VESTMENT FINANCIAL LLC

Item 1: Cover Page Vestment Financial LLC dba MD Financial Advisors Form ADV Part 2A Investment Adviser Brochure 7935 Stone Creek Dr., Suite 120 Chanhassen, MN 55317 (888) 256-6855 www.mdfinancialadvisors.com March 2025 This Brochure provides information about the qualifications and business practices of MD Financial Advisors (“we,” “us,” “our”). If you have any questions about the contents of this Brochure, please contact Katherine Vessenes, JD, CFP®, founder, Chief Executive Officer and Chief Compliance Officer at (888) 256-6855 or info@mdfinancialadvisors.com. Additional information about our Firm is also available at www.adviserinfo.sec.gov. 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. We are a registered investment adviser. Please note that use of the term “registered investment advisor” and a description of the Firm and/or our employees as “registered” does not imply a certain level of skill or training. For more information on the qualifications of the Firm and our employees who advise you, we encourage you to review this Brochure and the Brochure Supplement(s).  Item 2: Summary of Material Changes In this Item of MD Financial Advisors (“MDFA” or the “Firm,” “we,” “us,” “ours,”) Form ADV 2, we are required to discuss any material changes that have been made to Form ADV since the last Annual Amendment. Material Changes since the Last Update Since the filing of our Annual Amendment on March 18, 2024, we have the following material changes to report: • We rewrote Forms ADV 2A and 2B, and as such, will deliver these documents in their entirety to all clients. Annual Update You will receive a summary of any material changes to our Form ADV brochure within 120 days of our fiscal year end. We may also provide updated disclosure information about material changes on a more frequent basis. Any summaries of changes will include the date of the last annual update of the ADV. The Supplement to our Form ADV Brochure (Form ADV Part 2B) provides you with information regarding our employees that provide investment advice. Full Brochure Available Our Form ADV may be requested at any time, without charge by contacting Katherine Vessenes, JD, CFP®, Chief Executive Officer and Chief Compliance Officer at (888) 256-6855 or info@mdfinancialadvisors.com. Additional information about the Firm is also available via the SEC’s website at www.adviserinfo.sec.gov. The SEC’s website also provides information about any employees affiliated with the Firm who are registered as investment adviser representatives. 2  Item 3: Table of Contents Item 1: Cover Page ........................................................................................................................ 1 Item 2: Summary of Material Changes .......................................................................................... 2 Item 4: Advisory Business ............................................................................................................. 4 Item 5: Fees and Compensation .................................................................................................... 8 Item 6: Performance-Based Fees and Side-by-Side Management............................................... 13 Item 7: Types of Clients ............................................................................................................... 14 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ......................................... 15 Item 9: Disciplinary Information.................................................................................................. 17 Item 10: Other Financial Industry Activities and Affiliations ....................................................... 18 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .. 19 Item 12: Brokerage Practices ...................................................................................................... 20 Item 13: Review of Accounts ....................................................................................................... 22 Item 14: Client Referrals and Other Compensation .................................................................... 23 Item 15: Custody ......................................................................................................................... 24 Item 16: Investment Discretion ................................................................................................... 25 Item 17: Voting Client Securities ................................................................................................. 26 Item 18: Financial Information .................................................................................................... 27 Form ADV Part 2B – Investment Adviser Brochure Supplement ................................................. 28 3  Item 4: Advisory Business Firm Information This Disclosure Brochure (“Form ADV Part 2”) provides information regarding the qualifications, business practices, and the advisory services provided by MD Financial Advisors (“MDFA,” or “the Firm”, “we”, “us”, “ours”). We are a federally Registered Investment Adviser with the U.S. Securities and Exchange Commission (“SEC”). We were founded in 2013 and are owned, founded, and operated by Katherine Vessenes, JD, CFP®, Chief Executive Officer and Chief Compliance Officer. Types of Advisory Services Financial Planning and Consulting Services We offer financial planning services, which may include a review of all aspects of a client’s current financial situation, including the following components: cash management, risk management, insurance, education funding, goal setting, retirement planning, estate and charitable giving planning, tax planning, and capital needs planning. Clients understand that when we are engaged to address only certain components, the client’s overall financial and investment issues may not be taken into consideration. We meet with the client to review risk tolerance, financial goals and objectives, and time horizons. Additional meetings may include a review of additional financial information; sources of income, assets owned, existing insurance, liabilities, wills, trusts, business agreements, tax returns, investments, and personal and family obligations. The financial plan may include both long and short-term considerations, depending upon the individual scenario. Upon completion, a plan is presented to the client, and the client is provided with recommendations that are deemed to be compatible with the client’s stated goals and objectives. An implementation schedule is reviewed with the client to determine which steps will be pursued, and with whom the steps may be accomplished. The client is under no obligation to utilize the Firm to implement the