A. Description of Advisory Firm Including How Long We Have Been In Business and Our Principal Owner(s) Western Financial Corporation (“WFC,” “The Firm,” or “We”) is an SEC-registered investment adviser (“RIA”) and adheres to a fiduciary duty to all clients of the firm, including retirement plan clients where we act as a fiduciary adviser under the Employee Retirement Income Security Act of 1974 (“ERISA”). We are dedicated to providing individuals and other types of clients with a wide array of investment advisory services. The Firm is a privately-owned corporation headquartered in San Diego, California. Originally formed in the State of California in 1971, under the name JB Financial, Inc., the name was changed to Western Financial Corporation in 1974. WFC maintained registration as a FINRA registered broker-dealer from 1971 to 2020. We expanded to include an RIA in 2017. The Firm’s principal owner is the Richard S. Levenson Trust. 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 WFC 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. 5 | P a g e W e s t e r n F i n a n c i a l C o r p o r a t i o n N o v e m b e r 3 , 2 0 2 3 Duty of Loyalty WFC 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, WFC 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 least expose through full and fair disclosure all conflicts of interest which might incline WFC, 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. B. Description of the Types of Advisory Services We Offer Customized Portfolio Management Services WFC offers Customized Portfolio Management (CPM) services to individual investors, trusts, estates, charitable organizations, retirement plans, retirement plan fiduciaries, participants of retirement plans, small businesses and high-net-worth individuals based on the individual goals, objectives, time horizon, liquidity needs and risk tolerance of each particular client. The Firm assesses each client’s current situation (income, tax levels, existing resources, financial goals, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio of securities that matches each client’s specific situation. These services include, but are not limited to, the following: ▪ Investment Strategy ▪ Asset Allocation ▪ Individual Security Selection ▪ Regular portfolio monitoring WFC actively manages client portfolios on an ongoing basis and rebalances them when, in WFC’s judgment, rebalancing is warranted in light of market conditions and/or changes in clients’ circumstances. If the client experiences any significant changes to his/her financial or personal circumstances, the client must notify us so that we can consider such information in managing the client’s investments. The Firm’s practice includes account management offered on both a discretionary and non-discretionary basis. Clients who engage WFC to provide investment advisory services will be required to complete an Investment Management Agreement (IMA) and Client Profile. The IMA details the terms and conditions of the engagement and the scope of the services WFC will provide. The Client Profile provides WFC with valuable personal information regarding the client’s financial situation and risk tolerance. This information is used in the design, implementation, and management of a client’s investment portfolio. WFC utilizes the following investment types in its clients’ accounts: 1. Equity Securities, including U.S. stocks and foreign stocks listed on U.S. exchanges (ADRs) 2. Fixed Income Securities, including corporate, U.S. government and municipal bonds, commercial paper, and certificates of deposit (CD’s) 3. Exchange Traded Funds (ETFs) 6 | P a g e W e s t e r n F i n a n c i a l C o r p o r a t i o n N o v e m b e r 3 , 2 0 2 3 4. Money market funds and cash Depending on the client’s individual investment objectives and needs WFC’s investment selections may further include: 1. Securities with equity and debt characteristics, including convertible bonds, preferred stocks, or other preferred securities 2. Real estate investment trusts (REITs) 3. Mutual funds 4. Exchange traded notes (ETNs) 5. Closed-end funds 6. Unit Investment Trusts (UITs) 7.

