Since September 2000, CRA Financial has been in business as a comprehensive wealth management firm focused on fee-based asset management built on a foundation of solid financial planning. CRA is committed to providing value-added, wealth-enhancing services to its clients in a cost-effective manner that remains consistent with its philosophy that putting clients’ best interest first is CRA’s first priority. CRA provides financial planning, consulting, and investment management services. CRA’s principal owners are Thomas E. Reynolds, Matthew J. Reynolds, and Robert T. Martin. As of December 31, 2023, CRA had $1,200,689,624 of assets under management, $1,026,017,478 of which was managed on a discretionary basis and $174,672,146 of which was managed on a non- discretionary basis. Prior to engaging CRA to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with CRA setting forth the terms and conditions under which CRA renders its services (collectively the “Agreement”). This Disclosure Brochure describes the business of CRA. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of CRA’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on CRA’s behalf and is subject to CRA’s supervision or control. Financial Planning and Consulting Services Please Note: All tax preparation services are provided by an affiliated third party, not subject to CRA’s supervision and oversight. If the client engages any affiliated tax preparer, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged tax preparer, and not CRA, shall be responsible for the quality and competency of the tax preparation services provided. To the extent requested by the client, CRA will generally provide financial planning and related consulting services regarding matters such as tax and estate planning, insurance, etc. CRA’s planning fees are disclosed at Item 5 below. CRA may determine to provide such planning and consulting services inclusive of its investment management fee set forth at Item 5 below (exceptions will occur based upon assets under management, special projects, extraordinary services, stand-alone planning engagements, etc. for which CRA may charge a separate or additional fee). Please Note: CRA believes that it is important for the client to address financial planning issues on an ongoing basis. If CRA includes planning as part of its investment management fee as set forth at Item 5 below, CRA’s investment management fee, will remain the same regardless of whether or not the client determines to address financial planning issues with CRA. Please Also Note: CRA does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as same. Accordingly, CRA does not prepare legal documents, prepare tax returns, or sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for non-investment implementation purpose (i.e. attorneys, accountants, insurance, etc.), including our affiliated accounting firm, Capaldi, Reynolds & Pelosi (“CPA”) for tax preparation and accounting-related services. If a client determines to engage CPA, he/she does so per the terms and conditions of a separate written agreement between CPA and the client, to which CRA is not a party. There is no fee-sharing arrangement between the CPA and CRA. The recommendation by CRA that a client engage CPA for tax preparation and/or accounting-related services, presents a conflict of interest because CRA’s affiliate will derive additional compensation from such engagement. No client or prospective client is obligated to engage CPA. Clients are reminded that they may engage other, non-affiliated, providers. CRA will work with the tax professional of the client’s choosing. Investment Management Services Clients can engage CRA to manage all or a portion of their assets on a discretionary or non-discretionary basis. General CRA primarily allocates clients’ investment management assets among Independent Managers (as defined below), mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, real estate investment trusts (“REITs”), and/or options as well as the securities components of variable annuities in accordance with the investment objectives of the client. Where appropriate, CRA also provides advice about any type of investment held in clients' portfolios. Where appropriate, CRA also renders non-discretionary investment management services to clients relative to variable annuity products that they may own, their individual employer-sponsored retirement plans, and/or 529 plans or other products. In so doing, CRA either directs or recommends the allocation of client assets among the various investment options that are available with the product. Client assets are maintained at the specific insurance company or custodian designated by the product. CRA tailors its advisory services to the individual needs of clients. CRA consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon and other factors that may impact the clients’ investment needs. CRA ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify CRA if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon CRA’s management services. Clients may impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their assets be invested in socially responsible funds) if, in CRA’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Use of Independent Managers Independent Managers. CRA may allocate a portion of the client’s investment assets among unaffiliated independent investment managers in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager[s] shall have day-to-day responsibility for the active discretionary management of the allocated assets, including, to the extent applicable, proxy voting responsibility. CRA shall continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors that CRA shall consider in recommending Independent Manager[s] include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. Certain Independent Managers may maintain billing practices which differ from those of CRA. In such instances, CRA may alter its corresponding billing practices to accommodate those of the Independent Managers. In addition, clients are advised that certain Independent Managers may impose minimum account size and/or minimum asset level requirements. Please Note. The investment management fee charged by the Independent Manager[s] is separate from, and in addition to, CRA’s investment advisory fee disclosed at Item 5 below. ANY QUESTIONS: CRA’s Chief Compliance Officer, Donna Savastani, remains available to address any questions that a client or prospective client may have regarding the allocation of account assets to an Independent Manager(s), including the specific additional fee to be charged by such Independent Manager(s). Retirement Plan Consulting Services CRA provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized, and includes any or all of the following services:
• Plan Design and Strategy
• Plan Review and Evaluation
• Executive Planning & Benefits
• Investment Selection
• Plan Fee and Cost Analysis
• Plan Committee Consultation
• Fiduciary and Compliance
• Participant Education As disclosed in the Advisory Agreement, certain of the foregoing services are provided by CRA as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of CRA’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. Miscellaneous Disclosures Retirement Plan 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 CRA recommends that a client roll over their retirement plan assets into an account to be managed by CRA, such a recommendation creates a conflict of interest if CRA will earn new (or increase its current) compensation as a result of the rollover. If CRA 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), CRA 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 CRA, whether it is from an employer’s plan or an existing IRA. CRA’s Chief Compliance Officer, Donna Savastani, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. eMoney. CRA 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 CRA does not manage (the “Excluded Assets”). CRA does not provide investment management, monitoring, or implementation services for the Excluded Assets. Unless otherwise specifically agreed to, in writing, CRA’s service relative to the Excluded Assets is limited to reporting only. Therefore, CRA shall not be responsible for the investment performance of the Excluded Assets. Rather, the client and/or their advisor(s) that maintain management authority for the Excluded Assets, and not CRA, shall be exclusively responsible for such investment performance. Without limiting the above, CRA shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. The client may choose to engage CRA to manage some or all of the Excluded Assets pursuant to the terms and conditions of an Investment Advisory Agreement between CRA and the client. The eMoney platform also provides access to other types of information and applications including financial planning concepts and functionality, which should not, in any manner whatsoever, be construed as services, advice, or recommendations provided by CRA. Finally, CRA shall not be held responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the eMoney platform without CRA’s assistance or oversight. Cash Management Accounts. Clients who seek to maintain substantial (in CRA’s determination) ongoing cash balances can request that CRA open a separate account for cash management services (the “Account”). The Account will invest in short-term fixed income instruments only (i.e., money market funds, Certificates of Deposit, Ultra-short term bond funds, US Treasury bills, etc.). Thus, the Account will not participate in equity market advances. The Account will not be considered part of the client’s overall asset allocation for Client Profile/investment objective purposes. CRA’s annual fee for cash management services shall generally range from 0% to 1%, depending upon the amount of Account assets per a separate Fee Schedule Addendum to the Investment Advisory Agreement. Please Note: Cash Positions. CRA continues to treat cash as an asset class. As such, unless determined to the contrary by CRA, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating CRA’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), CRA 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, CRA’s advisory fee could exceed the interest paid by the client’s money market fund. ANY QUESTIONS: CRA’s Chief Compliance Officer, Donna Savastani, remains available to address any questions that a client or prospective client may have regarding the above fee billing practice. Custodian Charges - Additional Fees As discussed at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, CRA generally recommends that Fidelity or Schwab serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Fidelity and Schwab 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 and Schwab, generally (with the potential exception for large orders) do not currently charge fees on individual equity transactions (including ETFs), others do. Please Note: there can be no assurance that Fidelity and/or Schwab will not change their transaction fee pricing in the future. Please Also Note: Fidelity and Schwab may also assess fees to clients who elect to receive trade confirmations and account statements by regular mail rather than electronically. Tradeaways: When beneficial to the client, individual fixed‐income and/or equity transactions may be effected through broker‐dealers with whom CRA and/or the client have entered into arrangements for prime brokerage clearing services, including effecting certain client transactions through other SEC registered and FINRA member broker‐dealers (in which event, the client generally will incur the transaction fee charged by the executing broker‐dealer). The above fees/charges are in addition to CRA’s investment advisory fee at Item 5 below. CRA does not receive any portion of these fees/charges. ANY QUESTIONS: CRA’s Chief Compliance Officer, Donna Savastani, remains available to address any questions that a client or prospective client may have regarding the above. Cybersecurity Risk. The information technology systems and networks that CRA and its third-party service

