A. Firm Information K2 Financial Inc. (“K2 Financial” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”), which is organized as a Corporation under the laws of the State of California. K2 Financial was founded in January 2019 and is owned and operated by Allison Kapadia, Travis Bettfreund, and Kevin Kurimoto. As of the date of this filing, Travis Bettfreund is the Chief Compliance Officer of K2 Financial. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by K2 Financial. B. Advisory Services Offered K2 Financial offers investment advisory services to individuals, high net worth individuals, trusts, estates, and retirement plans (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. K2 Financial’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth and Investment Management Services K2 Financial’s investment strategies are adapatable to the needs of each Client based on a deep understanding of the Client’s long-term goals. This is achieved through regular personal Client contact and interaction while providing discretionary and non-discretionary investment management and related advisory services. K2 Financial works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to implement an appropriate portfolio strategy. The Advisor utilizes individual Mutual Funds, ETFs, Third Party Managers, stocks, bonds, Cash, CDs, Treasuries and options contracts to meet the needs of its Clients. The Advisor may retain certain types of investments based on a Client’s legacy portfolio construction. K2 Financial’s investment approach is primarily long-term focused, but, occasionally, the Advisor will buy, sell, or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. K2 Financial will construct, implement, and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. K2 Financial also offers the K2 Financial Asset Management Program (“the Program”) as part of its wealth and investment management services. Each investment strategy consists of investments specifically selected in order to achieve that particular strategy's investment objective. The Client's assets are invested in a manner consistent with the investment strategy chosen; however, specific Client portfolios could deviate from the Program's investment strategies due to a number of factors, including, among others, inception date of the account, tax considerations, liquidity needs, and other circumstances specific to the Client. K2 Financial evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. If appropriate for a Client, K2 Financial will generally consider redistributing investment allocations to diversify the portfolio, recommending specific positions to increase sector or asset class weightings, employing cash positions as a possible hedge against market movement, and/or selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, overvaluation or overweighting of the position[s] in the portfolio, changing risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. K2 Financial offers in conjunction with its investment management services, cash management services through the use of Cash and Cash Equivalents (CDs, Treasury Bills, and Money Market Mutual Funds). At no time will K2 Financial accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Financial Planning Services K2 Financial will typically provide a variety of financial planning and consulting services to Clients. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting encompasses one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs 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 can be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. When appropriate, K2 Financial will refer Clients to an accountant, attorney, or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor typically does not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor would pose a conflict, as it would increase the advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Retirement Plan Advisory Services K2 Financial provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Investment Oversight Services (ERISA 3(21))
• Investment Management Services (ERISA 3(38))
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
• Benchmarking Services These services are provided by K2 Financial serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of K2 Financial’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Use of Independent Managers At times, K2 Financial will recommend that a Client utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio if the Advisor deems such actions to the best interest of the Client. In such instances, the Client generally will be required to authorize and enter into a separate investment management agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide its services. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Clients’ investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client, prior to entering into an agreement with an Independent Manager[s], will be provided with the Independent Manager's Form ADV Part 2A (or a brochure that makes the appropriate disclosures). Advisor’s fees do not include those fees that Client will be charged by an Independent Manager. Please refer to Item 5 below for additional information regarding fees. Cash Positions K2 Financial continues to treat cash as an asset class. As such, unless determined to the contrary by K2 Financial, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating K2 Financial’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), K2 Financial may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, K2 Financial’s advisory fee could exceed the interest paid by the client’s money market fund. Cash Sweep Accounts Account custodians generally require that cash proceeds from account transactions or cash deposits be swept into and/or initially maintained in the custodian’s sweep account. The yield on the sweep account is generally lower than those available in money market accounts. To help mitigate this issue, K2 Financial shall generally purchase a higher yielding money market fund available on the custodian’s platform with cash proceeds or deposits, unless K2 Financial reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to, the amount of dispersion between the sweep account and a money market fund, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. Borrowing Against Assets/Risks A client who has a need to borrow money could determine to do so by using:
• Margin – The account custodian or broker-dealer lends money to the client. The custodian charges the client interest for the right to borrow money, and uses the assets in the client’s brokerage account as collateral; and,
• Pledged Assets Loan – In consideration for a lender (i.e., a bank, etc.) to make a loan to the client, the client pledges investment assets held at the account custodian as collateral. These above-described collateralized loans are generally utilized because they typically provide more favorable interest rates than standard commercial loans. These types of collateralized loans can assist with a pending home purchase, permit the retirement of more expensive debt, or enable

borrowing in lieu of liquidating existing account positions and incurring capital gains taxes. However, such loans are not without potential material risk to the client’s investment assets. The lender (i.e., custodian, bank, etc.) will have recourse against the client’s investment assets in the event of loan default or if the assets fall below a certain level. For this reason, K2 Financial does not recommend such borrowing unless it is for specific short-term purposes (i.e., a bridge loan to purchase a new residence). K2 Financial does not recommend such borrowing for investment purposes (i.e., to invest borrowed funds in the market). Regardless, if the client was to determine to utilize margin or a pledged assets loan, the following economic benefits would inure to K2 Financial:
