JSF Financial LLC (“JSF”) is a SEC-registered investment adviser with its principal place of business located in California. JSF began conducting business in 1996. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company): Jeffrey S. Fishman, Managing Member Shari Fishman, Chief Compliance Officer JSF offers the following advisory services to our clients: INVESTMENT SUPERVISORY SERVICES INDIVIDUAL PORTFOLIO MANAGEMENT JSF 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 allocation strategy and create and manage a portfolio based on that strategy. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, liquidity needs, and unique circumstances. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. 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 hire JSF on a discretionary basis. Clients who hire JSF for discretionary investment management allow JSF to have limited discretion to make buy and sell decisions on their behalf based on specific objectives or strategies established between JSF and the client. Discretionary authority is generally granted by the investment management agreement that the client signs with JSF. Investment management services will be ongoing until the arrangement is terminated in writing by either JSF or the client in accordance with the JSF investment management agreement executed by clients. 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)
• Certificates of deposit
• Municipal securities
• Variable life insurance
• Variable annuities
• Open-end and closed-end mutual fund shares
• Exchange Traded Funds (ETFs)1
• United States governmental securities
• Options contracts on securities
• Alternative investments/ Private Funds
• Interests in partnerships including but not limited to real estate, private equity, hedge funds and venture capital Portfolio positions are selected based on key portfolio indicators of investment style, correlation, risk and reward that are developed based on the client’s goals, objectives, strategies and restrictions, as stated in the investment management agreement, published manager information, market and economic environment research. When portfolios are reviewed, dynamic asset allocation is used to adjust the portfolios so that the various styles are closely aligned with current market conditions while maintaining compliance with the client’s suitability. From time to time, JSF will recommend alternative and/or private investments to clients, such as limited partnerships, or limited liability companies, which invest in securities or other private investments, such as feeder funds and fund of funds (“Private Investment Funds”). Such Private Investment Funds can include, but are not limited to hedge funds, real estate funds, private equity funds, and venture capital funds. Depending on the type of fund, the Private Investment Funds invest in various types of securities, including, but not limited to equities, debt instruments, commodities, futures contracts, real estate, and other private funds. Investing in Private Investment Funds involves various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints, lack of transparency, lack of portfolio investment diversification, and risks associated with the underlying investments. A complete discussion of risks and other important information is set forth in each Private Investment Fund’s offering documents, which will be provided to each client for review and consideration prior to investing. Unlike liquid investments, such as publicly traded securities, Private Investment Funds do not provide daily liquidity or pricing and in some cases limit or restrict redemptions. Please refer to Item 8 below for further information on risks. JSF will only recommend potential investment in a Private Investment Fund to clients that meet the appropriate qualification definition and the investment appears suitable for the client. JSF considers a client’s investment objectives, risk tolerances, the size of the client’s holdings and cash available for investment. Prior to investment, clients wanting to invest in a Private Investment Fund will be required by the issuer of the fund to complete a subscription agreement, pursuant to which the client shall confirm that he/she meets the required qualification status for investment in the Private Investment Fund and acknowledges and accepts the various risk factors that are associated with such an investment. Should a client decide to invest in a Private Investment Fund, we can facilitate the implementation of the transaction when requested. 1 The types of ETFs that JSF utilize include but are not limited to ETFs that track an index, invest in stocks, bonds, and/or commodities, and in certain cases clients request that we invest for them in leveraged and inverse ETFs. Please refer to Item 8 for information on the surrounding associated risks. For certain Private Investment Funds that we recommend, JSF will provide ongoing monitoring and oversight of the investment should a client decide to invest (see Item 8 for further information). However, there are some Private Investment Funds for which we do not provide such services. We will notify clients at the time we make the recommendation on whether we will provide ongoing monitoring and oversight. For any Private Investment Funds that we do monitor and oversee, the values of each client’s investment in these Funds are generally included in the client’s asset under management value when JSF calculates its fee for investment supervisory services (see Item 5 for further information). Clients are not required to invest in any Private Investment Fund recommended by JSF. There are times when one or more employees invest in Private Investment Funds or other alternative investments recommended to clients. This creates a potential conflict of interest. Please refer to Item 11 for further information, including how JSF addresses the conflict. We reserve the right to offer advice on any investment product that we believe is suitable for each client’s specific circumstances, needs, goals and objectives. Clients have the opportunity to place reasonable restrictions on the types of investments they wish to purchase. Clients retain individual ownership of all securities. Clients must notify JSF promptly of any material change in financial circumstances or investment objectives which might affect the manner in which accounts should be invested. 