IA Registration Status – Registered with the SEC since July 20031 Principal Owner – Brenda S. Friedlander Organization Status – Sole Proprietorship ADVISORY SERVICES Investment Management Services Our investment management services include, among others, financial goal setting, risk assessment, strategic asset allocation and the selection and management of securities and investments. We offer investment management services to individuals and their trusts and require an investment portfolio minimum of $500,000. We use an asset allocation investment strategy that determines how much of a client’s portfolio is invested in various asset classes. We follow an investment process that is ongoing and includes the following:
• A thorough assessment of client needs. Through data gathering meetings and questionnaires we determine: client financial needs, investment objectives, risk tolerance, investment time horizon, liquidity requirements and tax situation.
• Careful planning of each portfolio. Once we have established client objectives we plan an investment portfolio designed to meet client-specific goals with a level of risk appropriate to the client. We will evaluate the tax consequences and fees of our recommendations.
• Accurate and timely implementation of the investment plan. Implementation of each client’s investment plan includes the set-up of custodial accounts, transferring accounts, processing trades and a diligent follow-up process to confirm transaction accuracy.
• Ongoing review and servicing of client portfolios. Once the investments are made we continue to track and monitor client investment accounts. We review each client’s asset allocation and will re-balance the client’s portfolio when appropriate. We continually monitor the performance of investment assets and evaluate the effectiveness of the assets at achieving client goals and objectives.
• An annual review. We provide clients with an annual review that covers their investment performance as well as financial planning and tax issues as they apply to the client’s individual situation. A client may make additions to and withdrawals from their investment account at any time, subject to the Firm’s right to terminate an account if the amount of assets drops below our account size minimum. Clients may withdraw account assets with notice to the Firm, subject to the usual and customary securities settlement procedures. However, we design client portfolios as long-term investments and caution our clients that asset withdrawals may impair the achievement of the client’s investment objectives. 1 “Registration” means only that the Firm meets the minimum requirements for registration as an investment advisor and does not imply a certain level of skill or training or that the State of California or any other regulator guarantees the quality of our services or recommends them. Additions to an account may be in cash or securities provided that we may decline to accept particular securities into a client’s account or may recommend that the security be liquidated if it is inconsistent with the Firm’s investment strategy or the client’s investment objectives. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax ramifications. Financial Planning and Financial Consulting Services Spectrum provides financial planning services as a part of its investment management services upon client request. Spectrum Financial’s financial planning services may include a financial review and analysis of some or all of the following areas:
• Determining Financial Goals And Objectives
• Asset Allocation Review
• Retirement Plan Analysis
• Employee Stock Option/Restricted Share Analysis
• Current Portfolio Review
• Education Funding Analysis and Planning
• Cost Basis Audit of Current Investments
• Cash Flow Management Review
• Review of Insurance Needs
• Real Estate Analysis
• Mortgage and Refinance Evaluation

• Estate Plan Review or Development
• Charitable Planning
• Opinion on Current Investment Strategy/Advisors
• Other Financial or Investment Analysis Tax Analysis, Planning and Preparation Spectrum’s principal, Brenda S. Friedlander, has a degree in accounting and is an Enrolled Agent (“EA”), a federally authorized tax practitioner, who has technical expertise in the field of taxation and is qualified to represent taxpayers before all administrative levels of the Internal Revenue Service for audits, collections and appeals. Thus, Spectrum is able to provide coordinated tax-planning services to its investment management clients as an integrated part of its investment management services. Typically, tax services are provided to investment management clients as part of an integrated delivery of planning, management and tax services, but subject to an annual separate written agreement. On occasion, the Firm may accept clients that engage the Firm solely to provide tax services, also pursuant to a separate tax agreement. For tax – only clients, Spectrum may recommend the Firm be retained as their investment advisor; however such clients are under no obligation to do so. Investment management clients are not required to use our tax preparation services. If investment clients choose to prepare their own tax returns or work with a separate accountant or tax preparer, Spectrum will provide them with the portfolio tax information necessary to complete the returns. General Notices In performing its services, Spectrum is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is authorized to rely on such information as provided. Clients must promptly notify us of any change in their financial situation or investment objectives that would necessitate a review or revision by our advisors of the client’s portfolio and/or financial plan. Occasionally, Spectrum agrees to provide management services on a non-discretionary basis regarding client-designated securities within a client portfolio. Such clients are under no obligation to act upon any of the recommendations made by Spectrum with respect to such securities and the client retains absolute discretion over all such investments and are free to accept or reject any of the Firm’s recommendations. Fiduciary Status Under ERISA To the extent any client is a retirement plan or other employee benefit plan subject to the Employee Retirement Income Security Act of 1974, as amended ("ERISA"), and depending upon the investment management services provided by Spectrum, the Firm may be considered a “fiduciary” under ERISA. The Firm does not sponsor nor does it provide portfolio management services to wrap fee programs offered by broker-dealers or others. ASSETS UNDER MANAGEMENT AS OF DECEMBER 31, 2023 Discretionary Assets – $222,643,352 Non-discretionary Assets – $5,282,639 TERMINATION OF INVESTMENT MANAGEMENT RELATIONSHIP Clients or the Firm may terminate the relationship upon notice to other party. The Firm does not assess any fees related to termination but will be entitled to all management fees earned up to the date of termination. Any unearned prepaid management fees will be refunded to the client. Any unearned prepaid tax fees will be refunded to the client. Any unpaid tax fees will be billed to the client for immediate payment or deducted from the client’s retainer, if any. If a copy of this Form ADV Part 2A disclosure statement was not delivered to the client at least 48 hours prior to a client entering into a written advisory contract with Advisor, then the client has the right to terminate the contract without penalty within five (5) business days after entering into the contract. For purposes of this provision, a contract is considered entered into when all parties to the contract have signed the contract. If the client terminates the contract on this basis, all fees paid by the client will be refunded. Any transaction costs imposed by the executing broker or custodian for establishing the custodial account or for trades occurring during those five days are non-refundable.