A. OWNERSHIP/ADVISORY HISTORY Hungerford Financial, LLC (“the Advisor”) was established as a Michigan Limited Liability Company in 2015. It became registered as a Michigan Investment Adviser in December 2015 and subsequently registered with the Securities and Exchange Commission in December 2018. The Advisor is owned by Hungerford Nichols, a CPA firm and Thomas J. Price (“Mr. Price”). Mr. Price is the firm’s managing member. B. ADVISORY SERVICES OFFERED The Advisor’s services include portfolio management services and the creation of financial plans for clients. The Advisor will meet with a client to evaluate the individual client’s investment needs, goals and objectives. After the evaluation, the Advisor may recommend one of the services described below. 1. FINANCIAL PLANNING The Advisor offers clients financial planning services to evaluate their financial situation, goals and risk tolerance. Through a series of personal interviews and the use of questionnaires the Advisor will collect pertinent data, identify goals, objectives, financial problems, potential solutions, prepare specific recommendations and implement recommendations. As a result of these actions, the Advisor’s advice may be provided some or all of the following 13 Wealth Management Issues: 1) Investment Planning 2) Risk Management & Insurance Planning 3) Banking & Credit Management 4) Retirement Planning 5) Executive Compensation 6) Business Succession 7) Planning for Incapacity 8) Education & Family Support 9) Charitable Giving 10) Titling & Beneficiary Designations 11) Executor & Trustee Selection 12) Distribution of Estate 13) Tax Planning The Advisor may offer broad-based planning services, or the client may desire advice on certain planning components; the Advisor can tailor services as desired by the client. At the conclusion of the Financial Planning Service the Advisor will present the client with a written financial plan. Hungerford Financial, LLC Page 5 ADV Part 2A – 3/29/2024 2. PORTFOLIO MANAGEMENT The Advisor manages individualized portfolios for its clients. The Advisor works with each client to formulate an individualized portfolio based upon his/her objectives, time frame, risk parameters and other investment considerations. Please see Item 8 for additional information about the types of securities used and the Advisor’s investment strategies. The Advisor’s investment philosophy is to use principals of value, safety and quality to seek investment options globally. The Advisor places heavy emphasis on risk control, believing that avoiding losses allows appreciation potential of equities to be realized. 3. RECOMMENDATION OF THIRD-PARTY INVESTMENT ADVISERS The Advisor recommends and monitors third-party investment advisers (“Third-Party Advisers”). Advisor may recommend one or more Third-Party Adviser to its clients. The recommend will depend on the client’s individual circumstances, goals and objectives, desired strategy, account size,

risk tolerance, and other factors. The Advisor works with the client to determine which Third- Party Adviser may be appropriate. The client is never obligated to use a recommended Third- Party Adviser. The Advisor reviews each Third-Party Advisers before making a recommendation to the client. The Advisor considers the following factors during its review: fees, reputation, performance, financial strength, management, price, reporting capabilities, and the client’s financial situation, goals, needs and investment objectives. After our review, we will present the client with one or more recommendations. If the client wishes to proceed with the recommendation, the Advisor enters into a relationship with the recommended Third-Party Adviser. Under this relationship, the Third-Party adviser is responsible for portfolio management, best execution, portfolio reporting, trading, trade error resolution, and custodian reconciliations. The Advisor maintains their relationship with you by monitoring the status of the client’s accounts with the Third-Party Adviser, making recommendations about the Third-Party Adviser, typically meeting with the client either in person or by telephone on an annual basis, and acting as the client’s primary adviser. You should direct all questions regarding the Third-Party Adviser’s services and performance to the Advisor. When utilizing the services of a Third-Party Adviser, clients will be given a copy of their Form ADV Part 2A. Clients are encouraged to read and understand this disclosure document. 4. RETIREMENT PLAN SERVICES For business clients, the Advisor offers retirement plan consulting services. These services may cover ERISA and non-ERISA plans. Additionally, they may be ERISA fiduciary and/or ERISA non-fiduciary. The number of services is negotiated with each client. The ERISA fiduciary services may include: 1) Selection of Investments 2) Assessment of Investments 3) Participant Investment Advice Hungerford Financial, LLC Page 6 ADV Part 2A – 3/29/2024 4) Investment Policy Statement Preparation Non-ERISA fiduciary services may include: 1) Investment Policy Statement Review 2) Performance Monitoring 3) Third Party Service Provider Liaison 4) Employee Enrollment 5) Employee Education 6) Vendor Review/Conversion C. TAILORED SERVICES The Advisor’s portfolio management services are tailored to each client’s investment objectives, needs and goals. A client may impose restrictions on investment in certain securities (for example no tobacco stocks) or types of securities (for example no real estate related investments). Any restrictions must be provided in writing. D. WRAP PROGRAM The Advisor does not sponsor a wrap program. E. CLIENT ASSETS MANAGED As of January 25, 2024, we manage $287,807,326 in client assets on a discretionary basis and $21,012,519 in client assets on a non-discretionary basis. We have an additional $66,875,000 in client assets under advisement with a third-party adviser.