WEBSTERROGERS FINANCIAL ADVISORS, LLC

Item 1 – Cover Page WebsterRogers Financial Advisors, LLC 1411 Second Loop Road Florence, SC 29505 (843) 665-6321 www.wrfasc.com March 05, 2025 This Brochure provides information about the qualifications and business practices of WebsterRogers Financial Advisors, LLC (WRFA). If you have any questions about the contents of this Brochure, please contact us at (843) 665-6321. 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. WRFA is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. Additional information about WRFA also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The CRD number for WRFA is 121006.  Item 2 – Material Changes This Item of the Brochure will discuss only specific material changes that are made to the Brochure since the last annual update and provide clients with a summary of such changes. The last annual update of our brochure was March 5, 2024. The following changes have been implemented since our last update: Item 13 has been updated to reflect WRFA practices around account reviews. Item 14 has been updated to reflect WRFA practices around compensating affiliated employees of WebsterRogers LLP as also disclosed in Item 10. Item 5 has been updated to further clarify billing on held away assets and intra-cycle inception. ****** (Brochure Date 03/05/2025) (Date of Last Annual Updating Amendment 03/05/2025) We will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Our Brochure may be requested by contacting Dana M. Jones, Chief Compliance Officer, at (843) 665-5900, ext. 1254. Additional information about WRFA is also available via the SEC’s web site, www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with WRFA who are registered, or are required to be registered, as investment adviser representatives of WRFA. 2  Item 3 - Table of Contents Item 1 – Cover Page .............................................................................................................................................. 1 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 ......................................... 10 Item 9 – Disciplinary Information ............................................................................................................... 13 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 .............................................................................................................................................. 17 Item 16 – Investment Discretion .................................................................................................................. 17 Item 17 – Voting Client Securities ................................................................................................................ 17 Item 18 – Financial Information ................................................................................................................... 17 3  Item 4 – Advisory Business WRFA is owned by Partners of the accounting firm WebsterRogers LLP and has been providing advisory services since 1999. As of December 31, 2024, WRFA managed $371,689,806 on a discretionary basis and $148,142 on a non-discretionary basis. Investment Management Services WRFA works with a client to determine the client's investment objectives and investor risk profile and implement a suitable investment plan. WRFA uses investment and portfolio allocation software to evaluate alternative portfolio designs. WRFA evaluates the client's existing investments with respect to the client's investment plan. WRFA works with new clients to develop a plan to transition from the client's existing portfolio to the portfolio recommended by WRFA. WRFA will then continuously monitor the client's portfolio holdings and the overall asset allocation strategy and hold regular review meetings with the client regarding the account as necessary. WRFA will typically create a portfolio of no-load mutual funds or exchange traded funds (ETFs) and at times will implement model portfolios if the models match the client's investment policy. WRFA will allocate the client's assets among various investments taking into consideration the client’s risk profile and investment objectives. WRFA primarily selects portfolios consisting of mutual funds and ETFs that incorporate the concepts of Modern Portfolio Theory. Client portfolios may also include individual equity and fixed income securities. WRFA manages client portfolios on a discretionary or nondiscretionary basis. A client may impose any reasonable restrictions on WRFA’s discretionary authority, including restrictions on the types of securities in which WRFA is permitted to invest client’s assets and on specific securities, which the client does not believe to be appropriate. In certain circumstances, clients already own individual securities. WRFA will monitor these securities and recommend their sale or retention, as appropriate. On an ongoing basis, WRFA will consult with clients as needed to address any client-specific issues, such as significant life events, changes in cash flow needs or any other matter that might affect portfolio allocation. WRFA will periodically, and at least annually, review client's investment goals and risk profile. Pursuant to its discretionary authority, in certain circumstances, WRFA will retain one or more third party managers (Subadvisors) to employ a specific investment strategy consistent with the client’s investment objectives. The Subadvisor will be provided with the discretionary authority to invest client assets in separately managed accounts (SMAs) that 4  are custodied separately from assets directly managed by WRFA. WRFA maintains its fiduciary responsibility over subadvised portfolios