advice or plan. Clients may choose all or certain components of advice and recommendations and can implement the recommendations through the service providers of their choice. Investment Advisory Services We provide customized investment advisory solutions for clients. This is achieved through ongoing personal client contact and interaction while providing discretionary investment management and consulting services. We work with each client to identify their investment goals and objectives as well as risk tolerance and financial situation to create a portfolio allocation. We believe that markets reward investors over a long period of time. We help clients focus on controlling the things that they can control, like the investment structure of their portfolio's 4  asset allocation, diversification, rebalancing, their broad-based tax strategies, their internal fees, and portfolio model selection based on their timeframe for needing funds. We also believe that, for the most part markets are efficient and, therefore today's prices reflect all available public information. Therefore, we utilize low-cost mutual funds and exchange traded funds (primarily managed by Dimensional Fund Advisors, Avantis, and others) representing various traditional and alternative asset classes in a diversified portfolio. Our process involves developing asset allocation models both for taxable and tax-deferred accounts. The allocations are largely based on the market capitalization at the time of the portfolio creation. Our investment strategy is primarily long-term focused, but we may buy, sell, or re-allocate positions that have been held less than one year to meet the objectives of the client or due to market conditions. We will construct, implement, and monitor the portfolio which is designed to the meet the goals, objectives, circumstances, and risk tolerance of the client. We evaluate and select investments for inclusion in client portfolios only after applying an internal due diligence process. We may recommend, on occasion, redistributing investment allocations to diversify the portfolio. The Firm may recommend specific positions to increase sector or asset class weightings and may recommend employing cash positions as a possible hedge against market movement, which may adversely affect the portfolio’s performance. We may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of client, generating cash to meet client needs, or any risk deemed unacceptable for the client’s risk tolerance. Prior to rendering investment advisory services, we will assess, in conjunction with the client, the client’s financial situation, risk tolerance, investment/custodial platform, and investment objective[s]. Retirement Plan Services We also offer retirement plan services to businesses and other plan sponsors where we provide plan level services such as discretionary management services, non-discretionary management services, and investment advisory services related to different types of employer sponsored retirement plans. When providing discretionary management services, we are responsible for making and implementing decisions. When providing non-discretionary management services, we are responsible for making recommendations and for implementing them upon client approval. When we provide advisory services, the client is responsible for implementation of recommendations. Tailored Relationships We tailor investment advisory services to the individual needs of the client. Our clients are allowed to impose restrictions on the investments in their account. All limitations and 5  restrictions placed on accounts must be presented to us in writing. Wrap Fee Programs A “wrap-fee” program is one that provides the client with advisory and brokerage execution services for an all-inclusive fee. The client is not charged separate fees for the respective components of the total service. We do not sponsor, manage, or participate in a Wrap Fee Program. Fiduciary Statement We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act, (“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing retirement accounts. We must act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that conflicts with the interests of the client. We have the following responsibilities when working with a client: • To render impartial advice; • To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives; • To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead; • To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations; • Disclose any material conflict of interest in writing; and • Treat clients fairly and equitably. Regulations prohibit us from: • Employing any device, scheme, or artifice to defraud a client; • Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client; • Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or • Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner, when working with clients. We will use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, trading, promoting our 6  services, and engaging in other professional activities. Assets Under Management As of March 6, 2025, we managed $246,130,608 in client assets on a discretionary basis. 7  Item 5: Fees and Compensation We base our fees on hourly charges, fixed fees, or a percentage of assets under management, which are described below. Compensation – Financial Planning and Consulting Financial Planning and Consulting fees will be charged in one of three ways: • As a fixed fee, typically ranging up to $25,000 depending on the nature and complexity of each client’s circumstances, or • On an hourly basis of $50 - $650 per hour dependent upon the skill level of the team member involved (i.e., attorney - $650/hr., senior advisor - $300/hr., staff - $100- 150/hr.). • A monthly subscription or concierge financial planning fee, which typically ranges from $190 to $350 per month depending on the complexity of the client’s situation. Fees can be higher or lower. Depending on the manner of billing outlined in the client Agreement, clients will either be charged monthly, in arrears, or at the presentation of the financial plan. Credit card payments may be assessed an additional 3% fee per charge made on the credit card. Compensation – Investment Advisory Services Investment Advisory fees are charged a fee as follows: For accounts up to $250,000 $250,000 to $2,000,000 $2,000,000 to $5,000,000 $5,000,000 to $7,500,000 $7,500,000 to $10,000,000 Annual Fee (on all account assets) 1.25% 1.00% 0.85% 0.75% 0.70% Investment Advisory fees in the first period of service are prorated to the inception date of the account to the end of the first period. For accounts held at our custodians, fees are generally charged quarterly in arrears based on the market value of assets under management