Tudor Financial, Inc. was founded in 1992. The firm has operated and grown consistently since that time. In April 2020 the firm applied to become registered with the U.S. Securities and Exchange Commission. The firm has expanded to provide investment management and comprehensive financial advisory services to individuals, businesses, retirement and pension plans. Clients benefit from the extensive experience of Tudor Financial advisors, the firm’s deep research capabilities, a wide range of investment strategy choices and extensive investment in technology. The principal owner of the firm is Grant S. Donaldson, MS, CPA. Services offered include: Investment Management: Tudor Financial specializes in professional investment management services. The firm is research-driven and can provide an array of strategies structured to provide investment strategies that facilitate long- term client objectives. The firm’s investment management services are designed to provide a wide range of investment choices – from conservative income strategies to balanced growth to aggressive growth. The investment securities the firm uses to implement these strategies include no-load mutual funds, individual securities, bonds and exchange-traded funds. Tudor offers investment management services to individuals, families and institutions - for owners and employees in the form of retirement accounts and pooled retirement pension accounts. Tudor Financial has developed well-researched investment methods over its history and selects the most promising investment securities appropriate for a range of unique client return and risk profiles. The experience includes: Assessment: The Investment Management process begins with a determination of each client’s and institution’s unique return and risk profile. This initial stage helps assure that investment and strategy recommendations are aligned with client investment experience preferences. The assessment process includes a six-page questionnaire coupled with client discussions. This initial process helps determine the segment(s) of investment choices appropriate for the return and risk profile of each client. Strategies Aligned With Client/Institution Goals: Investment Models – Clients receive the benefits of a disciplined approach to investment management. Tudor manages a number of investment strategies designed to accommodate a range of client goals and unique return and risk profiles. Tudor strategies use a variety of investment vehicles including ETF’s, mutual funds and individual securities that are aligned to client needs. Client account size, liquidity and risk orientation determine which investment vehicles are appropriate for a portfolio. Custom Solutions – Clients with larger pools of assets may require customized investment services. Customized solutions are designed and appropriate for larger portfolios of $1 million or more. The firm offers sophisticated investment solutions to accommodate unique needs, including tax evaluation and risk management strategies. Types of Securities: The firm uses the following types of securities in fee-managed accounts: Individual Securities Designed for Two Investment Approaches: 1. Customized strategies for accounts over $1 million – Individual securities are ideal for larger portfolios. These securities can include individual stocks, bonds, preferred stocks, convertibles, closed-end funds and other similar securities. These include publicly available securities and currently do not include private equity. 2. Legacy Growth Strategy – This is Tudor’s premier and historically successful individual stock strategy designed for accounts $500,000 or larger. Legacy Growth is a value-based, quality stock strategy that filters down to a select group of security candidates. Filtered securities meet very high standards for financial strength and lower risk. There are approximately 2,800 stocks that trade on the New York Stock Exchange - a mere 5% of that universe meets the high quality corporate business and quality stock requirements of this strategy. Important performance-enhancing characteristics of this strategy include dividend-paying companies, stock price stability, company business entrenchment and stability, superior company financial strength and dividend growth. The companies in this strategy most often have a strong franchise in their industry. Additionally, the securities included in the Legacy Growth Strategy most often offer exceptional opportunities for growth since they are purchased when the underlying companies and their related stocks are temporarily out-of-favor. This approach has historically enhanced client long-term gains. Exchange-Traded Funds – ETF’s are investment vehicles that mimic the qualities of mutual funds, but are tradable during market hours. These securities are appropriate for accounts $50,000 or more since they incur transaction (purchase and sale) costs. Their internal costs are quite low relative to mutual fund alternatives, making them economical investment choices. There are an estimated 1,800 ETF choices available at this writing, with many added and many discontinued each year. The ETF market holds over $1 trillion of investment assets at this time and continues to grow rapidly due to the aforementioned attractive qualities. Tudor Financial employs a unique system to screen for only the most liquid ETF’s available, which the firm defines as those with an average daily volume of 250,000 or more. Liquidity