and is responsible for the due diligence and ongoing monitoring of any Subadvisors. The Subadvisor will charge a management fee for its services. For subadvised accounts, WRFA will offset its fee by the rate charged by the subadvisor, up to 100% of the management fee that would have been charged if the account was managed directly by WRFA. We utilize a third-party platform to facilitate the management of held-away assets in which we will have discretionary authority to implement tax-efficient asset allocation and opportunistic rebalancing strategies on behalf of the client. These are primarily 401(k) accounts, 529 Plans, HSAs and other assets which are held at third-party custodians, though other assets could also be included. We regularly review the available investment options in these accounts, monitor and rebalance and implement our strategies in the same way we do other accounts, though using different tools as necessary. WRFA is limited by the universe of investments offered by the custodian(s) for these held-away accounts. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the client allowing them to connect a held-away account(s) to the platform. Once the client’s account is connected to the platform, WRFA will review the current account allocations. We seek to align the client’s held-away account(s) with their overall investment time horizon, risk tolerance, and investment goals. When deemed necessary, WRFA will rebalance the account considering client’s investment profile, as well as changes in economic and market trends. In addition to managing the client’s investment portfolio, WRFA consults with clients on various financial areas including income and estate tax planning, business sale structures, college financing planning, retirement planning, insurance analysis, personal cash flow analysis, and establishment and design of retirement plans, among other things. These consultations are not specifically identified as contractual terms between the client and WRFA and will be provided as mutually deemed necessary by WRFA and the client. Investment Consulting/ Financial Planning Services WRFA offers investment consulting and/or financial planning services apart from the Investment Management Services listed above. Among other things, WRFA will work with clients to determine the client's investment objectives and investor risk profile, and will analyze the client's current investment program, making recommendations (including asset allocation models) where appropriate. Investment Consulting and Financial Planning Services provide advice on various financial planning topics as mutually deemed necessary by WRFA and a client. 5  Employee Benefit Retirement Plan Services WRFA also provides advisory services to the sponsors/plan fiduciaries of participant- directed retirement plans. WRFA will analyze the plan's current investment platform and assist the plan in creating an investment policy statement defining the types of investments to be offered and any restrictions imposed. WRFA will recommend investment options to achieve the plan's objectives, provide participant education meetings, and monitor the performance of the plan's investment vehicles. WRFA will recommend changes in the plan's investment vehicles as appropriate from time to time. WRFA will review the plan's investment vehicles and investment policy as necessary. WRFA will also assist the plan sponsor/trustee with selecting a third-party administrator for plan administration and assist the plan to coordinate activities with an administrator. WRFA will recommend one or more third party administrators that generally offer platforms enabling transactions in securities recommended by WRFA, and daily account access to participants. In certain circumstances, an attendee at a participant education meeting asks the WRFA person leading the session to address issues specific to that attendee's situation. The WRFA representative could then choose to privately address that person's questions. Any such specific advice will be provided to that participant only and at no charge, in the hope the participant would be interested in using WRFA's services. All such specific advice is entirely separate and distinct from the education services provided to pension plan participants by WRFA. WRFA will continue to work with plans to monitor plan investments, provide fiduciary plan advice including regular considerations of the goals and objectives of the plan, and provide participant education services to the plan. Item 5 – Fees and Compensation Investment Management Services The annual fee for investment management services will be charged as a percentage of assets under management, according to the schedule following: 6  Average Daily Balance of All Applicable Accounts Rates per Quarter* Rates Annualized First $500,000 On the next $500,000 ($500,001 to $1,000,000) On the next $2,000,000 ($1,000,001 to $3,000,000) On the next $2,000,000 ($3,000,001 to $5,000,000) Over $5,000,000 .337% .3125% .2500% .1875% .1250% 1.35% 1.25% 1.00% 0.75% 0.50% Rates per Quarter aggregate to determine the rates annualized. All accounts for members of the client’s immediate family (spouse and dependent children) or related businesses (non- fiduciary status accounts) may be assessed fees based on the total balance of all accounts. For client accounts held at a custodian that is not directly accessible by WRFA, such as held- away assets, WRFA can manage those assets via a third-party platform which allows WRFA to view and manage these assets in a discretionary manner. Held-away assets will be included in the client’s total assets subject to the fee in their agreement with WRFA. However, as it might not