at the end of each calendar quarter billing period. For accounts held outside of our custodians, fees are generally charged monthly or quarterly in arrears based on the market value of assets under management at the beginning of each period. Compensation - Retirement Plan Services Fees charged for retirement plan services are generally charged in arrears. Fees may be fixed or 8  asset based (not to exceed 1.50% annually), and are negotiable depending on the complexity of the service provided, size of plan, etc. Asset based fee levels are primarily based on actual services to be provided and complexity of the engagement. Fixed fees are estimated based on the total hours expected for the engagement, staff needed, etc. (i.e., estimated hours times hourly rates). Fees may be deducted directly from the plan or may be paid on behalf of the plan by a plan provider. When fees are deducted, clients will be provided with a statement, at least quarterly, from the custodian reflecting deduction of the Investment Advisory Fee from the plan. In some cases, clients may elect to alternatively pay fees by check or wire transfer initiated by the client or applicable plan provider. In these instances, client or the applicable plan provider would have control over initiating payments via the applicable payment platform, and the Firm would have no such control or access. Payment frequency is generally quarterly but is subject to negotiation. Calculation and Payment The specific way we charge fees is established in a client’s written agreement with us. Clients may elect to be invoiced directly for fees or to authorize us to directly debit fees from client accounts. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. In no case will more than $1,200 be collected from the client more than 6 months in advance. Other Fees There are no additional types of fees or expenses that our clients pay in connection with the delivery of advisory services. Agreement Terms Either party may terminate an agreement at any time by notifying the other in writing. If the client made an advance payment, we would refund any unearned portion of the advance payment. If the client made a payment in arrears, we would collect any earned yet unpaid fees. Cash Balances Some of your assets may be held as cash and remain uninvested. Holding a portion of your assets in cash and cash alternatives, i.e., money market fund shares, may be based on your desire to have an allocation to cash as an asset class, to support a phased market entrance strategy, to facilitate transaction execution, to have available funds for withdrawal needs or to pay fees or to provide for asset protection during periods of volatile market conditions. Your cash and cash equivalents will be subject to our investment advisory fees unless otherwise agreed upon. You may experience negative performance on the cash portion of your portfolio if 9  the investment advisory fees charged are higher than the returns you receive from your cash. Retirement Plan Rollover Recommendations As part of our investment advisory services to our clients, we may recommend that clients roll assets from their employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively, a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA, Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will advise on the client’s behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. If the client elects to roll the assets to an IRA that is subject to our advisement, we will charge the client an asset-based fee as set forth in the advisory agreement the client executed with our firm. This creates a conflict of interest because it creates a financial incentive for our firm to recommend the rollover to the client (i.e., receipt of additional fee-based compensation). Clients are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if clients do complete the rollover, clients are under no obligation to have the assets in an IRA advised on by our firm. Due to the foregoing conflict of interest, when we make rollover recommendations, we operate under a special rule that requires us to act in our clients’ best interests and not put our interests ahead of our clients. Under this special rule’s provisions, we must: • meet a professional standard of care when making investment recommendations (give prudent advice); • never put our financial interests ahead of our clients’ when making recommendations (give loyal advice); • avoid misleading statements about conflicts of interest, fees, and investments; • follow policies and procedures designed to ensure that we give advice that is in our clients’ best interests; • charge no more than a reasonable fee for our services; and • give clients basic information about conflicts of interest. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, clients should consider the costs and benefits of a rollover. Note that an employee will typically have four options in this situation: 1. leaving the funds in the employer’s (former employer’s) plan; 2. moving the funds to a new employer’s retirement plan; 3. cashing out and taking a taxable distribution from the plan; or 4. rolling the funds into an IRA rollover account. 10  Each of these options has positives and negatives. Because of that, along with the importance of understanding the differences between these types of accounts, we will provide clients with a written explanation of the advantages and disadvantages of both account types and document the basis for our belief that the rollover transaction we recommend is in your best interests. General Information on Compensation and Other Fees In certain circumstances, fees, account minimums and payment terms are adjusted depending on client’s unique situation – such as the size of the aggregate related party portfolio size, family holdings, low-cost basis securities, or certain passively advised investments and pre- existing relationships with clients. Certain clients may pay more or less than others depending on the amount of assets, type of portfolio, or the time involved, the degree of responsibility assumed, complexity of the engagement, special skills needed to solve problems, the application of experience and knowledge of the client’s situation. Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third party investment 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, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to our fees, and we shall not receive any portion of these commissions, fees, and costs. All fees paid to us for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds to their shareholders. These fees and expenses are described in each fund’s prospectus. These fees will generally include a management fee, other expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund directly, without our services. In that case, the client would not receive our services, which are designed, among other things, to assist the client in determining which mutual funds are most appropriate to each client’s financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and the fees charged by us to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Clients should note that similar advisory services may (or may not) be available from other registered investment advisers for similar, higher, or lower fees. Mutual Fund Share Class Selection Similar investment management services may (or may not) be available from other investment 11  advisers for a similar, higher, or lower fee. Investment management fees, which include investment management and transaction costs, may be more or less costly than paying for the services separately, depending upon the investment advisory fees charged, the number of transactions for the account, the mutual fund share class you purchase and the underlying 12(b)-1 fee, and the level of brokerage and other fees that would be payable if you obtained the services available individually. 12  Item 6: Performance-Based Fees and Side-by-Side Management “Performance-based fees” are fees based on the capital gains or capital appreciation in an account. We do not charge performance-based fees. “Side-by-side management” refers to the practice of managing both accounts that are charged a performance-based fee and accounts that are charged other types of fees, such as asset-based fees and hourly fees. Because we do not charge performance-based fees, we do not engage in side-by-side management. 13  Item 7: Types of Clients Types of Clients We provide services to individuals, high net worth individuals, trusts, estates, retirement plans, foundations, endowments, charitable organizations, and businesses. Account Minimums We have no minimum account size. 14  Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis We use the following methods of analysis in formulating our investment advice and/or managing client assets: Fundamental Analysis, which attempts to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Investment Strategies Our investment strategies and advice may vary depending upon each client's specific financial situation. As such, we determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs and other various suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is important that you notify us immediately with respect to any material changes to your financial circumstances, including for example, a change in your current or expected income level, tax circumstances, or employment status. Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. All investments involve the risk of loss, including (among other things) loss of principal, a reduction in earnings (including interest, dividends, and other distributions), and the loss of future earnings. Although we manage assets in a manner consistent with your investment objectives and risk tolerance, there can be no guarantee that our efforts will be successful. You should be prepared to bear the following risks of loss: • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Market Risk: The price of a security, bond, or mutual fund may drop in reaction to • tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market events. Inflation Risk: When any type of inflation is present, a dollar next year will not buy as much as a dollar today, because purchasing power is eroding at the rate of inflation. 15  • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. • Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties (i.e., Non-traded REITs and other alternative investments) are not. • Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. • Cybersecurity Risk: A breach in cyber security refers to both intentional and unintentional events that may cause an account to lose proprietary information, suffer data corruption, or lose operational capacity. This in turn could cause an account to incur regulatory penalties, reputational damage, and additional compliance costs associated with corrective measures, and/or financial loss. • Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries, and causing significant economic, social, and political disruption. • Custodial Risk: This risk is the probability that a party to a transaction will be unable or unwilling to fulfill its contractual obligations either due to technological errors, control failures, malfeasance, or potential regulatory liabilities. 16  Item 9: Disciplinary Information We are required to disclose all pertinent facts regarding any legal, regulatory, or disciplinary events that would be material to your evaluation of the Firm or the integrity of our management. There have never been any legal, regulatory, or disciplinary actions against the Firm or our management persons. 17  Item 10: Other Financial Industry Activities and Affiliations We are required to disclose to our clients any relationship or arrangement with certain related persons that is material to our advisory business. Financial Industry Activities We are not registered as a broker-dealer, and none of our management persons are registered representatives of a broker-dealer. Neither we, nor any of our management persons, is registered as (or associated with) a futures commissions merchant, commodity pool operator, or a commodity trading advisor. Lawyer or Law Firm Katherine Vessenes, JD, CFP®, Chief Executive Officer and Chief Compliance Officer, is an attorney, of counsel, to Messerli and Kramer, a Minnesota law firm. The law firm is a licensed and practicing entity providing legal services for separate and typical compensation. Katherine Vessenes may offer advice, through the law firm, regarding tax and estate planning, as well as other matters that do not fall within the scope of our investment advisory services, and she is compensated through the law firm for those services. The law firm may recommend our advisory services to its legal clients and vice versa. Legal services provided by the law firm are separate and distinct from our advisory services and are provided for separate and typical compensation. Please see Item 14: Client Referrals for more information on referral arrangements. Our clients are not obligated to use the law firm for any legal services, and conversely, no legal client of the law firm is obligated to use our advisory services. The law firm's legal services do not include the authority to sign checks or otherwise disburse funds on any of our clients' behalf. Insurance Company or Agency Certain of our Investment Adviser Representatives may be licensed insurance agents or brokers and may be appointed with several insurance companies. They may earn separate compensation for transactions implemented through various insurance companies, which is then directed to the Firm. Clients are not obligated to use any company for insurance product purchases and may work with any insurance agent they choose. Insurance compensation will be separate and distinct from our investment advisory fees. Other Investment Advisors We do not recommend or select other investment advisors for our clients. 