providers use to provide services to CRA’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in CRA’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and CRA 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 CRA 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 CRA 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. Interval Funds/Risks and Limitations: Where appropriate, CRA may utilize interval funds. An interval fund is a non-traditional type of closed-end mutual fund that periodically offers to buy back a percentage of outstanding shares from shareholders. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender shares when or in the amount desired. There can also be situations where an interval fund has a limited amount of capacity to repurchase shares and may not be able to fulfill all purchase orders. In addition, the eventual sale price for the interval fund could be less than the interval fund value on the date that the sale was requested. While an internal fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors may sell their shares at any given time or in the desired amount. As interval funds can expose investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment. Typically, the interval funds are not listed on any securities exchange and are not publicly traded. Thus, there is no secondary market for the fund’s shares. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client’s investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some, or all, of the investment. There can be no assurance that an interval fund investment will prove profitable or successful. In light of these enhanced risks, a client may separately direct CRA, in writing, not to employ any or all such strategies for the client’s account. Please Note: Inverse/Enhanced Market Strategies. CRA may utilize long and short mutual funds and/or exchange traded funds that are designed to perform in either an: (1) inverse relationship to certain market indices (at a rate of 1 or more times the inverse [opposite] result of the corresponding index) as an investment strategy and/or for the purpose of hedging against downside market risk; and (2) enhanced relationship to certain market indices (at a rate of 1 or more times the actual result of the corresponding index) as an investment strategy and/or for the purpose of increasing gains in an advancing market. There can be no assurance that any such strategy will prove profitable or successful. In light of these enhanced risks/rewards, a client may separately direct CRA in writing, not to employ any or all such strategies for his/her/their/its accounts. ANY QUESTIONS: CRA’s Chief Compliance Officer, Donna Savastani, remains available to address any questions that a client or prospective client may have regarding the above. ESG: We don’t have or recommend a strategy: Please Note: Socially Responsible (ESG) 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 meet 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. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by CRA), there can be no assurance that investment in ESG securities or funds will be profitable, or prove successful. CRA does not maintain or advocate an ESG investment strategy, but will seek to employ ESG if directed by a client to do so. If implemented, CRA shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate. WE DON’T RECOMMEND Cryptocurrency: For clients who want exposure to cryptocurrencies, including Bitcoin, CRA, will advise the client to consider a potential investment in corresponding exchange traded securities, or an allocation to separate account managers and/or private funds that provide cryptocurrency exposure. Cryptocurrency is a digital currency that can be used to buy goods and services, but uses an online ledger with strong cryptography (i.e., a method of protecting information and communications through the use of codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated and their price is determined by the supply and demand of their market. Because cryptocurrency is currently considered to be a speculative investment, CRA will not exercise discretionary authority to purchase a cryptocurrency investment for client accounts. Rather, a client must expressly authorize the purchase of the cryptocurrency investment. Please Note: CRA does not recommend or advocate the purchase of, or investment in, cryptocurrencies. CRA considers such an investment to be speculative. Please Also Note: Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility and complete loss of principal. Please Note - Use of Mutual and Exchange Traded Funds: CRA utilizes mutual funds and exchange traded funds for its client portfolios. In addition to CRA’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). Cross Transactions. In limited circumstances, when determined to be in the