A. Warner Financial, Inc. (“Warner Financial”) is an investment advisor registered with the United States Securities and Exchange Commission (“SEC”). Our company is a corporation formed under the laws of the State of Delaware and located in Bethesda, Maryland and has been registered as an investment adviser since April, 2005
• The firm is owned by Barbara Warner and Christopher Warner.
• We provide fee-based investment advisory services through Warner Financial. The nature and extent of the specific services provided to clients, including you, will always depend on each client’s financial status, objectives and needs, time horizons, concerns, expectations and risk tolerance. B. General Description of Primary Advisory Services The following are brief descriptions of Warner Financial’s primary services. A detailed description of our services is provided in Item 5 – Fees and Compensation so that clients and prospective clients can review the services and fees. Financial Planning: To the extent requested to do so, we offer to provide financial planning and related consulting services to clients, which services are generally offered in connection with our asset management services. Financial planning services do not involve the active management of client accounts, but instead focus on a client’s overall financial situation. Financial planning can be described as helping individuals determine and set their long-term financial goals, through investments, tax planning, asset allocation, risk management, retirement planning, and other areas. The role of a financial planner is to find ways to help the client understand his/her overall financial situation and help the client set financial objectives. Asset Management Services: This is the primary service we offer and most clients receiving this Disclosure Brochure will be retaining us for Asset Management Services. The service involves providing clients with continuous and on-going supervision over investment accounts. This means that we will continuously monitor a client’s account and make trades in client accounts when necessary. The client can determine to engage to provide discretionary and/or non-discretionary investment advisory services on a fee-only basis. Unless the client and Warner Financial agree to a fixed-fee arrangement, Warner Financial’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under Warner Financial’s management. Prior to engaging to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement with Warner 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. Warner Financial provides 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 objectives. Thereafter, Warner Financial will allocate and/or recommend that the client allocate investment assets consistent with the designated investment objectives. Once allocated, Warner Financial provides ongoing monitoring and review of account performance and asset allocation as compared to client investment objectives. When providing Asset Management Services, we typically construct each client’s account holdings using no-load mutual funds and ETFs to build diversified portfolios. We do not typically attempt to time the market but we may increase cash holdings modestly as deemed appropriate, based on your risk tolerance and our expectations of market behavior. In addition to our investment advisory fees 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). 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 we recommend that a client roll over their retirement plan assets into an account to be managed by us, such a recommendation creates a conflict of interest if we will earn new (or increase our current) compensation as a result of the rollover. If Warner 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), Warner 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 us, whether it is from an employer’s plan or an existing IRA . Our Chief Compliance Officer, Barbara Warner, 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. Limitations of Financial Planning and Non-Investment Consulting/Implementation Services: To the extent requested, Warner Financial will generally provide limited planning and consulting services regarding non-investment related matters, such as tax and estate planning, insurance, etc. The services will be provided inclusive of its advisory fee set forth at Item 5 below. Exceptions to the stated advisory fee may occur based upon assets under management, advanced planning needs, preparation of a comprehensive financial plan, special projects, etc. for which Warner Financial can charge a mutually agreeable additional fee and/or enter into stand-alone financial planning engagement. Warner Financial believes that it is important for the client to address financial planning issues on an ongoing basis. Warner’s advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to address financial planning issues with Warner Financial. Warner Financial does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as same. Accordingly, Warner Financial does not prepare estate planning or any other type of 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 certain non-investment implementation purposes (i.e. attorneys, accountants, insurance agents, etc.). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of our recommendations. Neither Warner Financial, nor its investment adviser representatives, assist clients with the implementation of any financial plan, unless they have agreed to do so in writing. In addition, Warner Financial does not monitor a client’s financial plan, and it is the client’s responsibility to revisit the financial plan with Warner Financial, if desired. If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. If, and when Warner Financial is involved in a specific matter (i.e. estate planning, insurance, accounting-related engagement, etc.), it is the engaged licensed professionals (i.e. attorney, accountant, insurance agent, etc.), and not Warner Financial, that is responsible for the quality and competency of the services provided. Our Chief Compliance Officer, Barbara Warner, remains available to address any questions that a client or prospective client may have regarding the above conflict of interest. Cash Positions. Warner Financial continues to treat cash as an asset class. As such, unless determined to the contrary by Warner Financial, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Warner 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), Warner 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, Warner Financial’s advisory fee could exceed the interest paid by the client’s money market fund. Charles Schwab & Co., Inc.: As discussed below at Item 12, unless the client directs otherwise, Warner Financial shall generally recommend that Charles Schwab & Co., Inc. (“Schwab”) serve as the broker- dealer/custodian for client investment management assets. Broker-dealers such as 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 Schwab, do not currently charge fees on individual equity transactions, others do). Broker-dealers such as Schwab charge transaction fees for effecting mutual fund transactions. In addition to Warner Financial’s investment management fee as described at Item 5 below, and transaction fees, 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). However, Schwab (as do its primary competitors that provide similar pricing arrangements) require that cash proceeds to be automatically swept into a Schwab proprietary or affiliated money market mutual funds or cash sweeps accounts, which proprietary/affiliated Schwab funds/accounts do not provide the highest return available. Cybersecurity Risk. The information technology systems and networks that Warner Financial and its third- party service providers use to provide