18  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Our employees must comply with a Code of Ethics and Statement for Insider Trading (the “Code”). The Code describes our high standard of business conduct, and fiduciary duty to our clients. The Code’s key provisions include: • Statement of General Principles • Policy on and reporting of Personal Securities Transactions • A prohibition on Insider Trading • Restrictions on the acceptance of significant gifts • Procedures to detect and deter misconduct and violations • Requirement to maintain confidentiality of client information Our employees must acknowledge the terms of the Code at least annually, and any employee not in compliance with the Code may be subject to termination. We will provide a copy of our Code upon request. Participation or Interest in Client Transactions – Personal Securities Transactions Both the Firm and our employees may buy or sell securities identical to those recommended to clients for their personal accounts. The Code, described above, is designed to assure that the personal securities transactions, activities, and interests of the employees of the Firm will not interfere with (i) making decisions in the best interest of clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code certain classes of securities, primarily mutual funds, have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of our clients. In addition, the Code requires pre-clearance of many transactions. The Firm may maintain a list of restricted securities that employees may not purchase or sell based upon having (or possibly having) access to inside information. Employee trading is continually monitored under the Code and designed to reasonably prevent conflicts of interest between the Firm and our clients. Participation or Interest in Client Transactions and Principal/Agency Cross Trades We do not recommend any securities to our clients in which we have a material financial interest. We do not affect any principal or agency cross securities transactions for client accounts. We also do not cross trades between client accounts. Participation or Interest in Client Transactions – Aggregation Neither we nor our employees aggregate (block) trades with clients. 19  Item 12: Brokerage Practices Research and Other Soft Dollar Benefits We have no written or verbal arrangements whereby we receive soft dollars. Brokerage for Client Referrals We do not receive client referrals from broker/dealers. Client Directed Brokerage We do not allow directed brokerage accounts. Directed Brokerage (Broker/Dealer) We generally recommend Charles Schwab & Co., a member of FINRA/SIPC, and independent and unaffiliated broker-dealer (Broker/Dealer). Each Broker/Dealer provides us with access to its institutional trading and custody services, which are typically not available to retail investors. These services generally are available to independent investment advisors on an unsolicited basis and are not otherwise contingent upon our commitment to the Broker/Dealer for any specific amount of business (assets in custody or trading). Each Broker/Dealer’s services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For our client accounts maintained there, each Broker/Dealer is compensated through commissions or other transaction-related fees for securities trades that are executed through the Broker/Dealer or that settle into Broker/Dealer accounts. The brokerage commissions and/or transaction fees charged by the Broker/Dealer are exclusive of and in addition to our fees. Directed Brokerage – Other Economic Benefits We may receive from Broker/Dealers, at no cost to us, professional services, computer software and related systems support, enabling us to better monitor client accounts maintained at the Broker/Dealer. We may receive this support without cost because of the portfolio management services rendered to clients that maintain assets at the Broker/Dealer. The support provided may benefit us, but not our clients directly. In fulfilling our duties to our clients, we endeavor at all times to put the interests of our clients first. Clients should be aware, however, that our receipt of economic benefits from a broker-dealer may create a conflict of interest since these benefits may influence our choice of broker-dealer over another broker- dealer that does not furnish similar services, software, and systems support. The commissions paid by our clients shall comply with our duty to obtain “best execution.” However, a client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where we determine, in good faith, that the commission is reasonable in relation to the value of the brokerage and research services 20  received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including among others, the value of research provided, execution capability, commission rates, and responsiveness. Consistent with the foregoing, while we will seek competitive rates, we may not necessarily obtain the lowest possible commission rates for client transactions. Broker/Dealers also make available to us other products and services that benefit us but may not directly benefit our clients’ accounts. Many of these products and services may be used to service all or some substantial number of our accounts, including accounts not maintained at the Broker/Dealer. The Broker/Dealer products and services that assist us in managing and administering clients’ accounts include software and other technology that (i) provide access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of our fees from our clients’ accounts; and (v) assist with back-office functions, recordkeeping and client reporting. Trade Aggregation We may aggregate trades for multiple accounts. Trade aggregation is the act of trading a large block of a security in a single order. Shares of a purchased security are then allocated to the appropriate accounts in the appropriate proportion. The main purposes of order aggregation are (i) for ease of trading and (ii) to obtain a lower transaction cost associated with trading a larger quantity. Orders for the same security entered on behalf of more than one client may be aggregated (i.e., blocked or bunched) subject to the aggregation being in the best interests of all participating clients. If the order is filled at