HANC WEALTH MANAGEMENT, LLC

HUNGERFORD FINANCIAL, LLC FIRM BROCHURE (ADV PART 2A) MARCH 26, 2025 Hungerford Financial, LLC 2910 Lucerne Drive SE Grand Rapids, MI 49546 Phone: (616) 551-5452 Fax: (616) 949-7720 Email: Thomas@hungerfordfinancial.com Website: www.hungerfordfinancial.com This brochure provides information about the qualifications and business practices of Hungerford Financial, LLC. If you have any questions about the contents of this brochure, please contact Thomas Price at (616) 551-5452. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Hungerford Financial, LLC is a registered investment Advisor. Registration of an Investment Advisor does not imply any level of skill or training. The written communications of an Advisor provide you with information about which you determine to hire or retain an Advisor. Additional information about Hungerford Financial, LLC is available on the SEC’s website www.Advisorinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The Advisor’s CRD number is 249789.  2. MATERIAL CHANGES We have one material change to report since our last annual update which was on March 29, 2024. - - Item 5 – We have changed our fee schedule Retirement Plan Services. Please see Item 5 below for the new fee schedule. Item 7 – We now require a minimum annual fee for retirement plan services. Please see Item 7 below for our minimum requirements. We have no additional material changes to report. Hungerford Financial, LLC Page 2 ADV Part 2A – 3/26/2025  TABLE OF CONTENTS Item 2. Material Changes ..............................................................................................................2 Item 3. Table of Contents ..............................................................................................................3 Item 4. Advisory Business .............................................................................................................4 Item 5. Fees and Compensation ....................................................................................................6 Item 6. Performance-Based Fees and Side-By-Side Management ............................................9 Item 7. Types of Clients .................................................................................................................9 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss......................................9 Item 9. Disciplinary Information ................................................................................................11 Item 10. Other Financial Industry Activities and Affiliations .................................................13 Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading..........................................................................................................................................13 Item 12. Brokerage Practices ......................................................................................................14 Item 13. Review of Accounts .......................................................................................................15 Item 14. Client Referrals and Other Compensation .................................................................16 Item 15. Custody ..........................................................................................................................16 Item 16. Investment Discretion ...................................................................................................17 Item 17. Voting Client Securities ................................................................................................17 Item 18. Financial Information ...................................................................................................17 Hungerford Financial, LLC Page 3 ADV Part 2A – 3/26/2025  4. ADVISORY BUSINESS A. OWNERSHIP/ADVISORY HISTORY Hungerford Financial, LLC (“the Advisor”) was established as a Michigan Limited Liability Company in 2015. It became registered as a Michigan Investment Adviser in December 2015 and subsequently registered with the Securities and Exchange Commission in December 2018. The Advisor is owned by Hungerford Nichols, a CPA firm and Thomas J. Price (“Mr. Price”). Mr. Price is the firm’s managing member. B. ADVISORY SERVICES OFFERED The Advisor’s services include portfolio management services and the creation of financial plans for clients. The Advisor will meet with a client to evaluate the individual client’s investment needs, goals and objectives. After the evaluation, the Advisor may recommend one of the services described below. 1. FINANCIAL PLANNING The Advisor offers clients financial planning services to evaluate their financial situation, goals and risk tolerance. Through a series of personal interviews and the use of questionnaires the Advisor will collect pertinent data, identify goals, objectives, financial problems, potential solutions, prepare specific recommendations and implement recommendations. As a result of these actions, the Advisor’s advice may be provided on some or all of the following 13 Wealth Management Issues: 1) Investment Planning 2) Risk Management & Insurance Planning 3) Banking & Credit Management 4) Retirement Planning 5) Executive Compensation 6) Business Succession 7) Planning for Incapacity 8) Education & Family Support 9) Charitable Giving 10) Titling & Beneficiary Designations 11) Executor & Trustee Selection 12) Distribution of Estate 13) Tax Planning The Advisor may offer broad-based planning services, or the client may desire advice on certain planning components; the Advisor can tailor services as desired by the client. At the conclusion of the Financial Planning Service the Advisor will present the client with a written financial plan. Hungerford Financial, LLC Page 4 ADV Part 2A – 3/26/2025  2. PORTFOLIO MANAGEMENT The Advisor manages individualized portfolios for its clients. The Advisor works with each client to formulate an individualized portfolio based upon his/her objectives, time frame, risk parameters and other investment considerations. Please see Item 8 for additional information about the types of securities used and the Advisor’s investment strategies. The Advisor’s investment philosophy is to use principals of value, safety and quality to seek investment options globally. The Advisor places heavy emphasis on risk control, believing that avoiding losses allows appreciation potential of equities to be realized. 3. RECOMMENDATION OF THIRD-PARTY INVESTMENT ADVISERS The Advisor recommends and monitors third-party investment advisers (“Third-Party Advisers”). Advisor may recommend one or more Third-Party Adviser to its clients. The recommendation will depend on the client’s individual circumstances, goals and objectives, desired strategy, account size, risk tolerance, and other factors. The Advisor works with the client to determine which Third-Party Adviser may be appropriate. The client is never obligated to use a recommended Third-Party Adviser. The Advisor reviews each Third-Party Advisers before making a recommendation to the client. The Advisor considers the following factors during its review: fees, reputation, performance, financial strength, management, price, reporting capabilities, and the client’s financial situation, goals, needs and investment objectives. After our review, we will present the client with one or more recommendations. If the client wishes to proceed with the recommendation, the Advisor enters into a relationship with the recommended Third-Party Adviser. Under this relationship, the Third-Party adviser is responsible for portfolio management, best execution, portfolio reporting, trading, trade error resolution, and custodian reconciliations. The Advisor maintains their relationship with you by monitoring the status of the client’s accounts with the Third-Party Adviser, making recommendations about the Third-Party Adviser, typically meeting with the client either in person or by telephone on an annual basis, and acting as the client’s primary adviser. You should direct all questions regarding the Third-Party Adviser’s services and performance to the Advisor. When utilizing the services of a Third-Party Adviser, clients will be given a copy of their Form ADV Part 2A. Clients are encouraged to read and understand this disclosure document. 4. RETIREMENT PLAN SERVICES For business clients, the Advisor offers retirement plan consulting services. These services may cover ERISA and non-ERISA plans. Additionally, they may be ERISA fiduciary and/or ERISA non-fiduciary. The number of services is negotiated with each client. The ERISA fiduciary services may include: 1) Selection of Investments 2) Assessment of Investments 3) Participant Investment Advice Hungerford Financial, LLC Page 5 ADV Part 2A – 3/26/2025  4) Investment Policy Statement Preparation Non-ERISA fiduciary services may include: 1) Investment Policy Statement Review 2) Performance Monitoring 3) Third Party Service Provider Liaison 4) Employee Enrollment 5) Employee Education 6) Vendor Review/Conversion C. TAILORED SERVICES The Advisor’s portfolio management services are tailored to each client’s investment objectives, needs and goals. A client may impose restrictions on investment in certain securities (for example no tobacco stocks) or types of securities (for example no real estate related investments). Any restrictions must be provided in writing. D. WRAP PROGRAM The Advisor does not sponsor a wrap program. E. CLIENT ASSETS MANAGED As of March 7, 2025, we manage $350,745,872 in client assets on a discretionary basis and $27,549,665 in client assets on a non-discretionary basis. We have an additional $63,244,918 in client assets under advisement with a third-party adviser. 