O’Donnell Financial Services, LLC (referred to throughout as we, us, our, firm, company or O’Donnell Financial) is a registered investment advisor with the United States Securities and Exchange Commission. We operate as a limited liability company formed in the State of California, owned, and controlled by our founder, Gregory C O’Donnell, since 2015. We specialize in the following types of services: Wrap Asset Management, Financial Planning & Consulting, and Retirement Planning Services. We provide individuals and other types of clients with a wide array of investment advisory services. Description of the Types of Advisory Services We Offer Asset Management: Asset Management services involves providing clients with continuous and on-going supervision over their accounts. This means that O’Donnell Financial will continuously manage client’s account and place trades in the client accounts when necessary. These services are only offered through wrapped accounts. When providing Asset Management services, we will typically consider equity, bonds, ETF’s, mutual funds, and alternative investments to build diversified portfolios to meet each client’s financial goals and objectives; however, we are not limited to those investments. It is not our typical investment strategy to attempt to time the market, but we may increase cash holdings as deemed appropriate based on your risk tolerance, short-and long-term goals. We may modify our investment strategy to accommodate specific situations including but not limited to low basis stock, stock options, legacy holdings, inheritances, closely held businesses, or special tax situations (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information). Financial Planning & Consulting: Financial planning services do not involve the on-going management of client accounts, but instead involves preparing a financial plan or rendering a financial consultation to help clients achieve their goals, based upon an understanding of each client’s individual financial resources and objectives. We provide an executive summary, highlighting each client’s financial situation, observations, and proposed plan of action. Our advisors are available to assist with the implementation of the plan and to answer any client questions, but the client is ultimately responsible for the implementation or rejection of our recommendations. You are never required to implement our recommendations. Recommendations may include that the client begin or revise investment programs, create, or revise wills or trusts, obtain, or revise insurance coverage, commence, or alter retirement savings, or establish education or charitable giving programs. Financial consulting engagements typically do not include a written summary of our observations and recommendations. Financial Plans or consultations are typically completed within six (6) months of the client signing an engagement proposal with us, if all the information and documents we request from the client are provided to us promptly. ADV Part 2A – Firm Brochure Page 5 O’Donnell Financial Services LLC We may refer clients to an accountant, attorney, or other specialist, as necessary for non-advisory related services. Retirement Planning Services: We offer retirement planning and consulting services to employer plan sponsors on a one-time or ongoing basis. The primary clients for these services are pension, profit sharing, and participant- directed, individual account plans (i.e., 401(k), 403(b), etc.). Specifically, we offer (1) Discretionary Asset Management Services, (2) Non-Discretionary Asset Advisory Services, (3) Retirement Plan Fiduciary Services to employer-sponsored retirement plans and their participants in ERISA 3(21) co-fiduciary capacity. Depending upon the type of plan and the specific needs of the plan sponsor, areas of advising could include assisting employer plan sponsors in establishing, monitoring, and reviewing their company’s participant-directed retirement plan, investment options, plan structure and participant education. Prior to being engaged by the plan sponsor we will provide a copy of this Form ADV Part 2A along with a copy of our Privacy Policy and the applicable Agreement that contains the information required to be disclosed under SEC. 408(b)(2) of the Employee Retirement Income

Security Act (“ERISA”), as applicable. If providing retirement plan services to a plan, a participant or beneficiary may request additional services. O’Donnell Financial may establish a separate client relationship with one or more plan participants or beneficiaries through a separate agreement. If the client accounts are part of a Plan, and we accept appointments to provide our services to such accounts, we acknowledge that we are a fiduciary within the meaning of Section 3(21) of ERISA (but only with respect to the provision of services described in Section 1 of the Retirement Plan Consulting Agreement). Such client relationships develop in various way, including, and without limitation:
• as a result of a decision by a plan participant or beneficiary to purchase services from O’Donnell Financial not involving the use of plan assets;
• as part of an individual or family financial plan for which any specific recommendations concerning the allocation of assets or investment recommendations relating to the assets held outside of the plan; and/or
• through a rollover of an Individual Retirement Account (“IRA”) Department of Labor Acknowledgement of Fiduciary Duty. 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 special rules that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations;
• Never put our financial interests ahead of yours when making recommendations;
• 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 ADV Part 2A – Firm Brochure Page 6 O’Donnell Financial Services LLC
• Give you basic information about conflicts of interest. Sub-Advisory Services: We have entered into sub-advisory agreements for separately management accounts(s) with independent federally registered investment advisors. These arrangements were established to fulfill specific investment strategies designed to meet certain client’s goals and objectives. We do not make individual security selections in the sub-advised accounts. The sub-advisors buy and sell securities over time as they manage the account directly on the client’s behalf. We monitor the investment account, but not to the degree that we would monitor investments in accounts that we directly manage. Sub-Advisory services are only offered through wrapped accounts. There will be a separate Agreement that you will sign with the sub-advisor that will lay out their fee structure in which you will be responsible for paying. Please see the Wrap Fee Program Brochure for fee information. Asset management fees charged by O’Donnell Financial are separate and distinct from management fees charged by the sub-advisor. O’Donnell Financial and the sub-advisors do not share any fees between them. Tailoring of Advisory Services We offer individualized investment advice to clients utilizing our Wrap Asset Management and Sub- Advisor Asset Management services. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Participation in Wrap Fee Programs O’Donnell Financial Services, LLC sponsors a Wrap Program. Accounts are managed based on financial goals, risk tolerance, etc. Asset management services are offered on a wrap-fee basis only. Please see Part 2A, Appendix 1 (the “Wrap Fee Program Brochure”) for more information. Regulatory Assets Under Management As of December 31, 2023, we managed $290,080,885 on a discretionary basis, and $4,494,430 on a non-discretionary basis. ADV Part 2A – Firm Brochure Page 7 O’Donnell Financial Services LLC