be possible to directly debit the fees from held-away accounts, those fees will be deducted from the client’s non-qualified accounts, pursuant to the client’s authorization, or the client will be billed directly. Assets held away are billed by one of two methods based on accessibility of daily pricing. If daily pricing of the asset is available, it is billed via average daily balance. Assets with daily pricing that is not accessible, are billed on the value of the account at the end of the calendar quarter. Based on client need and as contracted, these accounts will be billed in advance or in arrears. A minimum of $250,000 of assets under management is required for investment management services. A minimum of $250,000 is generally required for management services of portfolios of individual fixed income securities. A minimum annual fee of $3,375, which is the application of our fee schedule to $250,000 in assets under management, is required. Clients will be invoiced in advance at the beginning of each calendar quarter based upon the average daily market value of the client’s account during the previous quarter. The market value is based on independent third-party sources, or fair market value in the absence of market value. Client account balances on which WRFA calculates fees at times will vary from account custodial statements based on independent asset valuations and other accounting variances, including mechanisms for including accrued interest in account statements. Investment Consulting/ Financial Planning Services Clients will be billed an hourly rate for this service, ranging from $125 per hour to $250 per 7  hour, based on the nature and complexity of the client's situation. Fees are payable within 30 days of presentation of the bill to the client. Retirement Plan Services The annual fee for plan services will be charged as a percentage of assets within the plan as follows: Plan Assets WRFA’s Annual Fee Up to $1,000,000 $1,000,000 to $3,000,000 $3,000,000 to $5,000,000 Over $5,000,000 1.00% .75% .50% TBD Plans will be invoiced in advance at the beginning of each calendar quarter based upon the value (market value or fair market value in the absence of market value) of the client's account at the end of the previous quarter. New accounts are charged a prorated fee for the remainder of the quarter in which the account is incepted from the date WRFA begins management of the account through the last business day of the calendar quarter the account was opened.. A minimum of $250,000 of plan assets is required for participant-directed retirement plan services. A minimum fee of $2,500, which is the application of our fee schedule to $250,000 in plan assets, is required. General In certain circumstances, all fees, account minimums and their applications to family relationships are negotiable. In prior years, WRFA followed separate fee schedules, which remain in effect with clients who signed agreements with WRFA during such period and who have not agreed to an amended advisory fee schedule. WRFA requests authority from clients to receive quarterly payments directly from the client's account held by an independent custodian. In such cases, clients provide written limited authorization to WRFA to withdraw fees from the account via an Investment Management Agreement. Fees for certain 401(k) and pension plan clients using a third- party administrator (TPA) are calculated by the TPA rather than WRFA, and the TPA remits the fee to WRFA. A client agreement may be canceled at any time, by either party, for any reason upon receipt of 30 days written notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded and any earned, unpaid fees will be due and payable. In the 8  case where a stand alone Investment Consulting/Financial Planning client becomes a client under Investment Management Services, previously paid Investment Consulting fees will be refunded to clients within 30 days of the client engaging in an Investment Management Agreement. All fees paid to WRFA for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and ETFs to their shareholders. These fees and expenses are described in each fund's prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. A client could invest in mutual funds or ETFs directly, without the services of WRFA. In that case, the client would not receive the services provided by WRFA which are designed, among other things, to assist the client in determining which mutual fund or 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 WRFA to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. WRFA’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients incur certain charges imposed by custodians, brokers, and other third parties such as 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. Such charges, fees and commissions are exclusive of and in addition to WRFA’s fee, and WRFA shall not receive any portion of these commissions, fees, and costs. Item 6 – Performance-Based Fees and Side-By-Side Management WRFA does not charge any performance-based fees (fees based on a share of capital gains or capital appreciation of the assets of a client). All fees are calculated as described above and are not charged on the basis of income or capital gains or capital appreciation of the funds or any portion of the funds of an advisory client. Item 7 – Types of Clients WRFA manages investment portfolios for individuals, qualified retirement plans, trusts, charitable organizations and small businesses. WRFA requires a minimum account of $250,000 for investment management services and participant-directed retirement plan services. These account sizes are negotiable under certain circumstances. 