5. FEES AND COMPENSATION A. FINANCIAL PLANNING The Advisor’s financial planning services are offered on an hourly fee basis. The hourly fee is $250.00 per hour. The fee is negotiable and is based upon the number of topics covered, the amount of time required to write the plan, the areas of research involved, how involved/detailed the client would like the plan written, whether the Advisor works with the client’s CPA or attorney and time to write the plan. The fee is due upon presentation of the financial plan or conclusion of consulting arrangement. B. PORTFOLIO MANAGEMENT SERVICES Fees for portfolio management will be a percentage of the assets under management. The fee will be calculated, accrued and due quarterly in advance based upon the following annual fee schedule: Custodian Reported Value $0 to $1,000,000 $1,000,000.01 to $2,000,000 $2,000,000.01 to $5,000,000 $5,000,000.01 to $10,000,000 Above $10,000,000 Annual Management Fee 0.95% 0.85% 0.75% 0.65% Negotiable Hungerford Financial, LLC Page 6 ADV Part 2A – 3/26/2025  Notwithstanding the above fee schedule, Advisor requires a minimum annual management fee of $1,200 per account. The fee is negotiable based upon the size of the account and/or if the client has multiple accounts within his household with the Advisor. The fee will be based upon the account’s value as of the end of the previous quarter. The client will be asked to authorize the Advisor with the ability to withdraw the fee directly from the client’s account (see Item 15 for additional details). The Advisor’s fees are separate and distinct from other fees or expenses that may include brokerage charges, transaction fees, and other related costs and expenses. Additionally, clients may incur certain charges imposed by custodians, brokers, and other third parties such as fees charged by mutual fund managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, as disclosed in a fund’s prospectus, which are separate and distinct from the firm’s fee. Fees will not be based upon a share of capital gains or capital appreciation of the funds or of any portion of the funds under advisory contract. Fees for services to be performed will not be collected six or more months in advance. C. RECOMMENDATION OF THIRD-PARTY INVESTMENT ADVISERS Fees for when we recommend Third-Party Adviser services, we charge an annual management fee that is based on a percentage of the assets under management. The annual fee is based on the following fee schedule: Custodian Reported Value $0 to $1,000,000 $1,000,000.01 to $2,000,000 $2,000,000.01 to $5,000,000 $5,000,001 to $10,000,00 Above $10,000,000 Annual Management Fee 0.50% 0.40% 0.30% 0.20% Negotiable The fee is calculated, accrued and due quarterly, in arrears based on the account value as of the last business day of the quarter as reported by the account’s custodian. The fee is negotiable and is in addition to the Third-Party Adviser’s fee which is disclosed in their Form ADV Part 2A. The client will be asked to authorize the Third-Party Adviser with the ability to withdraw our fee. Our fees are separate and distinct from any other fees or expenses including the Third-Part Adviser’s fee. Other fees and expenses may include brokerage commissions, transactions fees, and other related costs and expenses. Additionally, clients may incur certain charges imposed by custodians, broker, third party investment advisors and other third parties such as; fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, as disclosed in a fund’s prospectus, which are separate and distinct from our fee. Hungerford Financial, LLC Page 7 ADV Part 2A – 3/26/2025  D. RETIREMENT PLAN SERVICES Fees for retirement plan services will be a percentage of plan assets. The fee will be calculated, accrued and due quarterly in advance based upon the following annual fee schedule: Custodian Reported Value $0 to $10,000,000 Above $10,000,000 Annual Management Fee 0.50% 0.25% The management fee is tiered. A tiered fee means the applicable rate will be applied to the fair market value in each applicable range of account value. For example, an account with a month end value of $10,300,000.00 will be charged 0.50% on the first $10,000,000 and 0.25% on the next $300,000. The fee is negotiable. E. TERMINATION OF SERVICES Financial Planning clients may terminate the financial planning service for any reason within the first five (5) business days after signing the contract without any cost or penalty. Thereafter, the contract may be terminated by either the client or the Advisor at any point in time through written notice to the party’s respective address of record. Portfolio management, Third-Party and qualified plan service clients may terminate their service for any reason at any time and, within the first five (5) business days after signing the contract, receive a 100% refund of any fees paid without any cost or penalty. Thereafter, the service may be terminated at any time by giving seven (7) days’ written notice to the other party. The written notice of termination by the client must be sent to Hungerford Financial, LLC, 2910 Lucerne Drive SE, Grand Rapids, MI 49546. Upon termination, fees will be prorated for the number of days that services were rendered during the termination quarter. All unearned fees will be refunded to the client. For example, if 90 days are in a quarter and services were rendered for 30 days in the quarter, the client will be refunded 67% of that quarter’s fee. (30/90 = .33 * 100 = 33% paid to Advisor for services with remainder/unearned fees paid to the Client. 100% - 33% = 67%). All refunds will be distributed within 30-days of termination. Refunds are paid by check or by depositing the fee back into the account. F. OTHER SECURITIES COMPENSATION Mr. Price is a registered representative of United Planners Financial Services (“UPFS”), member FINRA/SIPC. Through UPFS, he may sell securities to the Advisor’s clients for a commission. This causes a conflict of interest because the commissions UPFS are separate from the fees outlined above. Mr. Price attempts to mitigate this conflict of interest to the best of his ability by placing the client’s interest ahead of his own through his fiduciary duty. Additionally, it is our policy that recommended securities purchases or other investment Advisor services do not have to be purchased through Mr. Price or any affiliate. RETIREMENT ROLLOVER CONFLICTS OF INTEREST When we recommend you rollover a retirement account for us to manage, this creates a financial incentive because we charge a fee for our services. We attempt to mitigate the conflict of interest by acting in your best interest and applying an impartial conduct standard to all rollovers. Please Hungerford Financial, LLC Page 8 ADV Part 2A – 3/26/2025  note that you are not under any obligation to roll over a retirement account to an account managed by us. 6. PERFORMANCE-BASED FEES AND SIDE BY SIDE MANAGEMENT The Advisor does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client) or perform side by side management. This section is not applicable. 7. TYPES OF CLIENTS The Advisor’s services are offered to individuals, charities, high net worth individuals and pension and profit-sharing plans. The Advisor requires a minimum account size for its portfolio management services of $100,000. Additionally, there is a minimum annual fee of $2,000 for retirement plan services. However, the Advisor may waive the minimum at its discretion. 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS A. METHODS OF ANALYSIS AND INVESTMENT STRATEGIES The Advisor starts with a strategic asset allocation for each client and then manages the account using tactical asset allocation. With the initial strategic asset allocation, the Advisor takes into account the client’s risk tolerance, goals, investment objectives and other data gathered during the client meetings. Asset allocation is an investment strategy that aims to balance risk and reward by apportioning a portfolio's assets according to an individual's goals, risk tolerance and investment horizon among various asset classes. The risk associated with asset allocation is that each class has different levels of risk and return, so each will behave differently over time. Also, despite being diversified there is no guarantee that an account will grow. Tactical asset allocation is an active management portfolio strategy that rebalances the percentage of assets held in various categories in order to take advantage of market pricing anomalies or strong market sectors. This strategy is designed to allow portfolio managers to create extra value by taking advantage of certain situations in the marketplace. It is as a moderately active strategy because portfolio managers return to the portfolio's original strategic asset mix when desired short-term profits are achieved. The Advisor’s analysis of securities and advice relating thereto may be based upon information obtained from software programs, financial newspapers and magazines, research materials prepared by others, corporate ratings services, and annual reports, prospectuses and filings made with the Securities and Exchange Commission. The Advisor may also utilize computer models for performance analysis, asset allocation and risk management. B. RECOMMENDED SECURITIES AND INVESTMENT RISKS The Advisor primarily uses but is not limited to: Mutual Funds; Exchange Traded Funds; Equity Securities; Bonds and other corporate debt instruments; Government Debt instruments including Treasury Bills and Municipal securities; Options; Traded Real Estate Investment Trusts; Certificates of Deposit; Money Market Funds and Cash. Hungerford Financial, LLC Page 9 ADV Part 2A – 3/26/2025  All investments bear different types and degrees of risk and investing in securities involves risk of loss that clients should be prepared to bear. While the Advisor uses investment strategies that are designed to provide appropriate investment diversification, some investments have significantly greater risks than others. Obtaining higher rates of return on investments entails accepting higher levels of risk. Recommended investment strategies seek to balance risks and rewards to achieve investment objectives. A client needs to ask questions about risks he/she does not understand. The Advisor would be pleased to discuss them. An investment could lose money over short or even long periods. A client should expect his/her account value and returns to fluctuate within a wide range, like the fluctuations of the overall stock and bond markets. The client’s account performance could be hurt by:  Credit Risk: This is the risk that an issuer of a bond could suffer an adverse change in financial condition that results in a payment default, security downgrade, or inability to meet a financial obligation.  Inflation Risk: This is the risk that inflation will undermine the performance of your investment and/or the future purchasing power of your assets.  