different prices during the day, the prices are averaged for the day so that all participating accounts receive the same price. If an order has not been filled completely so that there are not enough shares to allocate among all the clients equally, shares will be allocated in good faith, based on the following considerations: amount of cash in the account, existing asset allocation and industry exposure, risk profile, and type of security. If a partial execution is attained at the end of the trading day, we will generally allocate shares on a pro rata basis but may fill small orders entirely before applying the pro rata allocation. All clients participating in each aggregated order shall receive the average price and subject to minimum ticket charges, pay a pro-rata portion of commissions. Our allocation procedure seeks to be fair and equitable to all clients with no particular group or client(s) being favored or disfavored over any other clients. Accounts for us or our employees will not be included in a block trade with client accounts. 21  Item 13: Review of Accounts Reviews We monitor client portfolios as part of an ongoing process, and regular account reviews are generally conducted on a quarterly basis. Reviews could also occur at the time of new deposits, material changes in the client’s financial information, changes in economic cycles, at our discretion, or as often as the client directs. Reviews entail analyzing securities, sensitivity to overall markets, economic changes, investment results, asset allocation, etc., to ensure the investment strategy and expectations are structured to continue to meet the client’s objectives. These reviews are conducted by one of our Investment Adviser Representatives. Clients are encouraged to discuss their needs, goals, and objectives with us and to inform us of any changes. Reporting At least quarterly, the custodian provides clients with an account statement for each client account, which may include individual holdings, cost basis information, deposits, and withdrawals, accrued income, dividends, and performance. We may also provide clients periodic reports regarding their holdings, allocations, and performance. Financial Planning – Reviews and Reporting The initial financial plan is included as a component of the financial planning service. Clients may receive updated financial plans for a separate fee. 22  Item 14: Client Referrals and Other Compensation Other Compensation – Brokerage Arrangements See disclosure in Item 12 regarding compensation, including economic benefits received in connection with giving advice to clients. Compensation – Client Referrals We maintain and from time to time enter into contractual third-party promoter agreements with certain affiliated and unaffiliated parties who refer clients to us. These parties can also be our clients, but most are not clients of the Firm’s . We, in turn, compensate these parties for any such referrals based on the assets that are managed by us arising from such referral. The persons or entities providing the third-party promoter services are commonly known as “third- party promoters.” Where the third-party promoter is a client of ours at the time of the referral, they provide a paid “testimonial,” as such term is defined in Rule 206(4)-1 of the Investment Advisers Act of 1940 (the “Advisers Act”), when referring clients to us. Where the third-party promoter is not a client of ours at the time of the referral, they provide a paid “endorsement,” as such term is defined in Rule 206(4)-1 of the Advisers Act, when referring clients to us. All third-party promoter agreements are made in writing, pursuant to, and in accordance with Rule 206(4)-1 of the Advisers Act. We may enter into written arrangements to receive cash referral fees from individuals or entities to whom we recommend prospective clients. In these cases, there will be a written agreement between us as a Promoter and the other individual/entity which clearly defines the duties and responsibilities of the Firm under this arrangement. In addition, we will provide a written disclosure document, which explains to the prospective client the terms under which they are working with the individual/entity and the fact that we are being compensated for the referral activities. 23  Item 15: Custody Custody – Fee Debiting Clients may authorize us (in the client agreement) to debit fees directly from their account at the broker dealer, bank, or other qualified custodian (“custodian”). The custodian is advised in writing of the limitation of our access to the account. The custodian sends a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of advisory fees paid directly to the Firm. Custody – First Party Money Transfers Clients may provide us with written ongoing authorization to wire money between the client’s accounts held with the custodian directly to an outside financial institution (i.e., a client’s bank account). A copy of this authorization is provided to the custodian. The authorization includes the client’s account number(s) at the outside financial institution(s) as required. Custody – Account Statements Clients receive at least quarterly statements from the custodian that holds and maintains client’s investment assets. Clients are urged to carefully review such statements and compare such official custodial records to the reports that we provide. Our reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. 24  Item 16: Investment Discretion We accept limited power of attorney to act on a discretionary basis on behalf of clients. A limited power of attorney allows us to execute trades on behalf of clients. When such limited powers exist between the Firm and the client, we have the authority to determine, without obtaining specific client consent, both the amount and type of securities to be bought to satisfy client account objectives. If we have not been given discretionary authority, we consult with the client prior to each trade. 25  Item 17: Voting Client Securities Proxy Voting We do not have any authority to and do not vote proxies on behalf of clients, nor do we make any express or implied recommendation with respect to voting proxies. Clients retain the sole responsibility for receiving and voting proxies that they receive directly from either their custodian or transfer agents. Clients may contact us for information about proxy voting. 26  Item 18: Financial Information We have no financial commitments that impair our ability to meet contractual and fiduciary commitments to clients and we have not been the subject of a bankruptcy proceeding. We do not require prepayment of fees of both more than $1,200 per client, and more than six months in advance; and therefore, we are not required to provide a balance sheet to clients. 