ITEM 5 - ADDITIONAL COMPENSATION .................................................................................................... ii ITEM 6 - SUPERVISION .............................................................................................................................. ii Jorden Bastien .................................................................................................................................. iii ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ..................................................... iii ITEM 3 - DISCIPLINARY INFORMATION .................................................................................................... iii ITEM 5 - ADDITIONAL COMPENSATION ................................................................................................... iii ITEM 6 - SUPERVISION ............................................................................................................................. iii M'Lissa Swift ..................................................................................................................................... iv ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ..................................................... iv ITEM 3 - DISCIPLINARY INFORMATION .................................................................................................... iv ITEM 5 - ADDITIONAL COMPENSATION ................................................................................................... iv ITEM 6 - SUPERVISION ............................................................................................................................. iv Privacy Notice ................................................................................................................................... A LifeSteps Financial, Inc. Brochure Revised March 22, 2024 6 Description of Advisory Firm LifeSteps Financial, Inc. (“LifeSteps,” “we,” “our,” or “us”) is a privately owned Corporation headquartered in Claremont, California. In 2009, Henry Ford co-founded Foothill Financial Advisors, Inc. (“Foothill”). In 2010, Foothill registered as an investment adviser with the U.S. Securities and Exchange Commission. In 2017, Foothill changed its entity name to LifeSteps Financial, Inc. LifeSteps offers investment advisory and financial planning services to individuals, families, trusts, and businesses. Fiduciary Duty Registered investment advisers are considered fiduciaries under federal law. Our fiduciary duty carries with it an obligation to act in the best interest of our clients pursuant to a relationship of trust and confidence. It encompasses a duty of care and a duty of loyalty. Duty of Care The duty of care includes, among other things, 1. the duty to provide advice that is in the best interest of the client; 2. the duty to seek best execution of a client’s transactions where the adviser has the responsibility to select broker-dealers to execute client trades; and 3. the duty to provide advice and monitoring over the course of the relationship. The duty to provide advice suitable to each client based on a reasonable understanding of the client’s objectives is a critical component of the duty of care. Providing suitable advice includes making a reasonable inquiry into the client’s financial situation, investment experience, and financial goals and then updating this information as necessary throughout the course of the relationship to reflect the client’s changing objectives over time and adjusting the advice we provide to reflect any changed circumstances. When LifeSteps has the responsibility to select broker-dealers to execute client trades in discretionary accounts, we seek to trade such that the client’s total cost or proceeds in each transaction are the most favorable under the circumstances. In doing so, we consider the full range and quality of a broker’s services and so the determinative factor is not necessarily the lowest possible commission cost but whether the transaction represents the best qualitative execution. Moreover, we periodically and systematically evaluate the execution we receive on behalf of our clients. Our duty of care includes an obligation to provide advice and monitoring at a frequency that is in the best interest of the client, taking into account the scope of the agreed relationship. This scope is indicated by the duration and nature of the services as outlined in each client’s advisory arrangement and extends to all personalized advice provided to clients. Duty of Loyalty LifeSteps adheres to a duty of loyalty where we seek to serve the best interests of our clients and never subordinate the interests of our clients to our own. Simply put, LifeSteps cannot place its own interests ahead of the interests of our clients. In observance of this duty, we must make full and fair disclosure to clients of all material facts relating to the advisory relationship. Further, we also seek to eliminate or at LifeSteps Financial, Inc. Brochure Revised March 22, 2024 7 least expose through full and fair disclosure all conflicts of interest which might incline LifeSteps, consciously or unconsciously, to render advice that is not disinterested. We believe that in order for disclosure to be full and fair, it should be sufficiently specific so that each client is able to understand the material fact or conflict of interest and make an informed decision whether to provide consent. Consequently, we provide this ADV 2A brochure to all prospective clients at or before entering into a contract so that they can use the information within to decide whether or not to enter into an advisory relationship. Advisory Services Offered LifeSteps offers the following services to