Interest Rate Risk: The chance that bond prices overall will decline because of rising interest rates. Interest rate risk will vary for the Firm, depending on the amount of Client assets invested in bonds.  International Investing Risk: Investing in the securities of non-U.S. companies involves special risks not typically associated with investing in U.S. companies. Foreign securities tend to be more volatile and less liquid than investments in U.S. securities, and may lose value because of adverse political, social or economic developments overseas or due to changes in the exchange rates between foreign currencies and the U.S. dollar. In addition, foreign investments are subject to settlement practices, and regulatory and financial reporting standards, which differ from those of the U.S.  Liquidity Risk: Liquidity risk exists when particular investments are difficult to purchase or sell, possibly preventing the ability to sell such illiquid securities at an advantageous time or price or possibly requiring the client to dispose of other investments at unfavorable times or prices in order to satisfy its obligations.  Manager Risk: The chance that the proportions allocated to the various securities will cause the Client’s account to underperform relevant to benchmarks or other accounts with a similar investment objective.  Options Risk: Like other securities - including stocks, bonds, and mutual funds - options carry no guarantees, and a person must be aware that it is possible to lose all of the principal he/she invests, and sometimes more. As an option holder, a person risks the entire amount of the premium he/she paid pay. But as an options writer, a person takes on a much higher level of risk. For example, if a person writes an uncovered call, he/she faces unlimited potential loss, since there is no cap on how high a stock price can rise. However, since initial options investments usually require less capital than equivalent stock positions, a potential cash loss as an options investor are usually smaller than if someone bought the underlying stock or sold the stock short. Hungerford Financial, LLC Page 10 ADV Part 2A – 3/26/2025  The exception to this general rule occurs when an option is used to provide leverage: Percentage returns are often high, but it is important to remember that percentage losses can be high as well.  REIT Market Risk: REITs have no control over market and business conditions and are vulnerable to market risk and slow-downs. External conditions beyond its control may reduce the value of properties that it acquires, the ability of tenants to pay rent on a timely basis, the amount of rent that can be charged and the ability of borrowers to make loan payments on a timely basis or at all. Cash available for distribution to stockholders can be affected by the tenant’s inability to make rents or pay loans.  REIT Tenant Strength Risk: REIT’s revenues are highly dependent on lease payments from its properties and interest payments on the loans it makes. Defaults by tenants or borrowers reduce the cash available for repayment of outstanding debt and distribution to investors. If tenants have multiple properties or borrowers have multiple loans it increases the risk of more than one property or loan going bad if that tenant or borrower defaults. More than one property could become vacant, or loans are in default because of the financial failure of one tenant or borrower. Multiple vacancies or defaults can reduce a REITs cash receipts and funds available for distribution and could decrease the value of the affected properties.  REIT Qualifying Risk: REITs must be organized and operated and intend to continue to be organized and to operate, in a manner that will enable them to qualify as a REIT for federal income tax purposes. No assurance can be given that a REIT qualifies or will continue to qualify as a REIT. If a REIT fails to qualify as a REIT, it will be subject to federal income tax at regular corporate rates. If a REIT fails to qualify the funds available for distribution to investors would be greatly reduced for each of the years involved.  Stock Market Risk: The chance that stock prices overall will decline. Stock markets tend to move in cycles, with periods of rising stock prices and periods of falling stock prices. 9. DISCIPLINARY INFORMATION Registered investment Advisors are required to disclose all material facts regarding any legal or disciplinary events within the past 10-years that would be material to your evaluation of the Advisor or the integrity of its management. These include the following: A. A criminal or civil action in a domestic, foreign or military court of competent jurisdiction in which the supervised person 1. was convicted of, or pled guilty or nolo contendere (“no contest”) to (a) any felony; (b) a misdemeanor that involved investments or an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses; 2. is the named subject of a pending criminal proceeding that involves an investment- related business, fraud, false statements or omissions, wrongful taking of property, Hungerford Financial, LLC Page 11 ADV Part 2A – 3/26/2025  bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses; 3. was found to have been involved in a violation of an investment-related statute or regulation; or 4. was the subject of any order, judgment, or decree permanently or temporarily enjoining, or otherwise limiting, the supervised person from engaging in any investment-related activity, or from violating any investment-related statute, rule, or order. The firm and Mr. Price have no information applicable to this item. B. An administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority in which the supervised person 1. was found to have caused an investment-related business to lose its authorization to do business; or 2. was found to have been involved in a violation of an investment-related statute or regulation and was the subject of an order by the agency or authority i. denying, suspending, or revoking the authorization of the supervised person to act in an investment-related business; ii. barring or suspending the supervised person's association with an investment-related business; iii. otherwise significantly limiting the supervised person's investment-related activities; or iv. imposing a civil money penalty of more than $2,500 on the supervised person. The firm and Mr. Price have no information applicable to this item. C. A self-regulatory organization (SRO) proceeding in which the supervised person 1. was found to have caused an investment-related business to lose its authorization to do business; or 2. was found to have been involved in a violation of the SRO’s rules and was: (i) barred or suspended from membership or from association with other members or was expelled from membership; (ii) otherwise significantly limited from investment- related activities; or (iii) fined more than $2,500. The firm and Mr. Price have no information applicable to this item. D. Any other proceeding in which a professional attainment, designation, or license of the supervised person was revoked or suspended because of a violation of rules relating to professional conduct. If the supervised person resigned (or otherwise relinquished his Hungerford Financial, LLC Page 12 ADV Part 2A – 3/26/2025  attainment, designation, or license) in anticipation of such a proceeding (and the adviser knows, or should have known, of such resignation or relinquishment), disclose the event. The firm and Mr. Price have no information applicable to this item. 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS A. BROKER-DEALER AFFILIATIONS The Advisor’s owner, Mr. Price, is a registered representative of United Planners Financial Services. Please see Item5.F for additional details. B. FUTURES/COMMODITIES FIRM AFFILIATION The Advisor and Mr. Price are not affiliated with a futures or commodities broker. C. OTHER INDUSTRY AFFILIATIONS The Advisor’s owner, Mr. Price, is licensed to sell (for sales commissions) insurance products (life and annuities) for various insurance companies that are duly licensed in the State of Michigan. This causes a conflict of interest because he receives a commission for these services, which is separate from the investment management and financial planning fees outlined in Item of the firm’s ADV Part 2A. Mr. Price attempts to mitigate the conflict of interest to the best of his ability by placing the client’s interests ahead of his own, through his fiduciary duty and by following the Advisor’s Code of Ethics. Clients are never obligated to purchase recommended insurance products through Mr. Price. Mr. Price is also a registered investment adviser of United Planners Financial Services, (“UPFS”). He may recommend this service to the firm’s clients. This other business activity pays him fees that are separate from the fees described above. This is a conflict of interest because the fees give Mr. Price a financial incentive to recommend UPFS’s services to the firm’s clients. However, Mr. Price attempts to mitigate any conflicts of interest to the best of his ability by placing the clients’ interest ahead of his own through his fiduciary duty and by informing clients that they are never obligated to use recommended services through him. D. SELECTION OF THIRD-PARTY INVESTMENT ADVISORS The Advisor can recommend the services of third-party investment adviser to assist with portfolio management services. This information can be found under Items 4 and 5. The Advisor will ensure that the third-party investment adviser is properly registered or exempt from registration in the client’s state of residence prior to making any recommendations. 11. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING A. DESCRIPTION The Advisor’s Code of Ethics establishes ideals for ethical conduct upon fundamental principles of openness, integrity, honesty, and trust. The Advisor will provide a copy of its Code of Ethics to any client or prospective client upon request. Hungerford Financial, LLC Page 13 ADV Part 2A – 3/26/2025  The Advisor’s Code of Ethics covers all supervised persons, and it describes its high standard of business conduct, and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at the Advisor must acknowledge the terms of the Code of Ethics annually or as amended. B. MATERIAL INTEREST IN SECURITIES The Advisor and its associates do not have a material interest in any securities. C. INVESTING IN OR RECOMMENDING THE SAME SECURITIES The Advisor’s associates may invest in the same securities that they purchase (for discretionary accounts) or recommend (for non-discretionary accounts) for client accounts. This causes a conflict of interest because the Advisor’s associates have the ability to trade ahead of the client and potentially receive more favorable prices than the client receives. The Advisor mitigates this conflict of interest by requiring the Advisor’s associates to trade their personal accounts either at the same time as it trades a client’s account (see Item 12.B for details about aggregate trading) or after trading a client’s account. The Advisor’s associates are aware of their fiduciary duty to their clients. Records of all associates' proprietary trading activities will be reviewed and made available to regulators to review on the premises. 12. BROKERAGE PRACTICES A. RECOMMENDATION CRITERIA When the Firm recommends brokers or custodians, it will seek broker-dealers who offer competitive commissions costs together with reliable services. A Client’s choice of another broker-dealer is acceptable if proven feasible. The Firm recommends Charles Schwab & Co., Inc., (“Schwab”) a registered broker-dealer, member FINRA/SPIC as the qualified custodian. We are independently owned and operated and not affiliated with Schwab. Schwab will hold the Clients’ assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend that the Client use Schwab as the custodian/broker, the client will decide whether to do so and open an account with Schwab by entering into an account agreement directly with them. We do not open the account for you; however, we can assist the Client in doing so. If the Client does not wish to place their assets with Schwab, then we cannot manage the account. With its charity clients, the Advisor typically recommends Schwab as the custodian because the Advisor participates in the Schwab Charitable Program. Schwab offers competitive commission costs together with reliable services through the program. A client’s choice of another broker-dealer is acceptable if proven feasible. The Advisor recognizes its fiduciary responsibility in negotiating brokerage commissions, assuring best execution practices and assuring adequate investment availability/inventory on behalf of our clients. The Advisor does not receive compensation with respect to execution of trades. In some instances, a client will incur a ticket charge for the sale and purchase of securities. Hungerford Financial, LLC Page 14 ADV Part 2A – 3/26/2025  NOTE: Clients may be able to obtain lower commissions and fees from other brokers, and the value of products, research and services given to the applicant is not a factor in determining the selection of broker/dealers or the reasonableness of their commissions. i. RESEARCH AND SOFT DOLLARS “Soft dollars” are defined as a form of payment investment firms can use to pay for goods and services such as news subscriptions or research. When an investment firm gives its business to a particular brokerage firm, the brokerage firm in return can agree to use some of its revenue to pay for these types of services. The Advisor does not receive “soft dollars” from any vendor, service provider or custodian. ii. BROKERAGE FOR CLIENT REFERRALS The Advisor does not receive client referrals or any other incentive from any broker-dealer or custodian. iii. DIRECTED BROKERAGE Some clients may direct the Advisor to use a specific broker-dealer to execute securities transactions for their accounts. When so directed, the Advisor may not be able to effectively achieve best execution on clients’ transactions. B. TRADE AGGREGATION The Advisor may aggregate orders with respect to the same security purchased for different clients. When orders are aggregated, each participating account receives the average share price for the transaction and bears a proportionate share of all transaction costs, based upon each account’s participation in the transaction, subject to our discretion depending on factual or market conditions. Clients participating in block trading may include proprietary or related accounts. Such accounts are treated as client accounts and are neither given preferential nor inferior treatment versus other client accounts. Allocations of orders among client accounts must be made in a fair and equitable manner. 13. REVIEW OF ACCOUNTS A. PERIODIC REVIEWS The Advisor’s owner, Thomas Price, reviews client accounts on a semi-annual basis. He also meets with clients either in person or by telephone three times per year. B. OTHER REVIEWS Reviews may also be triggered by events within client’s lives, as well as pertinent news events, changes in federal and state regulatory or tax regimes, and overall economic events. C. REPORTS Financial Planning clients receive a written report at the conclusion of the financial planning engagement. Portfolio Management clients will receive account statements from the custodian of their accounts at least quarterly, although monthly is customary. Hungerford Financial, LLC Page 15 ADV Part 2A – 3/26/2025  14. CLIENT REFERRALS AND OTHER COMPENSATION A. OTHER COMPENSATION The Firm may receive a non-economic benefit from Schwab in the form of support products and services they make available to us and other independent advisors whose Clients maintain their accounts at Schwab. The availability to us from Schwab’s products and services is not based on us giving particular investment advice, such as buying particular securities for the Client. B. CLIENT REFERRALS The Advisor does not pay for client referrals or use solicitors. 15. CUSTODY All client funds, securities and accounts are held at third-party custodians. The Advisor does not take possession of a client’s funds, securities or accounts. However, portfolio management clients will be asked to authorize the Advisor with the ability to deduct its fees directly from the client’s account. This authorization will apply to the Advisor’s management fees only. A client may cancel the Advisor’s ability to deduct the fees from the Account by notifying the Advisor at any time. The Account’s custodian will send a quarterly account statement, indicating the amount of fees withdrawn from the client’s Account. The Advisor urges clients to carefully review their statements and notify the firm of any discrepancies as soon as possible. At times, we assist some clients with the ability to move money from one account to another. In these situations, you will sign standing letter of instruction (“SLOAs”) with your custodian that grants us the ability to facilitate the transfer. When your money is transferred between accounts with different titles, this is considered a limited from of custody. In 2017, the SEC issued a no‐ action letter (“Letter”) with respect to the Rule 206(4)‐2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). We and your custodian follow the safeguards outlined in the letter. These safeguards include:  The client provides an instruction to the qualified custodian, in writing, which includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed.  The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time.  The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization and provides a transfer of funds notice to the client promptly after each transfer.  The client can terminate or change the instruction to the client’s qualified custodian.  The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction.  The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. Hungerford Financial, LLC Page 16 ADV Part 2A – 3/26/2025   The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. 16. INVESTMENT DISCRETION The Advisor offers both discretionary and non-discretionary investment management services. The discretionary investment management is granted when a client signs an investment management agreement. The investment management agreement contains a limited power of attorney that allows the firm to select the securities to be bought and sold and the amount of securities to be bought and sold in the client’s account. It also allows the firm to place each such trade without the client’s prior approval. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account, and any other investment policies, limitation or restrictions. When a client selects non-discretionary investment management services, the client retains full discretion to supervise, manage, and direct the assets of the account. The client will be free to manage the account with or without the Advisor’s recommendation and all with or without the Advisor’s prior consultation. 17. VOTING CLIENT SECURITIES The Advisor does not vote proxy. Clients should receive proxy solicitations directly from their account’s custodian. Any proxy solicitation materials received by the Advisor will be forwarded to clients for response and voting. In the event a client has a question about a proxy solicitation, the client should contact his/her investment Advisor representative. 18. FINANCIAL INFORMATION A. BALANCE SHEET The Advisor does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. B. FINANCIAL CONDITION Registered investment Advisors are required in this Item to provide you with certain financial information or disclosures about the Advisor’s financial condition. The Advisor has no financial commitment that impairs its ability to service its clients. C. BANKRUPTCY The Advisor, its owner and its investment Advisor representatives have not been the subject of a bankruptcy proceeding. Hungerford Financial, LLC Page 17 ADV Part 2A – 3/26/2025 

