A. Halpern Financial, Inc. (“Halpern Financial”) is a Maryland corporation formed on June 24, 1998, which became registered as an investment adviser in May 2000. Halpern Financial is owned by Ted S. Halpern, who is Halpern Financial’s principal owner, President, and Director. B. As discussed below, Halpern Financial offers investment advisory services to its clients, who are generally: individuals, high net worth individuals, trusts, estates, pensions and profit sharing plans. Although Halpern Financial may provide limited financial planning services upon request as part of the investment advisory process described below, it does not hold itself out as providing comprehensive financial planning services on a stand- alone, separate fee basis. INVESTMENT ADVISORY SERVICES The client can engage Halpern Financial to provide discretionary investment advisory services on a fee-only basis. Halpern Financial’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under management or advisement. As part of the investment advisory process, clients may choose to engage Halpern Financial to provide analysis and advice on various financial planning topics or financial consultative services at no additional charge, subject to the limitations below. Before engaging Halpern Financial to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement with Halpern Financial setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. As described in Item 5 below, clients will incur a “Client Establishment Fee,” which is an initial and one-time fee which covers the Wealth Profile (information gathering process) and preparation of a Review and Recommendation Report. This report includes an assessment of client’s current financial situation, general guidelines, and specific recommendations on client data collected. Based on this information, Halpern Financial will conduct a cash flow analysis, a debt management analysis, a review of all current accounts, a cost basis analysis, income planning, risk parameters examination, exposure to any potential estate tax liabilities and other distribution issues and a review of major financial concerns and financial priorities. The Client Establishment Fee also compensates for all account documentation, account transfers, reviews of security cost basis and client information loading into Halpern Financial’s systems, online access to Halpern Financial’s website and Halpern Financial’s meetings with other advisers of the client. After the Review and Recommendation Report, client onboards, and the Portfolio Development Report is presented and approved by the client, Halpern Financial will allocate the client’s investment assets consistent with the designated investment objectives. Halpern Financial primarily allocates client investment assets on a discretionary basis among various mutual funds, exchange traded funds (“ETFs”), and individual securities under special circumstances, in accordance with the client’s designated investment objectives. Once allocated, Halpern Financial provides ongoing monitoring and review of account performance and asset allocation as compared to client investment objectives and financial needs, and may periodically execute account transactions based upon those reviews or other triggering events. RETIREMENT PLAN SERVICES Halpern Financial provides services to assist plan sponsors, trustees, and administrators to meet fiduciary responsibilities under the Employee Retirement Income Security Act of 1974 (“ERISA”), which may include the following:
• Participant Education – Halpern Financial may provide group meetings and individual participant meetings to help participants achieve better financial understanding.
• Monitoring – Halpern Financial may establish and manage a process to select, de- select, and monitor investments offered to plan participants. Halpern Financial will then evaluate the plan’s current offering by benchmarking the investment return, risk, and expenses to its peers and relative indices, by providing an assessment of asset class overlap or gaps, and by evaluating overall investment offering to the plan.
• Trustee and Investment Committee Meetings – Halpern Financial may meet with the plan’s sponsor or administrator to document the performance of the plan’s investments and to make any recommendations that may be appropriate for changes.