9  Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategy WRFA's services are based on long-term investment strategies incorporating the principles of Modern Portfolio Theory. WRFA's investment approach is firmly rooted in the belief that markets are "efficient" over periods of time and that investors' long-term returns are determined principally by asset allocation decisions, rather than market timing or stock picking. WRFA selects or recommends diversified portfolios of securities to clients, principally open-end mutual funds, exchange traded funds (ETF’s) or investment-grade fixed income securities to implement this investment strategy. Although all investments involve risk, WRFA's investment advice seeks to limit risk through broad diversification among asset classes and, as appropriate for particular clients, the direct investment in fixed income securities to represent the fixed income class. WRFA's investment philosophy is designed for investors who desire a disciplined, long-term investment strategy. Frequent trading of securities increases brokerage and other transaction costs that WRFA's strategy seeks to minimize. In implementing investment plans, WRFA therefore primarily uses mutual funds, ETFs and, as appropriate, portfolios of investment-grade fixed income securities. Where appropriate, WRFA also utilizes preferred stocks and investment-grade variable-rate debt instruments. At times, clients will also hold or direct the purchase of other types of assets, such as individual common stocks, variable annuities and other securities, and, subject to client agreement, WRFA offers advice regarding those various assets as part of its services. WRFA conducts its research and due diligence using a variety of sources, including third- party commercial sources, mutual fund or ETF sponsors’ proprietary research and research from academic and institutional sources. Analysis of a Client’s Financial Situation In the development of investment plans for clients, including the recommendation of an appropriate asset allocation, WRFA relies on an analysis of the client’s financial objectives, current and estimated future resources, and tolerance for risk. To derive a recommended asset allocation, WRFA uses financial planning software, a Risk Tolerance Questionnaire and Monte Carlo simulation, a statistical model used to estimate the possible portfolio outcomes. As with any method used to make projections into the future, there are several risks and limitations associated with these methods, which may result in the client not being able to achieve their financial goals. They include: 10  • • • • The risk that expected future cash flows will not match those used in the analysis; The risk that future rates of return will fall short of the estimates used in the simulation; The risk that inflation will exceed the estimates used in the simulation; and For taxable clients, the risk that tax rates will be higher than was assumed in the analysis. Fixed Income Securities As described above, where appropriate, WRFA recommends portfolios of fixed income securities. In selecting securities for such a portfolio, WRFA considers a client’s investment time horizon, cash flow needs and risk tolerance to select securities that meet such characteristics. For example, WRFA evaluates a fixed income security’s interest rate, payment schedule, time to maturity, price and credit rating when considering an investment. Investing in fixed income securities presents certain risks, in addition to the general securities risks discussed below, including the effect of market interest rates on the value of the security, the risk of the default of the issuer, potential limited liquidity and the impact of ratings changes on the value of the security. If permitted by the client’s Investment Policy Statement, WRFA invests in lower rated investment grade bonds and continue to hold fixed income securities that are rated below investment grade. Such securities, often called “high yield” or “junk” bonds, present a greater risk of default than higher rated securities. Investing in securities involves risk of loss that clients should be prepared to bear. Risk of Loss All investments present the risk of loss of principal – the risk that the value of securities, when sold or otherwise disposed of, is less than the price paid for the securities. Even when the value of the securities when sold is greater than the price paid, there is the risk that the appreciation will be less than inflation. In other words, the purchasing power of the proceeds may be less than the purchasing power of the original investment. At various times in the past, volatile market conditions have had a dramatic effect on the value of securities. In addition, terrorist attacks, other acts of violence or war, health epidemics or pandemics, natural hazards, and/or force majeure affect the operations and profitability of an issuer. Such events also could cause consumer confidence and spending to decrease or result in increased volatility in the U.S. and worldwide financial markets and economy. Any of these occurrences could have a significant impact on the operating results and revenues of an issuer. The mutual funds and ETFs utilized by WRFA include funds invested in domestic and 11  international equities, including real estate investment trusts (REITs), corporate and government fixed income securities and commodities. Equity securities include large capitalization, medium capitalization and small capitalization stocks. Mutual fund and ETF shares invested in fixed income securities are subject to the same interest rate, inflation and credit risks associated with the underlying bond holdings. Among the riskiest mutual