HUNGERFORD FINANCIAL, LLC FIRM BROCHURE (ADV PART 2A) MARCH 26, 2025 Hungerford Financial, LLC 2910 Lucerne Drive SE Grand Rapids, MI 49546 Phone: (616) 551-5452 Fax: (616) 949-7720 Email: Thomas@hungerfordfinancial.com Website: www.hungerfordfinancial.com This brochure provides information about the qualifications and business practices of Hungerford Financial, LLC. If you have any questions about the contents of this brochure, please contact Thomas Price at (616) 551-5452. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Hungerford Financial, LLC is a registered investment Advisor. Registration of an Investment Advisor does not imply any level of skill or training. The written communications of an Advisor provide you with information about which you determine to hire or retain an Advisor. Additional information about Hungerford Financial, LLC is available on the SEC’s website www.Advisorinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The Advisor’s CRD number is 249789.  2. MATERIAL CHANGES We have one material change to report since our last annual update which was on March 29, 2024. - - Item 5 – We have changed our fee schedule Retirement Plan Services. Please see Item 5 below for the new fee schedule. Item 7 – We now require a minimum annual fee for retirement plan services. Please see Item 7 below for our minimum requirements. We have no additional material changes to report. Hungerford Financial, LLC Page 2 ADV Part 2A – 3/26/2025  TABLE OF CONTENTS Item 2. Material Changes ..............................................................................................................2 Item 3. Table of Contents ..............................................................................................................3 Item 4. Advisory Business .............................................................................................................4 Item 5. Fees and Compensation ....................................................................................................6 Item 6. Performance-Based Fees and Side-By-Side Management ............................................9 Item 7. Types of Clients .................................................................................................................9 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss......................................9 Item 9. Disciplinary Information ................................................................................................12 Item 10. Other Financial Industry Activities and Affiliations .................................................13 Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading..........................................................................................................................................14 Item 12. Brokerage Practices ......................................................................................................15 Item 13. Review of Accounts .......................................................................................................16 Item 14. Client Referrals and Other Compensation .................................................................16 Item 15. Custody ..........................................................................................................................16 Item 16. Investment Discretion ...................................................................................................17 Item 17. Voting Client Securities ................................................................................................18 Item 18. Financial Information ...................................................................................................18 Hungerford Financial, LLC Page 3 ADV Part 2A – 3/26/2025  4. ADVISORY BUSINESS A. OWNERSHIP/ADVISORY HISTORY Hungerford Financial, LLC (“the Advisor”) was established as a Michigan Limited Liability Company in 2015. It became registered as a Michigan Investment Adviser in December 2015 and subsequently registered with the Securities and Exchange Commission in December 2018. The Advisor is owned by Hungerford Nichols, a CPA firm and Thomas J. Price (“Mr. Price”). Mr. Price is the firm’s managing member. B. ADVISORY SERVICES OFFERED The Advisor’s services include portfolio management services and the creation of financial plans for clients. The Advisor will meet with a client to evaluate the individual client’s investment needs, goals and objectives. After the evaluation, the Advisor may recommend one of the services described below. 1. FINANCIAL PLANNING The Advisor offers clients financial planning services to evaluate their financial situation, goals and risk tolerance. Through a series of personal interviews and the use of questionnaires the Advisor will collect pertinent data, identify goals, objectives, financial problems, potential solutions, prepare specific recommendations and implement recommendations. As a result of these actions, the Advisor’s advice may be provided on some or all of the following 13 Wealth Management Issues: 1) Investment Planning 2) Risk Management & Insurance Planning 3) Banking & Credit Management 4) Retirement Planning 5) Executive Compensation 6) Business Succession 7) Planning for Incapacity 8) Education & Family Support 9) Charitable Giving 10) Titling & Beneficiary Designations 11) Executor & Trustee Selection 12) Distribution of Estate 13) Tax Planning The Advisor may offer broad-based planning services, or the client may desire advice on certain planning components; the Advisor can tailor services as desired by the client. At the conclusion of the Financial Planning Service the Advisor will present the client with a written financial plan. Hungerford Financial, LLC Page 4 ADV Part 2A – 3/26/2025  2. PORTFOLIO MANAGEMENT The Advisor manages individualized portfolios for its clients. The Advisor works with each client to formulate an individualized portfolio based upon his/her objectives, time frame, risk parameters and other investment considerations. Please see Item 8 for additional information about the types of securities used and the Advisor’s investment strategies. The Advisor’s investment philosophy is to use principals of value, safety and quality to seek investment options globally. The Advisor places heavy emphasis on risk control, believing that avoiding losses allows appreciation potential of equities to be realized. 3. RECOMMENDATION OF THIRD-PARTY INVESTMENT ADVISERS The Advisor recommends and monitors third-party investment advisers (“Third-Party Advisers”). Advisor may recommend one or more Third-Party Adviser to its clients. The recommendation will depend on the client’s individual circumstances, goals and objectives, desired strategy, account size, risk tolerance, and other factors. The Advisor works with the client to determine which Third-Party Adviser may be appropriate. The client is never obligated to use a recommended Third-Party Adviser. The Advisor reviews each Third-Party Advisers before making a recommendation to the client. The Advisor considers the following factors during its review: fees, reputation, performance, financial strength, management, price, reporting capabilities, and the client’s financial situation, goals, needs and investment objectives. After our review, we will present the client with one or more recommendations. If the client wishes to proceed with the recommendation, the Advisor enters into a relationship with the recommended Third-Party Adviser. Under this relationship, the Third-Party adviser is responsible for portfolio management, best execution, portfolio reporting, trading, trade error resolution, and custodian reconciliations. The Advisor maintains their relationship with you by monitoring the status of the client’s accounts with the Third-Party Adviser, making recommendations about the Third-Party Adviser, typically meeting with the client either in person or by telephone on an annual basis, and acting as the client’s primary adviser. You should direct all questions regarding the Third-Party Adviser’s services and performance to the Advisor. When utilizing the services of a Third-Party Adviser, clients will be given a copy of their Form ADV Part 2A. Clients are encouraged to read and understand this disclosure document. 4. RETIREMENT PLAN SERVICES For business clients, the Advisor offers retirement plan consulting services. These services may cover ERISA and non-ERISA plans. Additionally, they may be ERISA fiduciary and/or ERISA non-fiduciary. The number of services is negotiated with each client. The ERISA fiduciary services may include: 1) Selection of Investments 2) Assessment of Investments 3) Participant Investment Advice Hungerford Financial, LLC Page 5 ADV Part 2A – 3/26/2025  4) Investment Policy Statement Preparation Non-ERISA fiduciary services may include: 1) Investment Policy Statement Review 2) Performance Monitoring 3) Third Party Service Provider Liaison 4) Employee Enrollment 5) Employee Education 6) Vendor Review/Conversion C. TAILORED SERVICES The Advisor’s portfolio management services are tailored to each client’s investment objectives, needs and goals. A client may impose restrictions on investment in certain securities (for example no tobacco stocks) or types of securities (for example no real estate related investments). Any restrictions must be provided in writing. D. WRAP PROGRAM The Advisor does not sponsor a wrap program. E. CLIENT ASSETS MANAGED As of March 7, 2025, we manage $350,745,872 in client assets on a discretionary basis and $27,549,665 in client assets on a non-discretionary basis. We have an additional $63,244,918 in client assets under advisement with a third-party adviser. 