Francis Financial, Inc. (“Francis Financial” or “us” or “we”) is an SEC-registered investment adviser with its principal place of business located in New York. Francis Financial began conducting business in 2003. SEC registration does not imply a certain level of skill or training. Stacy A. Francis, President, is the firm’s principal shareholder (i.e., those individuals and/or entities controlling 25% or more of this company). Francis Financial offers the following advisory services to our clients: INVESTMENT SUPERVISORY SERVICES INDIVIDUAL PORTFOLIO MANAGEMENT Our firm provides continuous advice to our clients regarding the investment of client funds based on each client’s individual needs. Through personal discussions in which goals and objectives based on a client’s particular circumstances are established, we develop a client’s personal investment policy statement and create and manage a portfolio based on that policy. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client’s prior investment history, as well as family composition and background. Selection of Other Advisers or Managers We have discretion to choose individual third-party investment advisers, in addition to our full-time employees, to provide advice to our clients. Such third-party advisors, who may be independent contractors or consultants to our firm, will always act in the best interests of our client, and follow the policies and procedures of Francis Financial, including our Code of Ethics. Francis Financial will ensure that such advisers are properly licensed in connection with managing any accounts for our clients. Such advisers may also be dual registered with other unaffiliated Registered Investment Adviser firms. We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client’s stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Once the client’s portfolio has been established, we review the portfolio quarterly, and if necessary, rebalance the portfolio based on the client’s individual needs. Our investment recommendations are not limited to any specific investment type or product and will generally include advice regarding the following classes of securities:
• Exchange-listed securities
• Securities traded over-the-counter
• Foreign issuers
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Mutual fund shares
• United States governmental securities
• Options contracts on securities
• International debt securities
• Privately placed securities
• Other investments managed by third parties Because certain types of investments involve additional degrees of risk, they will only be implemented/recommended when consistent with the client’s stated investment objectives, tolerance for risk, liquidity needs, and suitability. In certain situations, and based upon a client’s stated investment objectives, we may recommend that they use third party discretionary independent managers for a portion (or all) of their assets. We may recommend investment managers who employ traditional and/or alternative investment strategies if they meet our criteria. To the extent that third party managers are used, the client will pay additional fees to such managers and may be asked to sign a separate investment management agreement with such managers. We also provide advice to our clients regarding their employee benefit plans, if requested. We may advise clients on their investment options within the plans; or we may advise clients regarding rolling over benefit plan assets to an IRA or another plan or redeeming their benefit plan assets for cash. Benefit plan assets are treated as assets under management, and we will charge our standard fees whether we are managing IRA accounts with discretion or providing non-discretionary advice to our clients on what investment options they should choose in their plans. Francis Financial may recommend an investor roll over plan assets to an IRA managed by Francis Financial. As a result, Francis Financial may earn an asset-based fee. Francis Financial could have an economic incentive to encourage an investor to roll plan assets into an IRA that Francis Financial will manage. However, such recommendations will be accompanied by appropriate and relevant disclosures regarding conflicts and duties, and will be made in accordance with our policies, which are designed to comply with applicable regulations. A minimum of $2,000,000 of assets under management is generally required for our investment supervisory services. This minimum may be negotiable under certain circumstances. Francis Financial may group certain related client accounts for the purposes of achieving the minimum account size. ROBO-ADVICE THROUGH SWIA Asset Management via Institutional Intelligent PortfoliosTM: For a group of Francis Financial’s clients, Francis Financial provides automated portfolio management services (“Robo-Advice”) through Institutional Intelligent PortfoliosTM, an automated, online investment management platform for use by independent investment advisors and sponsored by Schwab Wealth Investment Advisory, Inc. (the “Program” and “SWIA,” respectively). Through the Program, Francis Financial offers clients a range of investment strategies, each consisting of a portfolio of exchange traded funds (“ETFs”) and cash. The client’s portfolio is held in a brokerage account opened by the client with Charles Schwab & Co., Inc. (“CS&Co”). Francis Financial is independent of and not owned by, affiliated with, or sponsored or supervised by SWIA, CS&Co or their affiliates (together, “Schwab”). The Program is described in the Schwab Wealth Investment Advisory, Inc. Institutional Intelligent PortfoliosTM Disclosure Brochure (the “Program Disclosure Brochure”), which is delivered to clients by SWIA during the online enrollment process. Francis Financial, and not Schwab, is the client’s investment