is important to minimize costs and assure sufficient buyers and sellers are available when purchases and sales are made. Illiquid ETF’s can be risky in market declines when buyers might be scarce. Out of the entire universe of choices, less than 180 ETF’s meet our liquidity and risk requirements. 1. ETF Strategies: Tudor Financial has developed an array of ETF strategies to satisfy a range of investment goals. The general selection process is as follows: ETF information is downloaded, sorted and filtered. ETF candidates that meet our liquidity requirements are then evaluated for risk characteristics. Using the S&P 500 as a benchmark, we establish maximum levels of risk for any ETF candidate (typically no more than 130% of S&P 500 risk). ETF’s that meet liquidity and risk parameters then become potential candidates for Tudor Financial ETF strategies. Filtered positions are then ranked according to performance in the current economic/financial environment. Highly-ranked ETF’s are considered as new portfolio candidates or continue to be maintained in client portfolios. ETF’s that decline in the rankings are replaced by higher-ranked ETF alternatives. This process assures that the best-performers are included in each strategy while underperformers are sold over time. Certain strategies will have return/risk characteristics below the S&P 500 while others will have return/risk characteristics similar to the S&P 500. An entire range of growth and risk characteristics are reflected in our spectrum of strategy choices. The consistency of our process to evaluate liquidity, risk and performance characteristics makes our ETF strategies ideal choices for a wide range of clients. ETF Strategies are discussed in more detail at Item 8. Minimum account recommendation for ETF strategies: $50,000. 2. ETF Asset Allocation Strategy – The firm has developed a unique Asset Allocation strategy that utilizes very cost-effective ETF securities. We call this The Spectrum Strategy. This strategy invests in a very wide and diverse spectrum of investment categories including: Large Cap Domestic Stocks, Full Market Domestic Stocks, Developed International Stocks, Emerging Market Stocks, Corporate Bonds, Diversified Bonds, Real Estate Securities and Commodities. Each category is allocated according to internal evaluations of performance. The Spectrum Strategy was developed for those that are heavily focused on capital preservation and diversification but have a desire for growth of investment principal over time. Minimum account recommendation: $100,000 or greater. No-Load Mutual Funds – No-load mutual funds are those that have no sales charges associated with them. These funds are typically available to many investors; however, our ranking system provides a special method of selection to increase the probability of improved performance over time. 1. The firm employs a mutual fund selection system that reviews the performance of 1,000’s of mutual funds. Our filtering process eliminates smaller, less established funds (typically those with under $100 million in assets). The remaining funds are then divided into five risk categories – funds within the two highest quintiles of risk are eliminated. The remaining three mutual fund return/risk categories are then ranked to find the best-performing no- load mutual fund choices based on the current economic and financial environment. Highly-ranked no-load mutual funds for each of the strategies are maintained or purchased in appropriate client portfolios. Funds that decline in the rankings are replaced by higher- ranked funds. This process assures that the best-performing funds are included in each strategy, and underperformers are sold over time. Tudor Financial mutual fund strategies are discussed in more detail in Item 8. Minimum mutual fund strategies account recommendation: $10,000. Financial Planning Services: Our advisors include CPA’s, CFP’s, CLU’s, EA’s and other credentialed professionals. Our Financial Planning Services are rendered to clients on a per-hour basis or one-time basis. Fees depend on the complexity and involvement of the services rendered. In many cases, advice is provided to investment management clients for no cost depending on the established relationship of the advisor and client and level of assets managed. The rates for Financial Planning Services vary depending on complexity and experience level of the adviser. Financial Planning Services include investment advice, estate planning, tax planning, insurance review and other business and personal financial matters. A typical complete financial plan for established clients includes meetings with a credentialed planning professional, and begins at $495. Other Financial Planning Advice: Our advisors may periodically offer tax and estate planning advice and guidance while working with client tax and legal advisors. Tudor does not engage in tax preparation services. Individual advisors could provide that service if they had appropriate credentials. Educational Seminars/Newsletters: The firm offers educational seminars at their facility or other venues on a variety of financial topics that are available to clients and the public. Topics can include estate planning, financial markets, tax planning and others. There is typically no cost for these educational seminars. Additionally, newsletters that include a variety of financial planning topics are mailed on a periodic basis free of charge to existing and prospective clients. The firm manages approximately $ 199,403,000 in discretionary assets as of 12/31/2023