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, tax circumstances, liquidity and suitability. Retirement Plan Advisory Services As part of our portfolio management services, we offer retirement advisory services to employee benefit plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services can include an existing plan review and analysis, plan-level advice regarding fund selection and investment options, investment performance monitoring, and recommendation of a Third-Party Administrator. Additionally, we can determine the specific investments to be held by the plan or offered as investment options under the plan consistent with the Investment Guidelines. These pension services will be discretionary and advisory in nature. Wrap Fee Program (Closed to New Clients) JSF also sponsors a Wrap Fee Program, the JSF Wrap Program. A wrap fee program is one under which investment advisory and brokerage execution services are provided for a single "wrapped" fee that is not based on the transactions in a client's account. For clients who participate in the JSF Wrap Program, a description of the program, as well as the associated fee schedule, can be found in the Part 2A, Appendix 1. JSF is no longer accepting new clients into our wrap program. Additionally, wrap accounts are also no longer offered to existing clients. INVESTMENT SUPERVISORY SERVICES MODEL PORTFOLIO MANAGEMENT Asset Allocation Model Portfolios Our firm also provides portfolio management services to clients using model asset allocation portfolios. Each model portfolio is designed to offer a strategic asset allocation solution which meets a particular investment goal, mainly utilizing mutual funds and exchange traded funds (“ETFs”). Model allocation portfolios are designed to offer investment options that fit the desired risk profile and objectives of the client. Growth oriented model allocation portfolios are intended to allocate capital along the risk tolerance spectrum from conservative to aggressive. The desired risk level is achieved by controlling the allocation to the various major asset classes - cash and cash equivalents, fixed income, equities, alternatives and other asset classes. The actual allocation varies in each model allocation portfolio. There are two additional model allocation portfolios for income-oriented investing; one tailored for taxable accounts and one tailored for non-taxable accounts. he primary objective of the income model allocation portfolios is to generate income while maintaining a certain risk level necessary for modest growth. We manage these advisory accounts on a 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 risk tolerance and tax considerations. Through personal discussions with the client in which the client's investment goals and objectives are established, we determine the model allocation portfolio that is suitable to the client's circumstances. Once we determine the suitable model allocation portfolio for a client, the selected portfolio is managed based on the model portfolio's asset allocation targets and any reasonable restrictions requested by the client. Large-Cap Equity Model Portfolio Strategy JSF offers an investment strategy concentrated primarily in approximately 30 equity securities of US large-cap companies that have lower volatility characteristics relative to the broad equity market and/or sector ETFs.

The strategy is designed to capture all sectors of the S&P 500 Index and is geared to serve as a diversifier/complement to traditional large-cap allocations. Through personal discussions with the client in which the client's investment goals and objectives are established, we determine whether this strategy is suitable to the client's circumstances. A client’s assets invested in this strategy are managed by JSF based on a model portfolio of equity securities that pertain to the strategy’s investment thesis and any reasonable restrictions requested by the client. JSF will only recommend/implement model portfolios for clients when determined suitable and consistent with the client’s stated investment objectives, tolerance for risk, liquidity needs, and any stated restrictions. To ensure that our initial determination of an appropriate model portfolio remains suitable and that a client’s account continues to be managed in a manner consistent with the client's overall goals and objectives, we will: 1. At least annually, contact each participating client to determine whether there have been any changes in the client's financial situation or investment objectives, and whether the client wishes to impose investment restrictions or modify existing restrictions; 2. Be reasonably available to consult with the client; and 3. Maintain client suitability information in each client's file. Clients are required to inform JSF when there is a change to their financial circumstances, or investment goals or objectives during each year. Please refer to Item 8 for additional information on our methods of analysis and the risks associated with the securities used in our model portfolios. THIRD-PARTY MANAGER ACCOUNT PROGRAM For certain strategies, JSF will recommend one or more unaffiliated third-party professional investment managers (“TPMs”) who offer specialized investment management expertise through our Third-Party Manager Account Program (hereinafter, the "Program"). Our firm provides the client with an asset allocation strategy developed through personal discussions in which goals and objectives based on the client's particular circumstances are established. This asset allocation strategy is drafted into the client's recommended allocation. Based on the client's individual circumstances and needs, as exhibited in the client's recommended allocation, we will assist a client in selecting one or more TPMs \ whose portfolio management style is appropriate for that client. Factors considered in making this determination include but are not limited to account size, risk tolerance, time horizons, and the opinion of each client and the investment philosophy of the selected TPM. Once we determine the most suitable TPM(s) for the client, we provide the selected TPM(s) with the client's risk tolerance and investment objectives and the TPM(s) then creates and manages the client's portfolio on a discretionary basis. Certain TPMs will require the client to execute a separate management agreement, which will be in addition to the JSF agreement that our clients sign. When this occurs, JSF will facilitate the delivery of documents between the TPM and the client. JSF also has sub-advisory arrangements in place with certain TPMs, which do not require clients to sign a separate agreement. While the TPM will have discretionary trading authority with respect to the client’s account and have day-to-day responsibility for the active management of the allocated assets, JSF will continue to provide investment advisory services to the client relative to ongoing monitoring and review of account performance, overall portfolio asset allocation and