David Walter acquired Halberstadt Financial in 2000 and is the owner and principal of the Firm. Mr. Walter, who is a CPA and CFP, has more than 30 years of financial services experience. Prior to Halberstadt Financial, Mr. Walter worked as Treasurer for the Carnegie Foundation for the Advancement of Teaching. Mr. Walter also worked as an auditor/accountant for several firms, including KPMG. Investment Management Services: Halberstadt Financial provides continuous advice to a client regarding investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client’s particular circumstances are established, Halberstadt Financial develops a client’s personal investment policy and creates and manages a portfolio based on that policy. Halberstadt Financial will manage advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the stated objectives of the client (i.e., maximum capital appreciation, growth, income, growth and income or capital preservation). Halberstadt Financial will create a portfolio consisting of one or all of the following: individual equities, bonds, exchange-traded funds, mutual funds and other investment products. Halberstadt Financial will allocate the client’s assets among various investments taking into consideration the overall management style selected by the client. The mutual funds will be selected on the basis of any or all of the following criteria: (1) the fund’s performance history; (2) the industry sector in which the fund invests; (3) the track record of the fund’s manager; (4) the fund’s investment objectives; (5) the fund’s management style and philosophy; and (6) the fund’s management fee structure. Portfolio weighting between funds and market sectors will be determined by each client’s individual needs and circumstances. Clients will have the opportunity to place reasonable restrictions on the types of investments that will be made on the client’s behalf. Clients will retain individual ownership of all securities that are held by an independent custodian. When appropriate to the needs of the client, Halberstadt Financial may recommend the use of short-term trading (securities sold within 30 days), short sales, margin transactions or option writing. Because these investment strategies involve certain additional degrees of risk, they will only be recommended when consistent with the client’s stated tolerance for risk. Clients may meet with Halberstadt Financial annually or more frequently, as needed, to review their portfolios. At these meetings clients may consult Halberstadt Financial about other financial matters including budgeting, retirement and distribution planning and college planning. No additional fee above the annual fee for this service, as detailed below, will be charged for this consultation. The firm’s assets under management totaled approximately $130,000,000 as of January 31, 2023. 55% of this amount was managed on a discretionary basis, and 45% was managed on a non-discretionary basis.
Financial Planning Services: Halberstadt Financial also provides advice in the form of a financial plan. Clients receiving this service will receive a written report, providing the client with a detailed financial plan designed to achieve his or her stated financial goals and objectives. In general, the financial

plan will address any or all of the following areas of concern: a) Personal: Budgeting, personal liability, estate information and financial goals. b) Education: 529 plans, financial aid, custodial accounts, grants and general assistance in prepar- ing to fund continuing educational needs through development of an education plan.
c) Tax & Cash Flow: Income tax and spending analysis and planning for past, current and future years. Halberstadt Financial will illustrate the impact of various investments on a client’s current income tax and future tax liability. d) Death & Disability: Cash needs at death, income needs of surviving dependents, estate planning and disability income analysis. e) Retirement: Analysis of current strategies and investment plans to help the client achieve his or her retirement goals. Both retirement funding and distribution strategies are available. f) Investments: Analysis of investment alternatives and their effect on a client’s portfolio. Halberstadt Financial gathers information through personal interviews. Information gathered includes a client’s current financial status, future goals and attitudes towards risk. Related documents supplied by the client are carefully reviewed, including a questionnaire completed by the client, and a written report is prepared. Should a client choose to implement the recommendations contained in the plan, Halberstadt Financial suggests the client work closely with his/her attorney, accountant, insurance agent, and/or stock broker. Implementation of financial plan recommendations is entirely at the client’s discretion. Financial planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. Consulting Services: Clients can receive investment advice on a more limited basis. This may include advice on only an isolated area(s) of concern such as asset allocation, tax planning, retirement planning, reviewing a client’s existing portfolio, or any other specific topic. Halberstadt Financial also provides specific consultation and administrative services regarding investment and financial concerns of the client. Additionally, Halberstadt Financial provides advice on non-securities matters. Generally, this is in connection with the rendering of estate planning, insurance, and/or annuity advice. Other Terms & Conditions: Prior to engaging Halberstadt Financial to provide investment advisory services, the client will be required to enter into a formal Agreement with Halberstadt Financial setting forth the terms and conditions under which it shall provide advisory services and, when applicable, a separate custodial/clearing agreement with a designated broker-dealer/custodian. Both Halberstadt Financial's Agreement and the custodial/clearing agreement authorize the custodian to debit the account for the amount of the investment advisory fee and to remit payment directly to Halberstadt Financial. In the event that Halberstadt Financial bills the client directly, payment is due upon receipt of the invoice. The Agreement between Halberstadt Financial and the client will continue in effect until terminated in writing by either party with a 30-day notice. In the event the client terminates Halberstadt Financial’s services, the balance of any unearned fee shall be refunded to the client.