best interest of its clients, CRA may engage in a cross-transaction pursuant to which CRA may effect transactions between two of its managed client accounts (i.e., arranging for the clients’ securities trades by “crossing” these trades when CRA believes that such transactions [generally, thinly traded bonds] are beneficial to its clients). This may present a conflict of interest. For all such transactions, neither CRA nor any affiliate will be acting as a broker. CRA will not receive any commission or transaction-based compensation, although CRA has an interest in the price at which the cross trades are conducted since CRA’s asset-based fees will be negatively impacted by lower bond values. These transactions will be generally effected through Fidelity or Schwab, the account custodians. The client may revoke CRA’s cross-transaction authority at any time upon written notice to CRA. ANY QUESTIONS: Our Chief Compliance Officer, Donna Savastani, remains available to address any questions that a client or prospective client may have regarding cross transactions. Please Note: Non-Discretionary Service Limitations. Clients that determine to engage CRA on a non- discretionary investment advisory basis must be willing to accept that CRA cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event that CRA would like to make a transaction for a client’s account, and client is unavailable, CRA will be unable to effect the account transaction (as it would for its discretionary clients) without first obtaining the client’s consent. Pontera Platform. CRA uses an investment platform made available by Pontera Solutions, Inc. (“Pontera”), a third-party online platform, to assist with management of clients’ “held-away” accounts, including 401(k)s, 403(b)s, annuities, and 529 education savings plans. The Pontera platform permits advisers to manage held-away assets without having to reflect that it has custody of such assets on Part 1 of Form ADV. The advisory fee charged by CRA for the management of held-away assets is established in the client’s Investment Advisory Agreement. Pontera charges CRA an annual fee based upon the percentage of assets managed in the held-away accounts. Other than CRA’s advisory fee, clients do not pay any additional fee to Pontera or to CRA in connection with the use of Pontera platform. 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 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, CRA does not recommend such borrowing unless it is for specific short-term purposes (i.e. a bridge loan to purchase a new residence). CRA 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 CRA:
• by taking the loan rather than liquidating assets in the client’s account, CRA continues to earn a fee on such Account assets, net of debit; and
• if the client invests any portion of the loan proceeds in an account to be managed by CRA, CRA 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 loan. Portfolio Activity. CRA has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, CRA 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, mutual fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when CRA determines that changes to a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by CRA will be profitable or equal any specific performance level(s). Other Assets. A client may:
• hold securities that were purchased at the request of the client or acquired prior to the client’s engagement of CRA. Generally, with potential exceptions, CRA does not/would not recommend nor follow such securities, and absent mitigating tax consequences or client direction to the contrary, would prefer to liquidate such securities. Please Note: If/when liquidated, it should not be assumed that the replacement securities purchased by CRA will outperform the liquidated positions. To the contrary, different types of investments involve varying degrees of risk, and there can be no assurance that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by CRA) will be profitable or equal any specific performance level(s). In addition, there may be other securities and/or accounts owned by the client for which CRA does not maintain custodian access and/or trading authority; and,
• hold other securities and/or own accounts for which CRA does not maintain custodian access and/or trading authority. Corresponding Services/Fees: When agreed to by CRA, CRA shall: (1) remain available to discuss these securities/accounts on an ongoing basis at the request of the client; (2) monitor these securities/accounts on a regular basis, including, where applicable, rebalancing with client consent;(3) shall generally consider these securities as part of the client’s overall asset allocation; and, (4) report on such securities/accounts as part of regular reports that may be provided by CRA; and, (5) include the market value of all such securities for purposes of calculating advisory fee. ANY QUESTIONS: CRA’s Chief Compliance Officer, Donna Savastani, remains available to address any questions regarding the above. Please Note: 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 CRA) will be profitable or equal any specific performance level(s). Client Obligations. In performing its services, CRA shall not be required to verify any information received from the client or from the client’s other designated professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify CRA if there is ever any change in their financial situation or investment objectives for the purpose of reviewing/evaluating/revising CRA’s previous recommendations and/or services. Disclosure Brochure. A copy of CRA’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 CRA.