We specialize in the following types of services: Asset Management, Pension Consulting, and 401(k) Participant Service. A. Description of our advisory firm, including how long we have been in business and our principal owner(s)1. We are dedicated to providing individuals and other types of clients with a wide array of investment advisory services. Our firm is a corporation formed in the State of California in 2008, has been in business as an investment adviser since 2009, and is owned as follows by: Jeffrey Kapral Mestmaker – 50% Owner Daniel Patrick Petrey – 50% Owner B. Description of the Types of Advisory Services We Offer. (i) Asset Management: We emphasize continuous and regular account supervision. As part of our asset management service, we generally create a portfolio, consisting of individual stocks or bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or investments. The client’s individual investment strategy is tailored to his/her specific needs and may include some or all of the previously mentioned securities. Each portfolio will be initially designed to meet a particular investment goal, which we determine to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, we review the portfolio at least quarterly and if necessary, rebalance the portfolio based upon the client’s individual needs, stated goals and objectives. Each client can place reasonable restrictions on the types of investments to be held in the portfolio. (ii) Pension Consulting: We provide pension consulting services to employer plan sponsors on an ongoing basis. Generally, such pension consulting services consist of assisting employer plan sponsors in establishing, monitoring, and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising could include investment options, plan structure and participant education. All pension consulting services shall be in compliance with the applicable state law(s) regulating pension consulting services. This applies to client accounts that are pension or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). 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 1 Please note that: (1) For purposes of this item, our principal owners include the persons we list as owning 25% or more of our firm on Schedule A of Part 1A of Form ADV (Ownership Codes C, D or E). (2) If we are a publicly held company without a 25% shareholder, we simply need to disclose that we are publicly held. (3) If an individual or company owns 25% or more of our firm through subsidiaries, we must identify the individual or parent company and intermediate subsidiaries. If we are a state-registered adviser, on Form ADV Part 2A Page 2, we must identify all intermediate subsidiaries. If we are an SEC-registered adviser, we must identify intermediate subsidiaries that are publicly held, but not other intermediate subsidiaries. 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 Pension Consulting Agreement). (iii) 401(k) Participant Service: We occasionally assist individuals, who do not receive any of the advisory services noted in 401(k) accounts and offer advice as to the allocation of funds in such accounts and provide an explanation of the plan. We do not manage these accounts and only offer advice when requested by these individuals. These assets are not included in our firm's assets under management.

(iv) Online Newsletter & Blog: We occasionally provide newsletters and write on a blog, which is viewable to our clients when signing up for a yearly subscription. “Western Financial Underground” will be a subscription newsletter to assist those who would like investment help but do not want to give up total control of their investment portfolio. It will have a somewhat aggressive bias so subscribers should use discretion when determining appropriate portfolio allocation percentages. (v) IRA Rollover Recommendations: For the purpose of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02"), when applicable, we are providing the following acknowledgment to clients. When we provide investment advice to clients regarding their retirement plan account or individual retirement account, we are a fiduciary 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 client interests. We operate under an exemption that requires we act in the clients’ best interest and not put our or our employees’ interests ahead of the clients. Under this exemption, we must:
• meet a professional standard of care when making investment recommendations (give prudent advice),
• never put our or our employees’ financial interests ahead of the clients when making recommendations (give loyal advice),
• avoid making misleading statements about conflicts of interest, fees, and investments,
• follow policies and procedures designed to ensure that our and our employees give advice that is in the clients’ best interest,
• charge no more than is reasonable for services, and
• give the clients basic information about conflicts of interest. We benefit financially from the rollover of the clients’ assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when our and our employees believe it is in the clients’ best interest. (vi) Education Seminars: We provide education seminars for retirement plan fiduciaries at no additional costs to clients. C. Explanation of whether (and, if so, how) we tailor our advisory services to the individual needs of clients, whether clients may impose restrictions on investing in certain securities or types of securities. (i) Individual Tailoring of Advice to Clients: We offer individualized investment advice to clients utilizing our Asset Management service. On the other hand, we offer general investment advice to clients utilizing our Pension Consulting, and 401(k) Participant Service. (ii) Ability of Clients to Impose Restrictions on Investing in Certain Securities or Types of Securities: Each client can place reasonable restrictions on the types of investments to be held in the portfolio. 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. Restrictions would be limited to our Asset Management service. We do not manage assets through our other services. D. Participation in Wrap Fee Programs. We do not offer wrap fee programs. E. Disclosure of the amount of client assets we manage on a discretionary basis and the amount of client assets we manage on a non-discretionary basis as of December 31, 2023. We manage2 approximately $97.9 million on a discretionary basis and $0 on a non-discretionary basis. We also have approximately $93.6 million of assets under advisement3.