advisory clients: Investment Advisory Services LifeSteps offers advice to clients regarding asset allocation and the selection of investments. Our investment advisory services are generally inclusive of financial planning, asset allocation, and portfolio management services. We design, implement, and provide continued monitoring of client portfolios. LifeSteps will invest the account on a fully discretionary basis, limited only by the client’s individual needs and any restrictions imposed on the account. LifeSteps’ recommendations for new investments will primarily include exchange-traded funds (ETFs). Additionally, LifeSteps’ recommendations, depending on the individual investment objectives and needs of the client may include: 1. Equity securities, including stocks and foreign securities listed on US exchanges (ADRs) 2. Fixed income securities, including corporate, government, and municipal bonds, commercial paper, and certificates of deposit (CDs) 3. Mutual funds 4. Securities with Equity and Debt Characteristics, including convertible bonds, preferred stocks, or other preferred securities 5. Real estate investment trusts (REITs) LifeSteps also occasionally offers advice regarding additional types of investments if they are appropriate to address the individual needs, goals, and objectives of the client or in response to client inquiry. LifeSteps may also offer investment advice on any investment held by the client at the start of the advisory relationship. We describe the material investment risks for many of the securities that we recommend under the heading Specific Security Risks in Item 8 below. We discuss our discretionary authority below under Item 16 - Investment Discretion. For more information about the restrictions clients can put on their accounts, see Tailored Services and Client Imposed Restrictions in this item below. We describe the Fees charged for investment management services below under Item 5 - Fees and Compensation. Short-Term Cash Management LifeSteps also offers short-term cash management services to high net worth clients. This service utilizes short-term investments including but not limited to certificates of deposit (CDs), money market funds, LifeSteps Financial, Inc. Brochure Revised March 22, 2024 8 and treasuries with the goal of keeping assets in a liquid and safe

environment to accommodate clients’ short-term needs. Non-Discretionary Accounts LifeSteps also offers investment advisory services to clients on a non-discretionary basis. For these clients LifeSteps will contact the client before making recommendations it deems appropriate for the client. See also Item 16 – Investment Discretion below. Financial Planning Services LifeSteps offers a range of financial planning services, from broad planning to custom planning focused on specific areas requested by the client as part of the client’s overall Investment Advisory Service. We do not charge separate fees for financial planning services provided to clients. As part of the financial planning process, LifeSteps collects information about the client’s financial situation and needs, which may include net worth, income, expenses, taxes, investments, retirement plans, life insurance, disability insurance, health insurance, long term care insurance, business agreements, divorce papers, pre-nuptial agreements, estate documents, and any other documents that pertain to their overall financial picture. In addition, LifeSteps asks the client about their future goals and objectives. LifeSteps then develops a personalized plan including specific recommendations in all applicable areas. LifeSteps also works with the client to provide advice regarding particular aspects of the client’s financial situation. Areas of focus might include: 1. Preparing for or living in retirement 2. Investment strategies 3. Estate planning strategies 4. Income tax planning 5. Stock option analysis and planning 6. Insurance: life, disability, medical, long-term care insurance 7. Family savings and cash flow planning 8. Education planning and funding 9. Charitable gifting 10. Debt management 11. Employee benefit usage 12. Other, as determined between LifeSteps and the client Our investment management clients sometimes receive a written financial plan. However, our financial planning services do not include preparation of any kind of income tax, gift, or estate tax returns nor preparation of any legal documents, including wills or trusts. Bill Payment and Reconciliation Service LifeSteps facilitates payment of our billpay clients’ monthly bills and obligations. We obtain the client’s consent verbally or via email before paying any bills, especially any that are new or unfamiliar to our firm. We make bill payments via check or electronic transfer at the client’s discretion. Henry Ford, LifeSteps Financial, Inc. Brochure Revised March 22, 2024 9 Principal, is solely responsible for signing all checks. The client retains access to all of their bank accounts and receives monthly bank statements via physical mail or electronic delivery. Clients are required to provide us with copies of their monthly bank statements, which we reconcile with all payments on a monthly basis. Sub‐Advisory Services Clients can also access the investment management services of unaffiliated third party money managers through a sub-advisory program offered through 55IP, LLC (“55IP “). 