5. FEES AND COMPENSATION A. FINANCIAL PLANNING The Advisor’s financial planning services are offered on an hourly fee basis. The hourly fee is $250.00 per hour. The fee is negotiable and is based upon the number of topics covered, the amount of time required to write the plan, the areas of research involved, how involved/detailed the client would like the plan written, whether the Advisor works with the client’s CPA or attorney and time to write the plan. The fee is due upon presentation of the financial plan or conclusion of consulting arrangement. B. PORTFOLIO MANAGEMENT SERVICES Fees for portfolio management will be a percentage of the assets under management. The fee will be calculated, accrued and due quarterly in advance based upon the following annual fee schedule: Custodian Reported Value $0 to $1,000,000 $1,000,000.01 to $2,000,000 $2,000,000.01 to $5,000,000 $5,000,000.01 to $10,000,000 Above $10,000,000 Annual Management Fee 0.95% 0.85% 0.75% 0.65% Negotiable Hungerford Financial, LLC Page 6 ADV Part 2A – 3/26/2025  Notwithstanding the above fee schedule, Advisor requires a minimum annual management fee of $1,200 per account. The fee is negotiable based upon the size of the account and/or if the client has multiple accounts within his household with the Advisor. The fee will be based upon the account’s value as of the end of the previous quarter. The client will be asked to authorize the Advisor with the ability to withdraw the fee directly from the client’s account (see Item 15 for additional details). The Advisor’s fees are separate and distinct from other fees or expenses that may include brokerage charges, transaction fees, and other related costs and expenses. Additionally, clients may incur certain charges imposed by custodians, brokers, and other third parties such as fees charged by mutual fund managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, as disclosed in a fund’s prospectus, which are separate and distinct from the firm’s fee. Fees will not be based upon a share of capital gains or capital appreciation of the funds or of any portion of the funds under advisory contract. Fees for services to be performed will not be collected six or more months in advance. C. RECOMMENDATION OF THIRD-PARTY INVESTMENT ADVISERS Fees for when we recommend Third-Party Adviser services, we charge an annual management fee that is based on a percentage of the assets under management. The annual fee is based on the following fee schedule: Custodian Reported Value $0 to $1,000,000 $1,000,000.01 to $2,000,000 $2,000,000.01 to $5,000,000 $5,000,001 to $10,000,00 Above $10,000,000 Annual Management Fee 0.50% 0.40% 0.30% 0.20% Negotiable The fee is calculated, accrued and due quarterly, in arrears based on the account value as of the last business day of the quarter as reported by the account’s custodian. The fee is negotiable and is in addition to the Third-Party Adviser’s fee which is disclosed in their Form ADV Part 2A. The client will be asked to authorize the Third-Party Adviser with the ability to withdraw our fee. Our fees are separate and distinct from any other fees or expenses including the Third-Part Adviser’s fee. Other fees and expenses may include brokerage commissions, transactions fees, and other related costs and expenses. Additionally, clients may incur certain charges imposed by custodians, broker, third party investment advisors and other third parties such as; fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, as disclosed in a fund’s prospectus, which are separate and distinct from our fee. Hungerford Financial, LLC Page 7 ADV Part 2A – 3/26/2025  D. RETIREMENT PLAN SERVICES Fees for retirement plan services will be a percentage of plan assets. The fee will be calculated, accrued and due quarterly in advance based upon the following annual fee schedule: Custodian Reported Value $0 to $10,000,000 Above $10,000,000 Annual Management Fee 0.50% 0.25% The management fee is tiered. A tiered fee means the applicable rate will be applied to the fair market value in each applicable range of account value. For example, an account with a month end value of $10,300,000.00 will be charged 0.50% on the first $10,000,000 and 0.25% on the next $300,000. The fee is negotiable. E. TERMINATION OF SERVICES Financial Planning clients may terminate the financial planning service for any reason within the first five (5) business days after signing the contract without any cost or penalty. Thereafter, the contract may be terminated by either the client or the Advisor at any point in time through written notice to the party’s respective address of record. Portfolio management, Third-Party and qualified plan service clients may terminate their service for any reason at any time and, within the first five (5) business days after signing the contract, receive a 100% refund of any fees paid without any cost or penalty. Thereafter, the service may be terminated at any time by giving seven (7) days’ written notice to the other party. The written notice of termination by the client must be sent to Hungerford Financial, LLC, 2910 Lucerne Drive SE, Grand Rapids, MI 49546. Upon termination, fees will be prorated for the number of days that services were rendered during the termination quarter. All unearned fees will be refunded to the client. For example, if 90 days are in a quarter and services were rendered for 30 days in the quarter, the client will be refunded 67% of that quarter’s fee. (30/90 = .33 * 100 = 33% paid to Advisor for services with remainder/unearned fees paid to the Client. 100% - 33% = 67%). All refunds will be distributed within 30-days of termination. Refunds are paid by check or by depositing the fee back into the account. F. OTHER SECURITIES COMPENSATION Mr. Price is a registered representative of United Planners Financial Services (“UPFS”), member FINRA/SIPC. Through UPFS, he may sell securities to the Advisor’s clients for a commission. This causes a conflict of interest because the commissions UPFS are separate from the fees outlined above. Mr. Price attempts to mitigate this conflict of interest to the best of his ability by placing the client’s interest ahead of his own through his fiduciary duty. Additionally, it is our policy that recommended securities purchases or other investment Advisor services do not have to be purchased through Mr. Price or any affiliate. RETIREMENT ROLLOVER CONFLICTS OF INTEREST When we recommend you rollover a retirement account for us to manage, this creates a financial incentive because we charge a fee for our services. We attempt to mitigate the conflict of interest by acting in your best interest and applying an impartial conduct standard to all rollovers. Please Hungerford Financial, LLC Page 8 ADV Part 2A – 3/26/2025  note that you are not under any obligation to roll over a retirement account to an account managed by us. 6. PERFORMANCE-BASED FEES AND SIDE BY SIDE MANAGEMENT The Advisor does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client) or perform side by side management. This section is not applicable. 7. TYPES OF CLIENTS The Advisor’s services are offered to individuals, charities, high net worth individuals and pension and profit-sharing plans. The Advisor requires a minimum account size for its portfolio management services of $100,000. Additionally, there is a minimum annual fee of $2,000 for retirement plan services. However, the Advisor may waive the minimum at its discretion. 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS A. METHODS OF ANALYSIS AND INVESTMENT STRATEGIES The Advisor starts with a strategic asset allocation for each client and then manages the account using tactical asset allocation. With the initial strategic asset allocation, the Advisor takes into account the client’s risk tolerance, goals, investment objectives and other data gathered during the client meetings. Asset allocation is an investment strategy that aims to balance risk and reward by apportioning a portfolio's assets according to an individual's goals, risk tolerance and investment horizon among various asset classes. The risk associated with asset allocation is that each class has different levels of risk and return, so each will behave differently over time. Also, despite being diversified there is no guarantee that an account will grow. Tactical asset allocation is an active management portfolio strategy that rebalances the percentage of assets held in various categories in order to take advantage of market pricing anomalies or strong market sectors. This strategy is designed to allow portfolio managers to create extra value by taking advantage of certain situations in the marketplace. It is as a moderately active strategy because portfolio managers return to the portfolio's original strategic asset mix when desired short-term profits are achieved. The Advisor incorporates artificial intelligence ("AI") technologies into certain aspects of its investment advisory services. These technologies may include data analytics, machine learning algorithms, or decision-support tools designed to assist with functions such as investment research, portfolio analysis, risk monitoring, and operational processes. The use of AI is intended to supplement—not to replace the professional judgment of its investment personnel. All investment decisions are ultimately made by human advisors based on the client’s individual investment objectives, risk tolerance, and overall financial circumstances. While AI tools may enhance efficiency and analytical capabilities, they also present potential risks and limitations, including:  Reliance on historical or incomplete data Hungerford Financial, LLC Page 9 ADV Part 2A – 3/26/2025   Inherent biases in algorithms or data inputs  Lack of full contextual understanding by automated systems  Potential technical or operational failures The Advisor exercises oversight over AI-related tools and periodically reviews their functionality, accuracy, and consistency with client interests. The Advisor does not receive compensation from any third-party AI providers that would influence how such tools are used in managing client accounts. Client data used in connection with AI tools is subject to the Advisor’s information security and privacy safeguards, as described in its Privacy Policy. Clients are encouraged to contact the Advisor with any questions about how AI may be used in their advisory relationship. Additionally, the Advisor’s analysis of securities and advice relating thereto may be based upon information obtained from software programs, financial newspapers and magazines, research materials prepared by others, corporate ratings services, and annual reports, prospectuses and filings made with the Securities and Exchange Commission. The Advisor may also utilize computer models for performance analysis, asset allocation and risk management. B. RECOMMENDED SECURITIES AND INVESTMENT RISKS The Advisor primarily uses but is not limited to: Mutual Funds; Exchange Traded Funds; Equity Securities; Bonds and other corporate debt instruments; Government Debt instruments including Treasury Bills and Municipal securities; Options; Traded Real Estate Investment Trusts; Certificates of Deposit; Money Market Funds and Cash. All investments bear different types and degrees of risk and investing in securities involves risk of loss that clients should be prepared to bear. While the Advisor uses investment strategies that are designed to provide appropriate investment diversification, some investments have significantly greater risks than others. Obtaining higher rates of return on investments entails accepting higher levels of risk. Recommended investment strategies seek to balance risks and rewards to achieve investment objectives. A client needs to ask questions about risks he/she does not understand. The Advisor would be pleased to discuss them. An investment could lose money over short or even long periods. A client should expect his/her account value and returns to fluctuate within a wide range, like the fluctuations of the overall stock and bond markets. The client’s account performance could be hurt by:  Credit Risk: This is the risk that an issuer of a bond could suffer an adverse change in financial condition that results in a payment default, security downgrade, or inability to meet a financial obligation.  