funds used in WRFA’s investment strategies are funds investing in international securities (including emerging markets), small capitalization companies and commodities futures. Conservative fixed income securities have lower risk of loss of principal, but most bonds present the risk of loss of purchasing power through lower expected return. Certain funds utilized by WRFA contain international securities. Investing outside the United States involves additional risks, such as currency fluctuations, periods of illiquidity and price volatility. These risks may be greater with investments in developing countries. More information about the risks of any particular market sector can be reviewed in the prospectus for each mutual fund in which a client invests. Cybersecurity Risk The computer systems, networks and devices used by WebsterRogers and our service providers to carry out routine business operations employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks, or devices potentially can be breached. A client could be negatively impacted as a result of a cybersecurity breach. Cybersecurity breaches can include unauthorized access to systems, networks, or devices; infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow, or otherwise disrupt operations, business processes, or website access or functionality. Cybersecurity breaches cause disruptions and impact business operations, potentially resulting in financial losses to a client; impediments to trading; the inability by us and other service providers to transact business; violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs; as well as the inadvertent release of confidential information. Similar adverse consequences could result from cybersecurity breaches affecting issuers of mutual funds, ETFs and other securities in which a client invests; governmental and other regulatory authorities; exchange and other financial market operators, banks, brokers, 12  dealers, and other financial institutions; and other parties. In addition, substantial costs are be incurred by these entities in order to prevent any cybersecurity breaches in the future. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of WRFA or the integrity of WRFA’s management. WRFA has no information applicable to this Item. Item 10 – Other Financial Industry Activities and Affiliations WRFA is affiliated with the accounting firm WebsterRogers LLP (WR). Certain members and employees of WRFA are also partners and employees of WR. WRFA has agreements with WR partners and employees who are not otherwise involved in the business of WRFA (WR Personnel) to compensate them with a portion of the advisory fees received by WRFA for new clients in the first year of an advisory relationship. To be eligible to receive such fees, WR Personnel must also adhere to WRFA’s Code of Ethics and provide referrals of accounting clients or other persons to WRFA . Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading WRFA has adopted a Code of Ethics expressing the firm's commitment to ethical conduct. WRFA's Code of Ethics describes the firm's fiduciary duties and responsibilities to clients and sets forth WRFA's practice of supervising the personal securities transactions of employees with access to client information. Individuals associated with WRFA are permitted to buy or sell securities for their personal accounts identical or different than those recommended to clients. It is the expressed policy of WRFA that no person employed by the firm shall prefer his or her own interest to that of an advisory client or make personal investment decisions based on investment decisions of advisory clients. To supervise compliance with its Code of Ethics, WRFA requires that anyone associated with this advisory practice with access to advisory recommendations provide annual securities holding reports and quarterly transaction reports to the firm's Chief Compliance Officer (“CCO”). WRFA also requires such access persons to receive approval from the CCO prior to investing in any IPOs or private placements (limited offerings). WRFA's Code of Ethics further includes the firm's policy prohibiting the use of material non- public information and protecting the confidentiality of client information. WRFA requires that all individuals must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. Any individual not in observance of the 13  above will be subject to discipline. WRFA will provide a complete copy of its Code of Ethics to any client or prospective client upon request. Item 12 – Brokerage Practices With respect to client portfolios managed on a discretionary basis, WRFA will have the client’s written authority to determine which securities are to be bought and sold on a client’s behalf, the amount of the securities to be bought and sold, the timing of such transactions, and (absent specific client direction) the broker to be used for executing the transaction(s). WRFA’s discretion is based upon a “limited trading authorization agreement” that the client approves when the client’s account is opened, or when WRFA is added as adviser to an existing account. All existing and new accounts are registered in the name of the client, not WRFA. WRFA participates in the Schwab Advisor Services (SAS) program offered to independent investment advisers by Charles Schwab & Company, Inc. (Schwab), member FINRA/SIPC. Schwab is an unaffiliated SEC registered broker-dealer. The Schwab brokerage program will generally be recommended to advisory clients for custody and brokerage services. WRFA regularly reviews this program to ensure that its recommendation is consistent with its fiduciary duty. This trading platform is essential to WRFA's service arrangements