client investment objectives. In addition, through the JSF agreement, clients give JSF the authority to hire and fire TPMs. Each TPM charges a management fee, which is in addition to the fees charged by JSF and are typically billed to the client by the TPM. Fees differ depending upon the individual agreements we have with each TPM. In some cases, the advisory fees paid to the TPM and JSF will be more or less than if the client paid separately for the manager services and will vary depending on the investment advisory program or services offered by the TPM. We monitor the ongoing suitability and performance of the selected TPM(s). If we determine that a selected TPM is not providing sufficient management services to the client or is not managing the client's portfolio in a manner consistent with the client's allocation and suitability pursuant to the JSF Investment Management Agreement, we will have the authority to terminate the TPM and reallocate client assets as we deem appropriate. Clients must notify JSF promptly of any material change in financial circumstances or investment objectives which might affect the manner in which accounts should be invested. For each TPM selected, the client will receive a copy of the TPM’s Form ADV Part 2A, Part 2Bs, Form CRS (as applicable), and Privacy Notice. These documents should be read in their entirety in order for the clients to have a full understanding of the TPM’s investment management services, the associated fees, and applicable risks and conflicts. FINANCIAL PLANNING JSF provides a variety of financial planning services. Financial planning is a comprehensive evaluation of a client’s current and future financial state by 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. In general, the financial planning process can address any or all of the following areas: PERSONAL: We review family records, budgeting, personal liability and financial goals. TAX & CASH FLOW: We analyze the client’s income tax and spending and planning for past, current and future years; then illustrate the impact of various investments on the client's current income tax and future tax liability. INVESTMENTS: We analyze investment alternatives and their effect on the client's portfolio. INSURANCE: Analysis includes a review of existing policies to recommend proper coverage for life, health, disability, long-term care, liability, home and automobile. EMPLOYEE BENEFITS: We review and analyze whether the client is taking maximum advantage of available employee benefits. We will also offer advice on employer-sponsored retirement plans and/or stock options. COLLEGE FUNDING: Analysis includes projecting the amount of money needed to achieve post- secondary education funding goals, along with reviewing various college finding vehicles that are available. We can also assist with reviewing eligibility for financial aid. RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals. MORTGAGE FINANACING: We review the client’s real estate financing needs and help them find the most appropriate and cost-effective program. 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, mortgage refinancing and elder law. CHARITABLE PLANNING: We assist select high net worth clients in creating a charitable giving plan which can include articulating the family mission statement, identifying causes aligned with family values and engaging the next generation in philanthropic planning. BUSINESS CONSULTING: We assist clients with small businesses outline strategy and planning for future growth. We gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, family status and attitudes towards risk. We carefully review documents supplied by the client, complete various supporting documentation which can include a budget or balance sheet questionnaire and prepare various recommendations to present to the client. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, bookkeeper and/or other professionals. In the event that a client does not have an established relationship with the necessary professional(s), JSF will recommend the appropriate professionals to assist with implementation of the plan or other needs. Implementation of financial plan recommendations is entirely at the client's discretion. Financial planning services will be ongoing until the arrangement is terminated in writing by either JSF or the client in accordance with the JSF financial planning agreement executed by clients. Financial Planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. The financial planning process varies in the level of service and cost based upon clients’ circumstances, needs and objectives as well as information provided by the client. Client must promptly notify JSF if his or her financial situation, goals, objectives, or needs change. ANCILLARY SERVICES JSF provides educational seminars/webinars for our clients. These seminars/webinars include, but are not limited to, presentations on current events, economic trends and cycles, market activity, investment fundamentals, financial planning strategies, college or retirement planning or non- investment related topics. No fees are charged to attend these seminars. JSF also provides to clients ongoing newsletters which focus on various market events and planning strategies. Our newsletters do not focus on the needs of any specific individual. Newsletters are provided to clients free of charge. Account Aggregation. In conjunction with the firm’s portfolio management software provided by Orion and financial planning software provided by eMoney, JSF offers aggregation of outside assets/accounts held by a client and will provide periodic comprehensive reporting services which incorporate all of the client’s investment assets including those investment assets that are not part of the assets being managed by JSF. JSF’s service related to outside assets is limited to the reporting service only and does not include discretionary investment management of the outside assets. JSF does not have trading authority over the outside assets and as such the client is exclusively responsible for directing and implementing any recommendations JSF provides in the course of our financial planning or investment management relationship related to outside assets. Furthermore, JSF shall not be responsible for any implementation error (trading, etc.) that occur related to any outside assets. In the event the client desires that JSF provide investment management services on any of the outside assets, the client will do so under the terms and conditions of JSF’s Investment Management Agreement. AMOUNT OF MANAGED ASSETS As of December 31, 2023, we were actively managing $1,472,089,017 of clients' assets on a discretionary basis.