A. Description of the Advisory Firm Pathway Financial Advisers, LLC is a Limited Liability Company organized in the state of Indiana. The firm was effective in January of 2013, and the owners are Steven E Post, Joel Grimm and David R. Tracey.
B. Types of Advisory Services Pathway Financial Advisers, LLC (hereinafter “PFA”) offers the following services to advisory clients: Investment Supervisory Services PFA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. PFA creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client’s specific situation. Investment Supervisory Services include, but are not limited to, the following:
•Investment strategy•Personal investment policy
•Asset allocation•Asset selection
•Risk tolerance• Regular portfolio monitoring PFA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. PFA will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction.
Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client.
Qualified and Non-Qualified Plan Management Services PFA provides plan consulting services designed to assist the Plan Sponsor in meeting their fiduciary duties to administer the Plan in the best interest of the Plan’s participants and their beneficiaries. The services may include plan design, administrative support, oversight of the Plan’s service providers, investment monitoring support and/or participant services. PFA may be engaged as an ERISA Fiduciary with respect to investment management service and investment advice.
Selection of Other Advisers PFA may direct clients to third-party investment advisers. Before selecting other advisers for clients, PFA will verify that all recommended

advisers are properly licensed, notice filed, or exempt in the states where PFA is recommending the adviser to clients.
Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning, life insurance; tax concerns; retirement planning; college planning; and debt/credit planning.
These services are based on hourly fees and the final fee structure is documented in Exhibit II of the Financial Planning Agreement.
Services Limited to Specific Types of Investments PFA generally limits its investment advice and/or money management to mutual funds, equities, bonds, fixed income, debt securities, ETFs, REITs, insurance products including annuities, and government securities.PFA may use other securities as well to help diversify a portfolio when applicable.
C. Client Tailored Services and Client Imposed Restrictions PFA offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets.
Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent PFA from properly servicing the client account, or if the restrictions would require PFA to deviate from its standard suite of services, PFA reserves the right to end the relationship.
D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees.
PFA does not participate in any wrap fee programs.
E. Amounts Under Management PFA has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $383,925,555$0.00December 2023