 in regulatory assets under management, $174,913,909 of which are managed on a discretionary basis and $2,191,847 on a non-discretionary basis.