Inflation Risk: This is the risk that inflation will undermine the performance of your investment and/or the future purchasing power of your assets. Hungerford Financial, LLC Page 10 ADV Part 2A – 3/26/2025   Interest Rate Risk: The chance that bond prices overall will decline because of rising interest rates. Interest rate risk will vary for the Firm, depending on the amount of Client assets invested in bonds.  International Investing Risk: Investing in the securities of non-U.S. companies involves special risks not typically associated with investing in U.S. companies. Foreign securities tend to be more volatile and less liquid than investments in U.S. securities, and may lose value because of adverse political, social or economic developments overseas or due to changes in the exchange rates between foreign currencies and the U.S. dollar. In addition, foreign investments are subject to settlement practices, and regulatory and financial reporting standards, which differ from those of the U.S.  Liquidity Risk: Liquidity risk exists when particular investments are difficult to purchase or sell, possibly preventing the ability to sell such illiquid securities at an advantageous time or price or possibly requiring the client to dispose of other investments at unfavorable times or prices in order to satisfy its obligations.  Manager Risk: The chance that the proportions allocated to the various securities will cause the Client’s account to underperform relevant to benchmarks or other accounts with a similar investment objective.  Options Risk: Like other securities - including stocks, bonds, and mutual funds - options carry no guarantees, and a person must be aware that it is possible to lose all of the principal he/she invests, and sometimes more. As an option holder, a person risks the entire amount of the premium he/she paid pay. But as an options writer, a person takes on a much higher level of risk. For example, if a person writes an uncovered call, he/she faces unlimited potential loss, since there is no cap on how high a stock price can rise. However, since initial options investments usually require less capital than equivalent stock positions, a potential cash loss as an options investor are usually smaller than if someone bought the underlying stock or sold the stock short. The exception to this general rule occurs when an option is used to provide leverage: Percentage returns are often high, but it is important to remember that percentage losses can be high as well.  REIT Market Risk: REITs have no control over market and business conditions and are vulnerable to market risk and slow-downs. External conditions beyond its control may reduce the value of properties that it acquires, the ability of tenants to pay rent on a timely basis, the amount of rent that can be charged and the ability of borrowers to make loan payments on a timely basis or at all. Cash available for distribution to stockholders can be affected by the tenant’s inability to make rents or pay loans.  REIT Tenant Strength Risk: REIT’s revenues are highly dependent on lease payments from its properties and interest payments on the loans it makes. Defaults by tenants or borrowers reduce the cash available for repayment of outstanding debt and distribution to investors. If tenants have multiple properties or borrowers have multiple loans it increases the risk of more than one property or loan going bad if that tenant or borrower defaults. More than one property could become vacant, or loans are in default because of the financial failure of one tenant or Hungerford Financial, LLC Page 11 ADV Part 2A – 3/26/2025  borrower. Multiple vacancies or defaults can reduce a REITs cash receipts and funds available for distribution and could decrease the value of the affected properties.  REIT Qualifying Risk: REITs must be organized and operated and intend to continue to be organized and to operate, in a manner that will enable them to qualify as a REIT for federal income tax purposes. No assurance can be given that a REIT qualifies or will continue to qualify as a REIT. If a REIT fails to qualify as a REIT, it will be subject to federal income tax at regular corporate rates. If a REIT fails to qualify the funds available for distribution to investors would be greatly reduced for each of the years involved.  Stock Market Risk: The chance that stock prices overall will decline. Stock markets tend to move in cycles, with periods of rising stock prices and periods of falling stock prices. 9. DISCIPLINARY INFORMATION Registered investment Advisors are required to disclose all material facts regarding any legal or disciplinary events within the past 10-years that would be material to your evaluation of the Advisor or the integrity of its management. These include the following: A. A criminal or civil action in a domestic, foreign or military court of competent jurisdiction in which the supervised person 1. was convicted of, or pled guilty or nolo contendere (“no contest”) to (a) any felony; (b) a misdemeanor that involved investments or an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses; 2. is the named subject of a pending criminal proceeding that involves an investment- related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses; 3. was found to have been involved in a violation of an investment-related statute or regulation; or 4. was the subject of any order, judgment, or decree permanently or temporarily enjoining, or otherwise limiting, the supervised person from engaging in any investment-related activity, or from violating any investment-related statute, rule, or order. The firm and Mr. Price have no information applicable to this item. B. An administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority in which the supervised person 1. was found to have caused an investment-related business to lose its authorization to do business; or Hungerford Financial, LLC Page 12 ADV Part 2A – 3/26/2025  2. was found to have been involved in a violation of an investment-related statute or regulation and was the subject of an order by the agency or authority i. denying, suspending, or revoking the authorization of the supervised person to act in an investment-related business; ii. barring or suspending the supervised person's association with an investment-related business; iii. otherwise significantly limiting the supervised person's investment-related activities; or iv. imposing a civil money penalty of more than $2,500 on the supervised person. The firm and Mr. Price have no information applicable to this item. C. A self-regulatory organization (SRO) proceeding in which the supervised person 1. was found to have caused an investment-related business to lose its authorization to do business; or 2. was found to have been involved in a violation of the SRO’s rules and was: (i) barred or suspended from membership or from association with other members or was expelled from membership; (ii) otherwise significantly limited from investment- related activities; or (iii) fined more than $2,500. The firm and Mr. Price have no information applicable to this item. D. Any other proceeding in which a professional attainment, designation, or license of the supervised person was revoked or suspended because of a violation of rules relating to professional conduct. If the supervised person resigned (or otherwise relinquished his attainment, designation, or license) in anticipation of such a proceeding (and the adviser knows, or should have known, of such resignation or relinquishment), disclose the event. The firm and Mr. Price have no information applicable to this item. 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS A. BROKER-DEALER AFFILIATIONS The Advisor’s owner, Mr. Price, is a registered representative of United Planners Financial Services. Please see Item5.F for additional details. B. FUTURES/COMMODITIES FIRM AFFILIATION The Advisor and Mr. Price are not affiliated with a futures or commodities broker. C. OTHER INDUSTRY AFFILIATIONS The Advisor’s owner, Mr. Price, is licensed to sell (for sales commissions) insurance products (life and annuities) for various insurance companies that are duly licensed in the State of Michigan. This causes a conflict of interest because he receives a commission for these services, which is Hungerford Financial, LLC Page 13 ADV Part 2A – 3/26/2025  separate from the investment management and financial planning fees outlined in Item of the firm’s ADV Part 2A. Mr. Price attempts to mitigate the conflict of interest to the best of his ability by placing the client’s interests ahead of his own, through his fiduciary duty and by following the Advisor’s Code of Ethics. Clients are never obligated to purchase recommended insurance products through Mr. Price. Mr. Price is also a registered investment adviser of United Planners Financial Services, (“UPFS”). He may recommend this service to the firm’s clients. This other business activity pays him fees that are separate from the fees described above. This is a conflict of interest because the fees give Mr. Price a financial incentive to recommend UPFS’s services to the firm’s clients. However, Mr. Price attempts to mitigate any conflicts of interest to the best of his ability by placing the clients’ interest ahead of his own through his fiduciary duty and by informing clients that they are never obligated to use recommended services through him. D. SELECTION OF THIRD-PARTY INVESTMENT ADVISORS The Advisor can recommend the services of third-party investment adviser to assist with portfolio management services. This information can be found under Items 4 and 5. The Advisor will ensure that the third-party investment adviser is properly registered or exempt from registration in the client’s state of residence prior to making any recommendations. 11. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING A. DESCRIPTION The Advisor’s Code of Ethics establishes ideals for ethical conduct upon fundamental principles of openness, integrity, honesty, and trust. The Advisor will provide a copy of its Code of Ethics to any client or prospective client upon request. The Advisor’s Code of Ethics covers all supervised persons, and it describes its high standard of business conduct, and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at the Advisor must acknowledge the terms of the Code of Ethics annually or as amended. B. MATERIAL INTEREST IN SECURITIES The Advisor and its associates do not have a material interest in any securities. C. INVESTING IN OR RECOMMENDING THE SAME SECURITIES The Advisor’s associates may invest in the same securities that they purchase (for discretionary accounts) or recommend (for non-discretionary accounts) for client accounts. This causes a conflict of interest because the Advisor’s associates have the ability to trade ahead of the client and potentially receive more favorable prices than the client receives. The Advisor mitigates this conflict of interest by requiring the Advisor’s associates to trade their personal accounts either at Hungerford Financial, LLC Page 14 ADV Part 2A – 3/26/2025  the same time as it trades a client’s account (see Item 12.B for details about aggregate trading) or after trading a client’s account. The Advisor’s associates are aware of their fiduciary duty to their clients. Records of all associates' proprietary trading activities will be reviewed and made available to regulators to review on the premises. 12. BROKERAGE PRACTICES A. RECOMMENDATION CRITERIA When the Firm recommends brokers or custodians, it will seek broker-dealers who offer competitive commissions costs together with reliable services. A Client’s choice of another broker-dealer is acceptable if proven feasible. The Firm recommends Charles Schwab & Co., Inc., (“Schwab”) a registered broker-dealer, member FINRA/SPIC as the qualified custodian. We are independently owned and operated and not affiliated with Schwab. Schwab will hold the Clients’ assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend that the Client use Schwab as the custodian/broker, the client will decide whether to do so and open an account with Schwab by entering into an account agreement directly with them. We do not open the account for you; however, we can assist the Client in doing so. If the Client does not wish to place their assets with Schwab, then we cannot manage the account. With its charity clients, the Advisor typically recommends Schwab as the custodian because the Advisor participates in the Schwab Charitable Program. Schwab offers competitive commission costs together with reliable services through the program. A client’s choice of another broker-dealer is acceptable if proven feasible. The Advisor recognizes its fiduciary responsibility in negotiating brokerage commissions, assuring best execution practices and assuring adequate investment availability/inventory on behalf of our clients. The Advisor does not receive compensation with respect to execution of trades. In some instances, a client will incur a ticket charge for the sale and purchase of securities. NOTE: Clients may be able to obtain lower commissions and fees from other brokers, and the value of products, research and services given to the applicant is not a factor in determining the selection of broker/dealers or the reasonableness of their commissions. i. RESEARCH AND SOFT DOLLARS “Soft dollars” are defined as a form of payment investment firms can use to pay for goods and services such as news subscriptions or research. When an investment firm gives its business to a particular brokerage firm, the brokerage firm in return can agree to use some of its revenue to pay for these types of services. The Advisor does not receive “soft dollars” from any vendor, service provider or custodian. ii. BROKERAGE FOR CLIENT REFERRALS The Advisor does not receive client referrals or any other incentive from any broker-dealer or custodian. iii. DIRECTED BROKERAGE Some clients may direct the Advisor to use a specific broker-dealer to execute securities Hungerford Financial, LLC Page 15 ADV Part 2A – 3/26/2025  transactions for their accounts. When so directed, the Advisor may not be able to effectively achieve best execution on clients’ transactions. B. TRADE AGGREGATION The Advisor may aggregate orders with respect to the same security purchased for different clients. When orders are aggregated, each participating account receives the average share price for the transaction and bears a proportionate share of all transaction costs, based upon each account’s participation in the transaction, subject to our discretion depending on factual or market conditions. Clients participating in block trading may include proprietary or related accounts. Such accounts are treated as client accounts and are neither given preferential nor inferior treatment versus other client accounts. Allocations of orders among client accounts must be made in a fair and equitable manner. 13. REVIEW OF ACCOUNTS A. PERIODIC REVIEWS The Advisor’s owner, Thomas Price, reviews client accounts on a semi-annual basis. He also meets with clients either in person or by telephone three times per year. B. OTHER REVIEWS Reviews may also be triggered by events within client’s lives, as well as pertinent news events, changes in federal and state regulatory or tax regimes, and overall economic events. C. REPORTS Financial Planning clients receive a written report at the conclusion of the financial planning engagement. Portfolio Management clients will receive account statements from the custodian of their accounts at least quarterly, although monthly is customary. 14. CLIENT REFERRALS AND OTHER COMPENSATION A. OTHER COMPENSATION The Firm may receive a non-economic benefit from Schwab in the form of support products and services they make available to us and other independent advisors whose Clients maintain their accounts at Schwab. The availability to us from Schwab’s products and services is not based on us giving particular investment advice, such as buying particular securities for the Client. B. CLIENT REFERRALS The Advisor does not pay for client referrals or use solicitors. 15. CUSTODY All client funds, securities and accounts are held at third-party custodians. The Advisor does not take possession of a client’s funds, securities or accounts. However, portfolio management clients will be asked to authorize the Advisor with the ability to deduct its fees directly from the client’s account. This authorization will apply to the Advisor’s management fees only. A client may cancel the Advisor’s ability to deduct the fees from the Account by notifying the Advisor at any time. Hungerford Financial, LLC Page 16 ADV Part 2A – 3/26/2025  The Account’s custodian will send a quarterly account statement, indicating the amount of fees withdrawn from the client’s Account. The Advisor urges clients to carefully review their statements and notify the firm of any discrepancies as soon as possible. At times, we assist some clients with the ability to move money from one account to another. In these situations, you will sign standing letter of instruction (“SLOAs”) with your custodian that grants us the ability to facilitate the transfer. When your money is transferred between accounts with different titles, this is considered a limited from of custody. In 2017, the SEC issued a no‐ action letter (“Letter”) with respect to the Rule 206(4)‐2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). We and your custodian follow the safeguards outlined in the letter. These safeguards include:  The client provides an instruction to the qualified custodian, in writing, which includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed.  The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time.  The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization and provides a transfer of funds notice to the client promptly after each transfer.  The client can terminate or change the instruction to the client’s qualified custodian.  The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction.  The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser.  The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. 16. INVESTMENT DISCRETION The Advisor offers both discretionary and non-discretionary investment management services. The discretionary investment management is granted when a client signs an investment management agreement. The investment management agreement contains a limited power of attorney that allows the firm to select the securities to be bought and sold and the amount of securities to be bought and sold in the client’s account. It also allows the firm to place each such trade without the client’s prior approval. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account, and any other investment policies, limitation or restrictions. When a client selects non-discretionary investment management services, the client retains full discretion to supervise, manage, and direct the assets of the account. The client will be free to manage the account with or without the Advisor’s recommendation and all with or without the Advisor’s prior consultation. Hungerford Financial, LLC Page 17 ADV Part 2A – 3/26/2025  17. VOTING CLIENT SECURITIES The Advisor does not vote proxy. Clients should receive proxy solicitations directly from their account’s custodian. Any proxy solicitation materials received by the Advisor will be forwarded to clients for response and voting. In the event a client has a question about a proxy solicitation, the client should contact his/her investment Advisor representative. 18. FINANCIAL INFORMATION A. BALANCE SHEET The Advisor does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. B. FINANCIAL CONDITION Registered investment Advisors are required in this Item to provide you with certain financial information or disclosures about the Advisor’s financial condition. The Advisor has no financial commitment that impairs its ability to service its clients. C. BANKRUPTCY The Advisor, its owner and its investment Advisor representatives have not been the subject of a bankruptcy proceeding. Hungerford Financial, LLC Page 18 ADV Part 2A – 3/26/2025