27  Form ADV Part 2B – Investment Adviser Brochure Supplement Vestment Financial LLC dba MD Financial Advisors Form ADV Part 2B Investment Adviser Brochure Supplement 7935 Stone Creek Dr., Suite 120 Chanhassen, MN 55317 (888) 256-6855 www.mdfinancialadvisors.com Katherine Vessenes, JD, CFP® March 2025 This Brochure Supplement provides information about the Firm’s (“we,” “us,” “our”) employees that supplements our Brochure. You should have received a copy of that Brochure. Please contact Katherine Vessenes, JD, CFP®, Chief Executive Officer and Chief Compliance Officer at (888) 256-6855 or info@mdfinancialadvisors.com if you did not receive our Brochure or if you have any questions about the contents of this Supplement. Additional information about our employee(s) referenced above is also available on the SEC’s website at www.adviserinfo.sec.gov. You may search this site using a unique identifying number, known as a CRD number for each employee. 28  Item 2: Educational Background and Business Experience We require that employees that provide investment advice have a bachelor's degree and further coursework demonstrating knowledge of financial planning and tax planning. Examples of acceptable coursework include: an MBA, a CFP®, a CFA®, a ChFC®, JD, CTFA, EA or CPA. Additionally, advisers must have work experience that demonstrates their aptitude for financial planning and investment management. 1949 Katherine Vessenes CRD #: 1320580 2013 to Present Business Background: Vestment Financial, LLC Chief Executive Officer and Chief Compliance Officer Formal Educational after High School: University of Denver Juris Doctorate University of Denver Bachelor of Arts in Mass Communications Professional Designations: CERTIFIED FINANCIAL PLANNER™ (CFP®) Professional Certifications Katherine Vessenes maintains a professional designation, which requires the following minimum requirement: CERTIFIED FINANCIAL PLANNER™ (CFP®) Issued By Certified Financial Planner Board of Standards, Inc. Candidate must meet the following requirements: • A bachelor’s degree (or higher) from an accredited college Prerequisites or university, and • 3 years of full-time personal financial planning experience Candidate must complete a CFP®-board registered program, or hold one of the following: Education Requirements • CPA • ChFC® • Chartered Life Underwriter® (CLU®) • CFA® • Ph.D. in business or economics • Doctor of Business Administration 29  • Attorney's License CFP® Certification Examination 30 hours every 2 years Exam Type Continuing Education Requirements Item 3 - Disciplinary Information Katherine Vessenes has not been involved in any activities resulting in a disciplinary disclosure. Item 4 - Other Business Activities Katherine Vessenes, JD, CFP®, Principal and Chief Compliance Officer of MD Financial Advisors / Vestment Financial is also a licensed insurance agent. Implementation of insurance recommendations may be done separate and apart from her role with the firm. As an insurance agent, Katherine Vessenes may receive customary commissions and other related revenues from the various insurance companies whose products are sold. Commissions generated by insurance sales do not offset regular advisory fees. This may cause a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by Katherine Vessenes or the firm. In addition to her duties at the firm, Katherine Vessenes is an associate attorney for Messerli and Kramer, a local law firm. In certain circumstances, Katherine Vessenes may refer clients to this law firm for legal services and may receive compensation based on these referrals, as well as compensation for services she provides through the law firm. Advisory Clients of MD Financial Advisors / Vestment Financial are under no obligation to use this law firm. Katherine Vessenes is President and Co-Owner of Vestment Consulting, Inc. (DBA Vestment Advisors), a non-investment related consulting firm, which provides training and consulting services primarily in the financial services industry. These outside business activities do not create a material conflict of interest with clients. Item 5 - Additional Compensation Katherine Vessenes does not receive any economic benefit outside of regular salaries or bonuses. Item 6 - Supervision Katherine Vessenes, JD, CFP®, Principal and Chief Compliance Officer, supervises all persons named in this Form ADV Part 2B Investment Adviser Brochure Supplement. Katherine Vessenes 30  supervises these persons by holding regular staff, investment, and other ad hoc meetings. In addition, Katherine Vessenes regularly reviews client reports, emails, and trading, as well as employees’ personal securities transaction and holdings reports. Katherine Vessenes may be reached at (888) 256-6855. 31  Vestment Financial LLC dba MD Financial Advisors Form ADV Part 2B Investment Adviser Brochure Supplement 7935 Stone Creek Dr., Suite 120 Chanhassen, MN 55317 (888) 256-6855 www.mdfinancialadvisors.com Josh B. Lantz March 2025 This Brochure Supplement provides information about the Firm’s (“we,” “us,” “our”) employees that supplements our Brochure. You should have received a copy of that Brochure. Please contact Katherine Vessenes, JD, CFP®, Chief Executive Officer and Chief Compliance Officer at (888) 256-6855 or info@mdfinancialadvisors.com if you did not receive our Brochure or if you have any questions about the contents of this Supplement. Additional information about our employee(s) referenced above is also available on the SEC’s website at www.adviserinfo.sec.gov. You may search this site using a unique identifying number, known as a CRD number for each employee. 32  Item 2: Educational Background and Business Experience We require that employees that provide investment advice have a bachelor's degree and further coursework demonstrating knowledge of financial planning and tax planning. Examples of acceptable coursework include: an MBA, a CFP®, a CFA®, a ChFC®, JD, CTFA, EA or CPA. Additionally, advisers must have work experience that demonstrates their aptitude for financial planning and investment management. 