• by taking the loan rather than liquidating assets in the client’s account, K2 Financial continues to earn a fee on such Account assets; and,
• if the client invests any portion of the loan proceeds in an account to be managed by K2 Financial, K2 Financial will receive an advisory fee on the invested amount; and,
• if K2 Financial advisory fee is based upon the higher margined account value, K2 Financial will earn a correspondingly higher advisory fee. This could provide K2 Financial with a disincentive to encourage the client to discontinue the use of margin. Please Note: The Client must accept the above risks and potential corresponding consequences associated with the use of margin or a pledged assets loan. Retirement Rollovers – Potential for Conflict of Interest A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If K2 Financial recommends that a client roll over their retirement plan assets into an account to be managed by K2 Financial, such a recommendation creates a conflict of interest if K2 Financial will earn new (or increase its current) compensation as a result of the rollover. If K2 Financial provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), K2 Financial is acting as 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. No client is under any obligation to roll over retirement plan assets to an account managed by K2 Financial, whether it is from an employer’s plan or an existing IRA. Socially Responsible Investing Limitations Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that maintain an acceptable ESG mandate can be limited when compared to those that do not and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange-traded funds are limited when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by K2 Financial), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. K2 Financial does not maintain or advocate an ESG investment strategy but will seek to employ ESG if directed by a client to do so. Use of Mutual and Exchange Traded Funds K2 Financial utilizes mutual funds and exchange traded funds for its client portfolios. In addition to K2 Financial’s investment advisory fee described below, and transaction and/or custodial fees discussed above, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Use of DFA Mutual Funds: K2 Financial utilizes the mutual funds issued by Dimensional Fund Advisors (“DFA”). DFA funds are generally only available through registered investment advisers approved by DFA. Thus, if the client was to terminate K2 Financial’s services, and transition to another adviser who has not been approved by DFA to utilize DFA funds, restrictions regarding additional purchases of, or reallocation among other DFA funds, will generally apply. Portfolio Activity K2 Financial has a fiduciary duty to provide services consistent with the client’s best interest. K2 Financial will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, fund manager tenure, style drift, account additions or withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when K2 Financial determines that changes to a client’s portfolio are unnecessary. Clients remain subject to the fees described in Item 5 below during periods of portfolio inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by K2 Financial will be profitable or equal any specific performance level(s). Reporting Services K2 Financial can also provide, for a separate fee, account reporting services, which can incorporate client investment assets that are not part of the assets that K2 Financial manages (the “Excluded Assets”). Unless agreed to otherwise, the client and/or their other advisors that maintain trading authority, and not K2 Financial, shall be exclusively responsible for the investment performance of the Excluded Assets. Unless also agreed to otherwise, K2 Financial does not provide investment management, monitoring or implementation services for the Excluded Assets. If K2 Financial is asked to make a recommendation as to any Excluded Assets, the client is under absolutely no obligation to accept the recommendation, and K2 Financial shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. The client can engage K2 Financial to provide investment management services for the Excluded Assets pursuant to the terms and conditions of the Investment Advisory Agreement between K2 Financial and the client.
• eMoney: In the event that K2 Financial provides the client with access to an unaffiliated vendor’s website such as eMoney (change if a different vendor), and the site provides access to information and/or concepts, including financial planning, the client, should not, in any manner whatsoever, infer that such access is a substitute for services provided by K2 Financial. Rather, if the client utilizes any such content, the client does so separate and independent of K2 Financial. Other Assets To the extent that K2 Financial provides advisory monitoring or review services for client investment assets for which K2 Financial does not maintain custodian access or trading authority (including initial and ongoing consideration of such assets as part of the client’s asset allocation), K2 Financial may determine to include such assets in its advisory fee calculation per Item 5 below. Client Obligations In performing our services, K2 Financial shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, it remains each client’s responsibility to promptly notify K2 Financial if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. Investment Risk Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by K2 Financial) will be profitable or equal any specific performance level(s). Cybersecurity Risk The information technology systems and networks that K2 Financial and its third-party service providers use to provide services to K2 Financial’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in K2 Financial’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and K2 Financial are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost, and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although K2 Financial has established its systems to reduce the risk of cybersecurity incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that K2 Financial does not directly control the cybersecurity measures and policies employed by third- party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Disclosure Brochure A copy of K2 Financial’s written Brochure as set forth on Part 2A of Form ADV and Form CRS (Client Relationship Summary) shall be provided to each client prior to, or contemporaneously with, the execution of an agreement between the client and K2 Financial. C. Client Account Management Prior to engaging K2 Financial to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services can include:
• Establishing an Investment Strategy – K2 Financial, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – K2 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 – K2 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 – K2 Financial will provide investment management and ongoing oversight of the Client’s investment portfolio.
• Financial Planning – K2 Financial provides ongoing financial planning services to assist Clients in meeting their financial goals. D. Wrap Fee Programs K2 Financial does not manage or place Client assets into a wrap fee program. E. Assets Under Management As of December 31, 2022 K2 Financial manages $145,293,687 in Client assets, of which $138,507,857 are managed on a discretionary basis and $6,785,830 on a non-discretionary basis. Clients can request more current information at any time by contacting the Advisor.