• Discretionary Model Management – Halpern Financial may develop and manage portfolios designed to meet specific risk and return characteristics. These models will be comprised mainly of investments offered to plan participants. Halpern Financial may also serve as the advisor on these models in an advisory arrangement under ERISA § 3(21) and ERISA § 3(38) as described below. RETIREMENT PLAN CONSULTING SERVICES UNDER ERISA § 3(21) Halpern Financial provides retirement plan consulting services under ERISA §3(21). In this capacity, Halpern Financial assists sponsors of self-directed retirement plans with the selection and/or monitoring of investment alternatives from which plan participants choose in self-directing the investments for their individual plan retirement accounts. The plan sponsor or administrator ultimately decides whether and how to implement these recommendations. In addition, to the extent requested by the plan sponsor, Halpern Financial will also provide participant education designed to assist participants in identifying the appropriate investment strategy for their retirement plan accounts. The plan participants are responsible for any individual investment selections made under the plan. When providing services under ERISA §3(21), Halpern Financial does not exercise discretionary authority or control of plan assets or administration of the plan. RETIREMENT PLAN INVESTMENT MANAGEMENT SERVICES UNDER ERISA § 3(38) For the purposes of ERISA §3(38), Halpern Financial may serve as the “investment manager” that exercises discretionary authority to select‚ monitor‚ and replace the investment options in the plan platform, and provides model portfolios it develops and manages for the plan, from which the plan participants can self-direct. For non-self- directed retirement plans, Halpern Financial may also have discretion to purchase and sell securities within the plan’s portfolio without having to obtain the plan sponsor or administrator’s permission to execute transactions. MISCELLANEOUS Limitations of Consulting/Implementation Services. Although Halpern Financial does not hold itself out as providing financial planning services, it may choose to provide limited consultation services to its investment advisory clients about investment and non- investment related matters, such as estate planning, tax planning, insurance, etc. that are generally ancillary to the investment advisory process. Any such consultation services, to the extent rendered, shall be rendered exclusively on an unsolicited basis. Halpern Financial may seek to charge a fee for such consulting services according to the terms and conditions of a separate Limited Consulting Agreement that would be executed by the client and Halpern Financial. Neither Halpern Financial, nor any of its representatives, serves as an attorney, accountant, or licensed insurance agent, and no portion of Halpern Financial’s services should be construed as legal, accounting, or insurance implementation services. Accordingly, Halpern Financial does not prepare estate planning documents, tax returns or sell insurance products. Unless specifically agreed in writing, neither Halpern Financial nor its representatives are responsible to implement any financial plans or financial consulting advice; provide ongoing consulting services; or provide ongoing monitoring of financial plans or consulting advice. The client retains absolute discretion over all financial planning, consulting, and related implementation decisions, and is free to accept or reject any recommendation from Halpern Financial and its representatives. To the extent requested by a client, Halpern Financial may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance agents, etc.). Clients are under no obligation to engage the services of any recommended professional, who shall be solely responsible for the quality and competency of the services they provide. If the client engages any recommended professional, and a dispute arises related to the engagement, the client should seek recourse exclusively from and against the engaged professional. The preceding sentence shall not limit or waive any applicable rights under federal or state law, including securities laws and fiduciary obligations that cannot be limited or waived. Client Obligations. In performing its services, Halpern 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. Clients are responsible to promptly notify Halpern Financial if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Halpern Financial’s previous recommendations and/or services. Portfolio Activity. As part of its investment advisory services, Halpern Financial will review client portfolios on an ongoing basis to determine if any trades are necessary based upon various factors, including but not limited to investment performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods of time when Halpern Financial determines that trades within a client’s portfolio are not prudent. Clients nonetheless remain subject to the fees described in Item 5 during periods of portfolio trading inactivity. eMoney Advisor Platform. Halpern Financial may provide its clients with access to an online platform hosted by “eMoney Advisor” (“eMoney”). The eMoney platform allows a client to view their complete asset allocation, including those assets that Halpern Financial does not manage (the “Excluded Assets”). Unless agreed to otherwise, the client and/or his/her/its other advisors that maintain trading authority, and not Halpern Financial, shall be exclusively responsible for the investment performance of the Excluded Assets. Unless