Mortgage backed securities (MBS) and Collateralized Mortgage Obligations (CMO’s) 8. High-yield debt 9. Treasury inflation protected securities (TIPs) 10. Master limited partnerships (MLP) 11. Call or put options listed on U.S. exchanges Western Retirement Plan Program (WRPP) WFC provides various consultation and investment services to retirement plans, fiduciaries of retirement plans, and participants of retirement plans through its Western Retirement Plan Program (WRPP) including, but not limited to, the following: Consultation Services 1. WFC assists clients with plan design considerations. 2. WFC assists clients in understanding their fiduciary responsibilities. 3. WFC provides initial consultation services as to the selection of plan service vendors. 4. WFC prepares Request for Proposals (RFPs) for plan recordkeepers, third party administrators or other plan service providers and assists with the review and evaluation of the responses. In performing the consultation services listed above, WFC does not provide investment advice and is not acting as a fiduciary of a plan. Plan Level Non-Discretionary Investment Advisory Services 1. WFC assists clients in the development of an investment policy statement (IPS). The IPS establishes the investment policies and objectives for the plan. Clients, however, have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS. 2. WFC provides non-discretionary investment advice to clients about asset classes and investment alternatives available for the plan in accordance with the plan’s investment policies and objectives. Clients have the final decision-making authority regarding the initial selection, retention, removal, and addition of investment options. 3. WFC assists clients with the selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder. 7 | P a g e W e s t e r n F i n a n c i a l C o r p o r a t i o n N o v e m b e r 3 , 2 0 2 3 4. WFC assists in monitoring investment options by preparing periodic investment reports that are based on conformance to the guidelines set forth in the IPS and makes recommendations to maintain or remove and/or replace investment options. 5. WFC meets with clients on a periodic basis to discuss the reports and the investment recommendations. 6. WFC provides non-discretionary investment advice to clients with respect to the selection of a qualified default investment alternative (“QDIA”) for participants who fail to make an investment election. Clients, however, remain responsible for determining whether the plan should have a QDIA. Clients also retain the sole responsibility to provide all notices to participants required under ERISA Section 404(c)(5). The non-discretionary investment services listed above are provided under Section 3(21) of ERISA. Plan Level Discretionary Investment Management Services 1. WFC develops an investment policy statement (IPS) for its clients which establishes the investment policies and objectives for a plan. 2. WFC selects a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder. 3. WFC provides ongoing and continuous discretionary investment management with respect to the asset classes and investment alternatives available under the plan in accordance with the IPS. Under this authority, WFC may select, retain, remove and/or replace the investment alternatives available under the plan in its discretion. 4. Clients are responsible for determining whether the plan should have a qualified default investment alternative (“QDIA”) for participants who fail to make an investment election. When clients determine that the plan should have a QDIA, WFC will select the investment to serve as the QDIA. Clients retain the sole responsibility to provide all notices to participants required under ERISA Section 404(c)(5). 5. WFC provides clients with periodic reporting of investment performance and results. The discretionary investment services listed above are provided under Section 3(38) of ERISA. Rollover Recommendations WFC provides services to retirement plans and participant clients. With regard to plan distributions and rollovers, if WFC were to make recommendations (“rollover recommendations”) to participants, it would be a conflict of interest because it results in WFC receiving compensation that it would not have received absent the recommendation, for example, fees for advising the rollover IRA. As a result, WFC does not make rollover recommendations. Instead, WFC provides information about the alternatives available to participants, and answers their questions in a neutral, educational manner. In that way, a participant can make an informed decision about whether to take a distribution and, if so, whether to roll it over to an IRA with WFC or another IRA provider. No client is under an obligation to roll over ERISA plan or IRA assets to an account advised by WFC. 8 | P a g e W e s t e r n F i n a n c i a l C o r p o r a t i o n N o v e m b e r 3 , 2 0 2 3 Financial Planning Services WFC provides financial planning services as part of our overall advisory services or at a client’s request. When utilized, these services generally include advising clients on retirement and cashflow planning, risk management, estate planning and tax planning. However, services do not include preparation of any income tax, gift, or estate tax returns, or preparation of any legal documents. WFC does not receive separate compensation for the above-mentioned ancillary financial planning services. C. Tailored Services and Client Imposed Restrictions Clients may request restrictions on the account, such as prohibiting specific security purchases or keeping a minimum level of cash in the account; however, we typically do not allow clients to impose restrictions on investing in broader types of securities/sectors due to changes in underlying positions held in some ETFs that we recommend and/or the level of difficulty this would entail in managing their account. WFC reserves the right to not accept and/or terminate management of a client’s account if we feel that any client-imposed restrictions would limit or prevent us from meeting or maintaining the client’s investment strategy. D. Participation in Wrap Fee Programs We do not participate in or 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 WFC offers management of client assets in both discretionary and non-discretionary accounts on a continuous and regular basis. As of September 30, 2023, the total amount of assets under our management was: Discretionary Assets $ 200,254,301 Non-Discretionary Assets $ 0 Total Assets $ 200,254,301