adviser and primary point of contact with respect to the Program. We are solely responsible, and Schwab is not responsible, for determining the appropriateness of the Program for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis. Francis Financial has contracted with SWIA to provide us with the technology platform and related trading and account management services for the Program. This platform enables us to make the Program available to clients online and includes a system (the “System”) which includes an online questionnaire used to determine the client’s investment objectives and risk tolerance. Clients should note that the System will recommend a portfolio in response to the Client’s answers to the online questionnaire. The System also includes an automated investment engine through which we manage the client’s portfolio on an ongoing basis through automatic rebalancing. Clients do not pay fees to SWIA in connection with the Program, but we charge clients a fee for our services. Our fees are not set or supervised by Schwab. Clients that utilize the Program do not pay brokerage commissions to CS&Co as part of the Program. FINANCIAL PLANNING & DIVORCE FINANCIAL PLANNING We provide financial planning services, typically as part of our Investment Supervisory Service. Financial planning is a personalized evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information, and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service receive a written report which provides the client with a detailed financial plan designed to assist the client achieve his or her financial goals and objectives. In general, the financial plan can address any or all of the following areas:
• PERSONAL: We review family records, budgeting, personal liability, estate information and financial goals.
• TAX & CASH FLOW: We analyze the client’s income tax and spending and planning for past, current, and future years; then illustrate the impact of various investments on the client’s current income tax and future tax liability.
• INVESTMENTS: We analyze investment alternatives and their effect on the client’s portfolio.
• COLLEGE FUNDING: We analyze the client’s income and develop a strategy of saving and investing to plan for college expenses and loan repayments.
• INSURANCE: We review existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home, and automobile.
• RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals.
• DEATH & DISABILITY: We review the client’s cash needs at death, income needs of surviving dependents, estate planning and disability income.
• ESTATE: We assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid, and elder law. We do not draft legal documents as we are not attorneys. We gather required information through in-depth personal interviews. Information gathered includes the client’s current financial status, tax status, future goals, returns objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the client’s discretion. We also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. Typically, the financial plan is presented to the client within six months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. Financial Planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. All recommendations are of a generic nature but customized to each client’s situation. Stacy Francis and others in the firm have earned the designation of Certified Divorce Financial Analyst ®(CDFA). The role of a CDFA includes knowledge of tax law, asset distribution, and short- and long-term financial planning to achieve an equitable settlement. Francis Financial helps clients determine the short term and long term financial impact of any proposed divorce settlement. We will also provide valuable information on financial issues that are related to divorce, such as tax consequences, dividing pension plans, continued health care coverage, and stock option elections. PUBLICATION OF PERIODICALS We publish a monthly newsletter providing general information on various financial topics including, but not limited to, estate and retirement planning, and market trends. No specific investment recommendations are provided in this newsletter and the information provided does not purport to meet the objectives or needs of any individual. This newsletter is distributed free of charge to our advisory clients, potential clients, and other trusted colleagues. Our website offers a blog with articles written by our associates about a range of topics relevant to women’s financial well-being. SEMINARS, WORKSHOPS AND SPEAKING ENGAGEMENTS Occasionally we provide educational workshops and/or seminars upon request. We do not charge for such speaking engagements and if a third party compensates Francis Financial, we will donate any compensation to Savvy Ladies, a non-profit organization that provides free financial education to women. AMOUNT OF MANAGED ASSETS As of December 31, 2023, we were actively managing $453,558,428 of client assets on a discretionary basis plus $56,160,009 of client assets on a non-discretionary basis. The total assets under management were $509,718,437.