also agreed to otherwise, Halpern Financial does not provide investment management, monitoring or implementation services for the Excluded Assets. If the Halpern Financial is asked to make a recommendation as to any Excluded Assets, the client is under absolutely no obligation to accept the recommendation, and Halpern Financial shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. The client can engage Halpern Financial to provide investment management services for the Excluded Assets pursuant to the terms and conditions of the Investment Advisory Agreement between Halpern Financial and the client.. The eMoney platform also provides access to other financial planning-related information that should not be construed as services, advice, or recommendations provided by Halpern Financial. Halpern Financial shall not be held responsible for any adverse results a client may experience by engaging in financial planning or other functions available on the eMoney platform without Halpern Financial’s assistance or oversight. Use of Mutual Funds and ETFs. Halpern Financial utilizes mutual funds and exchange traded funds for its client portfolios. In addition to Halpern Financial’s investment advisory fee described below, and transaction and/or custodial fees discussed below, 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). Custodian Charges-Additional Fees. As discussed below at Items 5 and 12 below, when requested to recommend a broker-dealer/custodian for client accounts, Registrant generally recommends that Fidelity serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Fidelity charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian. While certain custodians, including Fidelity, generally (with the potential exception for large orders) do not currently charge fees on individual equity transactions (including ETFs), others do. Although Registrant is not a frequent trader, its primary investment vehicles for client accounts are ETFs and mutual funds. Please Note: there can be no assurance that Fidelity will not change their transaction fee pricing in the future. Disclosure Statement. A copy of Halpern Financial’s written disclosure statement as set forth on Part 2 of Form ADV and Form CRS (Client Relationship Summary) shall be provided to each client before, or contemporaneously with, the execution of the applicable form of client agreement. Retirement Plan Rollovers – No Obligation / 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). As a fiduciary, Halpern Financial will review the overall implications of transferring an inactive retirement plan to an IRA under Halpern Financial’s management. The evaluation criteria covers access to advice, investments and a comparison of costs including investment, administrative and advisory fee costs. A client has the choice of whether or not to accept Halpern Financial’s recommendation. If Halpern Financial recommends that a client roll over their retirement plan assets into an account to be managed by Halpern Financial, such a recommendation creates a conflict of interest if Halpern Financial will earn a new (or increase its current) advisory fee as a result of the rollover. Whether Halpern Financial provides a recommendation as to whether a client should engage in a rollover or not, Halpern 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 Halpern Financial. Halpern Financial’s Chief Compliance Officer, Melissa Sotudeh, remains available to address any questions about the conflict of interest presented by such a rollover recommendation. Cash Positions. Halpern Financial continues to treat cash as an asset class. As a matter of general policy and practice, Halpern Financial does not include excessive balances of cash or cash equivalents, which may be designated as cash reserves in the calculation of client advisory fees. Individual cash reserves will be determined on a client-by-client basis and will vary from time to time based upon a particular client's needs. 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), Halpern 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, Halpern 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, Halpern Financial designates a higher yielding money market fund available on the custodian’s platform as the ‘core cash’ position for all cash within the account. Trade Error Policy. Halpern Financial shall reimburse accounts for losses resulting from Halpern Financial’s trade errors, however, if errors result in market gains, the net gains will be sent to a registered charity. The gains and losses are reconciled within Halpern Financial’s custodial firm account. Margin / Securities Based Loans. A client who has a need to borrow money could determine to do so by using:
• Pledged Assets Loan- In consideration for a lender (i.e., a bank, etc.) to make a loan to the client, the client pledges its 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, Halpern Financial does not recommend such borrowing unless it is for specific short-term purposes (i.e. a bridge loan to purchase a new residence). Halpern 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 a pledged assets loan, the following economic benefits would inure to Halpern Financial:  by taking the loan rather than liquidating assets in the client’s account, Halpern Financial continues to earn a fee on such pledged account assets; and  if the client invests any portion of the loan proceeds in an account to be managed by Halpern Financial, Halpern Financial will receive an advisory fee on the invested amount. Please Note: The Client must accept the above risks and potential corresponding consequences associated with the use of margin or a pledged assets loans. Cybersecurity Risk. The information technology systems and networks that Halpern Financial and its third-party service providers use to provide services to Halpern 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 Halpern Financial’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Halpern 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 Halpern 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 Halpern 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. C. Halpern Financial shall provide investment advisory services specific to the needs of each client. Before providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, Halpern Financial shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on Halpern Financial’s services. D. Halpern Financial does not participate in a wrap fee program. E. As of December 31, 2022, Halpern Financial had $828,828,344 in assets under management on a discretionary basis.