55IP is a separately managed account (SMA) provider offered through Fidelity Institutional Wealth Services (“Fidelity”). Limitations on Investments In some circumstances, LifeSteps’ advice is limited to certain types of securities. Limitation by Plan Sponsor/Employer In the event LifeSteps is managing assets within a retirement plan such as 401(k), 529 plans, or other employer plan, LifeSteps is limited to those investment providers and investment options chosen by the plan administrator. Similarly, when we provide services to participants in an employer-sponsored plan, the participant is generally limited to investing in securities included in the plan’s investment options. Therefore, LifeSteps can only make recommendations to the client from among the available options and will not recommend or invest the client’s account in other securities, even if there may be better options elsewhere. Limitation by Type of Security Limitation on Equities Generally, LifeSteps utilizes equity-related ETFs rather than investing in individual equity securities. However, there may be instances when we make the determination that an individual equity security is more appropriate than equity-related ETFs investment options available. We also hold individual positions as an accommodation to clients. Mutual Fund Limitations No Load Mutual Funds LifeSteps generally limits recommendations of mutual funds to no load funds or equivalent investment products. Limitation by Custodian There are also limitations on the mutual funds that we recommend. All clients establish brokerage accounts with Schwab Institutional®, a division of Charles Schwab & Co., Inc. (“Schwab”) or Fidelity Institutional Wealth Services (“Fidelity”), registered broker-dealers, Members SIPC. LifeSteps is limited to the mutual funds available through Schwab/Fidelity. LifeSteps Financial, Inc. Brochure Revised March 22, 2024 10 Limitation by Client LifeSteps will also limit advice based on certain client-imposed restrictions. For more information about the restrictions clients can put on their accounts, see Tailored Services and Client Imposed Restrictions in this Item below. Non-managed Assets With respect to investment management services, LifeSteps will only be responsible for the supervision and management of securities we recommend. LifeSteps will not be responsible for the supervision or management of non-managed assets. Non-managed assets typically include securities held in a client’s account that is under management with LifeSteps that were: 1. Delivered into the account by the client; 2. Purchased by the client; 3. Purchased by LifeSteps at the request of the client as an accommodation; or 4. Designated by the client to be non-managed securities by written notification. Rollover Recommendations A conflict of interest arises when LifeSteps makes recommendations about plan distributions and rollovers (“rollover recommendations”), if it results in LifeSteps receiving compensation that it would not have received absent the recommendation, for example, fees for advising a rollover IRA. LifeSteps will manage this conflict through a process designed to develop an informed recommendation in the best interest of the client. No client is under an obligation to roll over ERISA plan or IRA assets to an account advised by LifeSteps. The rollover recommendations occur in two scenarios. The first is where LifeSteps is serving as a fiduciary adviser to a private sector retirement plan, for example, a 401(k) plan. In that case, the rollover recommendation is fiduciary advice under both the Investment Advisers Act of 1940 (Advisers Act) and the Employee Retirement Income Security Act (ERISA). In addition to being a conflict of interest as described above, it is also a prohibited transaction under ERISA where LifeSteps receives compensation from the rollover IRA that is greater than the compensation, if any, being received from the participant’s account in the plan. In that circumstance, LifeSteps will comply with the conditions of exceptions to the prohibited transaction rules (e.g., a prohibited transaction exemption or non-enforcement policy). The second scenario is where LifeSteps is not providing ERISA fiduciary advisory services to the plan. In that case, a rollover recommendation is not a prohibited transaction under ERISA, but it is a conflict of interest under the Advisers Act because of the compensation received by LifeSteps from the rollover IRA. Tailored Services and Client Imposed Restrictions LifeSteps manages client accounts based on the investment strategy as discussed below under Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss. LifeSteps applies the strategy for each client, based on the client’s individual circumstances and financial situation. We make investment decisions for clients based on information the client supplies about their financial situation, goals, and risk tolerance. Our recommendations may be limited if the client does not provide us with accurate and LifeSteps Financial, Inc. Brochure Revised March 22, 2024 11 complete information. It is the client’s responsibility to keep LifeSteps informed of any changes to their investment objectives or restrictions. Clients may also request other restrictions on the account, such as when a client needs to keep a minimum level of cash in the account or does not want LifeSteps to buy or sell certain specific securities or security types in the account. LifeSteps reserves the right to not accept and/or terminate management of a client’s account if we feel that the client-imposed restrictions would limit or prevent us from meeting or maintaining the client’s investment strategy. Wrap Fee Programs LifeSteps does not manage accounts as part of a wrap or bundled fee program. Assets Under Management LifeSteps manages client assets in both discretionary and non-discretionary accounts on a continuous and regular basis. As of December 31, 2023, the total amount of assets under our management was: Discretionary Assets $256,939,684 Non-Discretionary Assets $58,454,441 Total Assets $315,394,125