A. Firm Information Vestment Financial, LLC, which conducts business under the name “MD Financial” and under the name “Vestment Financial” (“MD Financial / Vestment Financial”), is an SEC Registered Investment Advisor. The firm is registered in its home state of Minnesota and other states as required. The firm is organized as a Limited Liability Company (LLC) under the laws of the State of Minnesota. The firm began operations in June 2011, became registered as in investment adviser in 2013, and is led by Principal and Chief Compliance Officer, Katherine Vessenes, CFP®. The firm is wholly owned by Ms. Vessenes. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by the firm. B. Advisory Services Offered MD Financial / Vestment Financial offer various investment advisory services to individuals, businesses and high net worth individuals in Minnesota and other states (each referred to as a “Client”). Account Portfolio Management MD Financial / Vestment Financial provide customized investment advisory solutions for its Clients. This is achieved through ongoing personal Client contact and interaction while providing discretionary investment management and consulting services. MD Financial / Vestment Financial work with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio allocation. MD Financial / Vestment Financial believes that markets reward investors over a long period of time. MD Financial / Vestment Financial help clients focus on controlling the things that they can control, like the investment structure of their portfolio's asset allocation, diversification, rebalancing, their broad-based tax strategies, their internal fees, and portfolio model selection based on their timeframe for needing funds. We also believe that, for the most part markets are efficient and, therefore today's prices reflect all available public information. Therefore, we utilize low-cost mutual funds and exchange traded funds (primarily managed by Dimensional Fund Advisors, Avantis, and others) representing various traditional and alternative asset classes in a diversified portfolio. Our process involves developing asset allocation models both for taxable and tax-deferred accounts. The allocations are largely based on the market capitalization at the time of the portfolio creation. MD Financial / Vestment Financial’s investment strategy is primarily long-term focused, but the firm may buy, sell or re-allocate positions that have been held less than one year to meet the objectives of the Client or due to market conditions. MD Financial / Vestment Financial will construct, implement and monitor the portfolio which is designed to the meet the goals, objectives, circumstances, and risk tolerance of the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, however we may decline to accept a client if we feel their restrictions are overly burdensome. MD Financial / Vestment Financial evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. MD Financial / Vestment Financial may recommend, on occasion, redistributing investment allocations to diversify the portfolio. MD Financial / Vestment Financial may recommend specific positions to increase sector or asset class weightings. The firm may recommend employing cash positions as a possible hedge against market movement, which may adversely affect the portfolio’s performance. MD Financial / Vestment Financial may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Page 5 Prior to rendering investment advisory services, MD Financial / Vestment Financial will assess, in conjunction with the Client, the Client’s financial situation, risk tolerance, investment/custodial platform, and investment objective[s]. MD Financial / Vestment Financial will provide investment advisory services and portfolio management services but does not provide other administrative services. At no time will MD Financial / Vestment Financial accept or maintain custody of a Client’s funds or securities. All Client assets will be managed within their designated brokerage account or pension account, pursuant to the Client Investment Advisory Agreement. Financial Planning and Consulting Services MD Financial / Vestment Financial will typically provide a variety of financial planning services to individuals, businesses and families, pursuant to a written Financial Planning Agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals, objectives and financial situation. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not limited to investment planning, retirement

planning, personal savings, education savings and other areas of a Client’s financial situation. A financial plan developed for or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. MD Financial / Vestment Financial may also refer Clients to an accountant, attorney or other specialist, as appropriate for their unique situation. For certain financial planning engagements, the firm will provide a written summary of a Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the firm may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations may pose a potential conflict between the interests of the firm and the interests of the Client. Clients are not obligated to implement any recommendations made by the firm or maintain an ongoing relationship with the firm. If the Client elects to act on any of the recommendations made by the firm, the Client is under no obligation to effect the transaction through the firm but may purchase investment products recommended through other brokers or agents that are not affiliated with MD Financial / Vestment Financial. Financial planning engagements may also include non-discretionary advisory services, whereby MD Financial / Vestment Financial will make recommendations and the Client is free to choose whether to implement all, some, or none of the recommendations. Financial planning engagements do not however include ongoing management or supervision services which are offered separately. Retirement Plan Services MD Financial / Vestment Financial also offers retirement plan services to businesses and other plan sponsors where the firm provides plan level services such as discretionary management services, non-discretionary management services, and investment advisory services related to different types of employer sponsored retirement plans. When providing discretionary management services, the firm is responsible for making and implementing decisions. When providing non-discretionary management services, the firm is responsible for making recommendations and for implementing upon client approval. When the firm is providing advisory services, the client is responsible for implementation of recommendations. C. Client Account Management Page 6 Because MD Financial / Vestment Financial is a registered investment adviser, we are required to meet certain fiduciary standards when providing investment advice to clients. Additionally, when we provide investment advice related to a retirement plan account or an individual retirement account, we are considered 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. As such, we are required to act in your best interest and not put our interest ahead of yours, even though our compensation creates some conflicts with your interests in that the more you have us manage, the more we can earn. Our clients however are under no obligation to use services recommended by our associated persons. Furthermore, we believe that our recommendations are in the best interests of our clients and are consistent with our clients’ needs. Prior to engaging MD Financial / Vestment Financial to provide investment advisory services, each Client is required to enter into an Investment Advisory Agreement with the firm that defines the terms, conditions, authority and responsibilities of the firm and the Client. These services may, but will not necessarily, include:  Establishing an Investment Policy Statement – MD Financial / Vestment Financial, in connection with the Client, may develop a statement that summarizes the Client’s investment goals and objectives along with the broad strategy[ies] to be employed to meet the client’s objectives. An Investment Policy Statement generally includes specific information on the Client’s stated goals, time horizon for achieving the goals, investment strategies, Client risk tolerance and any restrictions imposed by the Client.  Asset Allocation – MD Financial / Vestment Financial will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.  Portfolio Construction – MD Financial / Vestment Financial will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.  Investment Management and Supervision – MD Financial / Vestment Financial will provide investment management and ongoing oversight of the Client’s portfolio and overall account. D. Wrap Fee Programs MD Financial / Vestment Financial does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by MD Financial / Vestment Financial. E. Assets Under Management As of March 08, 2024, the firm managed $213,412,385 in assets, all of which was managed on a discretionary basis.