services to Warner 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 Warner Financial’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Warner 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 Warner Financial has established its processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that Warner 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. 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, Warner Financial does not recommend such borrowing unless it is for specific short-term purposes (i.e. a bridge loan to purchase a new residence). Warner Financial does not recommend such borrowing for investment purposes (i.e. to invest borrowed funds in the market). Regardless, if the client were to decide to utilize margin or a pledged assets loan, Warner Financial would receive an economic benefit because we would continue to earn a fee on the pledged assets. Please Note: The Client must accept the above risks and potential corresponding consequences associated with the use of margin or a pledged assets loan. 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. 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 Warner Financial), there can be no assurance that investment in ESG securities or funds will be profitable, or prove successful. Warner Financial 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, Warner Financial shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account portfolio manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate Bitcoin, Cryptocurrency, and Digital Assets: For clients who want exposure to cryptocurrencies and digital assets, including Bitcoin, Warner Financial will advise the client to consider a potential investment in corresponding exchange traded securities. Cryptocurrencies are digital assets that can be used to buy goods and services and use 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, Warner Financial 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: Warner Financial does not recommend or advocate the purchase of, or investment in, cryptocurrencies. Warner Financial considers such an investment to be speculative. 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. 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, Warner Financial may purchase a higher yielding money market fund available on the custodian’s platform with cash proceeds or deposits, unless Warner Financial reasonably anticipates that it will use the cash proceeds in the near future to purchase additional investments for the client’s account or make distributions to the client. 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, the size of the cash balance, 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. Non-Discretionary Service Limitations: Clients that determine to engage Warner Financial on a non- discretionary investment advisory basis acknowledge that Warner Financial cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event that Warner Financial would like to make a transaction for a client's account (including in the event of an individual holding or general market correction), and the client is unavailable, Warner Financial will be unable to effect the account transaction(s) (as it would for its discretionary clients) without first obtaining the client’s consent. Client Obligations: In performing its services, Warner 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, each client is advised that it remains their responsibility to promptly notify Warner Financial if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Warner Financial’s previous recommendations and/or services. Disclosure Statement: A copy of Warner Financial’s written Brochure as set forth on Part 2 of Form ADV, along with Form CRS, shall be provided to each client prior to, or contemporaneously with, the execution of the applicable form of agreement between Warner Financial and the client. Portfolio Activity: Warner Financial has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Warner 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, 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 Warner Financial determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below at Item 8, there can be no assurance that investment decisions made by Warner Financial will be profitable or equal any specific performance level(s). Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Trustee-Directed Plans: Warner Financial may be engaged to provide discretionary investment advisory services to ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the investment objective designated by the Plan trustees. In such engagements, Warner Financial will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). Warner Financial will generally provide services on an “assets under management” fee basis per the terms and conditions of an Investment Advisory Agreement between the Plan and the Firm. Participant-Directed Retirement Plans: Warner Financial may also provide investment advisory and consulting services to participant directed retirement plans per the terms and conditions of a Retirement Plan Services Agreement between Warner Financial and the plan. For such engagements, Warner Financial shall assist the Plan sponsor with employee enrollment and education, and with the selection of an investment platform from which Plan participants shall make their respective investment choices. . C. Tailor Advisory Services to Individual Needs of Clients Our services are always provided based on the individual needs of the individual client. You are able to impose restrictions on your accounts including specific investment selections and sectors. We work with you on a one-on-one basis through interviews and meetings to determine your investment objectives and suitability information. If you transfer a portfolio to us that has existing assets and tax consequences if those are sold, we will take that into account in the construction of your portfolio. D. Warner Financial does not participate in any wrap programs. E. Client Assets Managed by Warner Financial The amount of clients’ assets managed by our firm totaled $627,513,588.as of December 31, 2023. $613,290,627 is managed on a discretionary basis and $$14,222,961 is managed on a non-discretionary basis (please refer to Item 16 – Investment Discretion for more details regarding discretionary and non- discretionary services).