1983 Josh B. Lantz CRD #: 4974172 2013 to Present Business Background: Vestment Financial, LLC Chief Investment Officer, Financial Advisor Formal Educational after High School: Iowa State University Bachelor of Science in Business Finance Professional Designations: Chartered Retirement Planning Counselor℠ (CRPC®) Professional Certifications Josh B. Lantz maintains a professional designation, which requires the following minimum requirements: Chartered Retirement Planning Counselor℠ (CRPC®) College for Financial Planning None Candidate must complete the online instructor led or self-study course Final designation exam (online, timed) 16 hours every 2 years Issued By Prerequisites Education Requirements Exam Type Continuing Education Requirements Item 3 - Disciplinary Information Josh B. Lantz has not been involved in any activities resulting in a disciplinary disclosure. Item 4 - Other Business Activities Josh B. Lantz is a licensed insurance agent. Implementation of insurance recommendations may 33  only be made pursuant to his role at the Firm. Clients are under no obligation to implement any recommendations made by Josh B. Lantz or the firm. This outside business activity does not create a material conflict of interest with clients. Item 5 - Additional Compensation Josh B. Lantz does not receive any economic benefit outside of regular salaries or bonuses. Item 6 - Supervision Katherine Vessenes, Principal and Chief Compliance Officer, supervises the person named in this Form ADV Part 2B Investment Adviser Brochure Supplement. Katherine Vessenes supervises this person by holding regular staff, investment, and other ad hoc meetings. In addition, Katherine Vessenes regularly reviews client reports, emails, and trading, as well as employees’ personal securities transaction and holdings reports. Katherine Vessenes may be reached at (888) 256-6855. 34  Vestment Financial LLC dba MD Financial Advisors Form ADV Part 2B Investment Adviser Brochure Supplement 7935 Stone Creek Dr., Suite 120 Chanhassen, MN 55317 (888) 256-6855 www.mdfinancialadvisors.com/ Benjamin D. Kirchner March 2025 This Brochure Supplement provides information about the Firm’s (“we,” “us,” “our”) employees that supplements our Brochure. You should have received a copy of that Brochure. Please contact Katherine Vessenes, JD, CFP®, Chief Executive Officer and Chief Compliance Officer at (888) 256-6855 or info@mdfinancialadvisors.com if you did not receive our Brochure or if you have any questions about the contents of this Supplement. Additional information about our employee(s) referenced above is also available on the SEC’s website at www.adviserinfo.sec.gov. You may search this site using a unique identifying number, known as a CRD number for each employee. 35  Item 2: Educational Background and Business Experience We require that employees that provide investment advice have a bachelor's degree and further coursework demonstrating knowledge of financial planning and tax planning. Examples of acceptable coursework include: an MBA, a CFP®, a CFA®, a ChFC®, JD, CTFA, EA or CPA. Additionally, advisers must have work experience that demonstrates their aptitude for financial planning and investment management. 1990 Benjamin D. Kirchner CRD #: 6552364 2019 to Present Business Background: Vestment Financial, LLC Associate Financial Advisor, Client Service Manager Formal Educational after High School: University of Wisconsin - La Crosse Bachelor of Arts in Communication Studies Normandale Community College Associate of Arts in Communication Item 3 - Disciplinary Information Benjamin D. Kirchner has not been involved in any activities resulting in a disciplinary disclosure. Item 4 - Other Business Activities Benjamin D. Kirchner is a licensed insurance agent. Implementation of insurance recommendations may only be made pursuant to his role at the Firm. Clients are under no obligation to implement any recommendations made by Benjamin D. Kirchner or the firm. This outside business activity does not create a material conflict of interest with clients. Item 5 - Additional Compensation Benjamin D. Kirchner does not receive any economic benefit outside of regular salaries or bonuses. 36  Item 6 - Supervision Katherine Vessenes, JD, CFP®, Principal and Chief Compliance Officer, supervises the person named in this Form ADV Part 2B Investment Adviser Brochure Supplement. Katherine Vessenes supervises this person by holding regular staff, investment, and other ad hoc meetings. In addition, Katherine Vessenes regularly reviews client reports, emails, and trading, as well as employees’ personal securities transaction and holdings reports. Katherine Vessenes may be reached at (888) 256-6855. 37  Vestment Financial LLC dba MD Financial Advisors Form ADV Part 2B Investment Adviser Brochure Supplement 7935 Stone Creek Dr., Suite 120 Chanhassen, MN 55317 (888) 256-6855 www.mdfinancialadvisors.com Ian D. Schneider March 2025 This Brochure Supplement provides information about the Firm’s (“we,” “us,” “our”) employees that supplements our Brochure. You should have received a copy of that Brochure. Please contact Katherine Vessenes, JD, CFP®, Chief Executive Officer and Chief Compliance Officer at (888) 256-6855 or info@mdfinancialadvisors.com if you did not receive our Brochure or if you have any questions about the contents of this Supplement. Additional information about our employee(s) referenced above is also available on the SEC’s website at www.adviserinfo.sec.gov. You may search this site using a unique identifying number, known as a CRD number for each employee. 38  Item 2: Educational Background and Business Experience We require that employees that provide investment advice have a bachelor's degree and further coursework demonstrating knowledge of financial planning and tax planning. Examples of acceptable coursework include: an MBA, a CFP®, a CFA®, a ChFC®, JD, CTFA, EA or CPA. Additionally, advisers must have work experience that demonstrates their aptitude for financial planning and investment management. 1997 Ian D. Schneider CRD #: 7206435 2019 to Present Business Background: Vestment Financial, LLC Investment Advisor Representative Formal Educational after High School: University of Minnesota, Duluth Bachelor’s Degree in Financial Planning Item 3 - Disciplinary Information Ian D. Schneider has not been involved in any activities resulting in a disciplinary disclosure. Item 4 - Other Business Activities Ian D. Schneider is a licensed insurance agent. Implementation of insurance recommendations may only be made pursuant to his role at the Firm. Clients are under no obligation to implement any recommendations made by Ian D. Schneider or the firm. This outside business activity does not create a material conflict of interest with clients. Item 5 - Additional Compensation Ian D. Schneider does not receive any economic benefit outside of regular salaries or bonuses. Item 6 - Supervision Katherine Vessenes, JD, CFP®, Principal and Chief Compliance Officer, supervises the person named in this Form ADV Part 2B Investment Adviser Brochure Supplement. Katherine Vessenes supervises this person by holding regular staff, investment, and other ad hoc meetings. In 39  addition, Katherine Vessenes regularly reviews client reports, emails, and trading, as well as employees’ personal securities transaction and holdings reports. Katherine Vessenes may be reached at (888) 256-6855. 40