and capabilities, and WRFA reserves the ability to not accept clients who direct the use of other brokers. As part of these programs, WRFA receives benefits that it would not receive if it did not offer investment advice (See the disclosure under Item 14 of this Brochure). Not all investment advisers require clients to direct the use of specific brokers. Schwab generally does not charge clients a custody fee and is compensated by account holders through commissions or other transaction-related fees for securities trades that are executed through the broker or that settle into the clients' accounts at the broker. Trading client accounts through other brokers may result in fees (including mark-ups and mark- downs) being charged by Schwab and an additional broker. WRFA also does not have any arrangements to compensate any broker dealer for client referrals. WRFA does not maintain any client trade error gains. WRFA makes clients whole with respect to any trade error losses incurred by client and caused by WRFA. WRFA will aggregate client transactions when the aggregated (block) trade would reduce transaction costs for the participating clients. Aggregated (block) transactions are typically limited to individual securities and exchange-traded funds. 14  WRFA anticipates that client transactions will receive best execution by arranging all transactions with Schwab. WRFA regularly considers and evaluates Schwab’s services and costs to determine that use of the provider is in client’s best interests. WRFA considers a number of factors, including but not limited to, execution capability, experience and financial stability, reputation, and the quality of services provided. Investment Consulting/ Financial Planning Services WRFA will, if requested by the client, assist the client in the selection of a broker. Recommendations are made based on several factors, including (but not limited to) the broker's reputation, commission cost, the ability of the broker to provide any specialized services required by the client, and WRFA's experience with the broker. Except for the benefits received from Schwab described below, WRFA receives no benefits from any recommended broker-dealer. Retirement Plan Services WRFA can arrange for the execution of securities transactions for participant directed retirement plans as a part of this service. However, most transactions are executed directly through employee plan participation and a third-party administrator. Item 13 – Review of Accounts Reviews are tailored to the services WRFA provides you, as well as individual needs and goals. We encourage you to discuss your needs, goals, and objectives with your investment professional and keep WRFA informed of any changes. For ongoing investment advisory services, WRFA will contact you at least annually to determine whether there have been any changes to your financial situation or investment objectives and whether you wish to impose any reasonable restrictions on the management of your account or reasonably modify any existing restrictions. At this time, we will advise you of any account changes we feel are necessary to help you stay on track with meeting your financial goals and consider whether the current services provided by our firm continue to be suitable for your needs. Investment Investment Management Services Accounts at WRFA are reviewed on a periodic basis. This informal review includes assessing client goals and objectives, monitoring the account, and addressing the need to rebalance, as necessary. Individual securities held in client accounts are periodically monitored by the firm, while any selected third-party managers are monitored on a periodic basis. Accounts are reviewed in the context of each client’s stated investment objectives and guidelines. More frequent reviews may be triggered by material changes to a client’s individual circumstances, market conditions, or the political or economic environment. 15  Consulting/ Financial Planning Services Clients have their accounts reviewed as contracted for in the advisory agreement. Retirement Plan Services Retirement Plan assets are reviewed on a quarterly basis, and according to the standards and situations described above for investment management accounts. Reports Investment Management and Retirement Plan Services clients will receive quarterly performance reports that summarize the client's account and asset allocation. Clients will also receive statements from qualified account custodians. Investment Consulting clients will receive any reports contracted for in the advisory agreement. Item 14 – Client Referrals and Other Compensation As indicated under the disclosure for Item 12, Schwab provides WRFA with access to services which are not available to retail investors. These services generally are available to independent investment advisors on an unsolicited basis at no charge to them. These services benefit WRFA but may not benefit its clients' accounts. Many of the products and services assist WRFA in managing and administering clients' accounts. These include software and other technology that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of WRFA's fees from its clients' accounts, and assist with back-office functions, recordkeeping and client reporting. Many of these services generally may be used to service all or a substantial number of WRFA's accounts. Recommended brokers also make available to WRFA other services intended to help WRFA manage and further develop its business enterprise. These services vary and include consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, and marketing. WRFA does not enter into any commitments with the brokers for transaction levels in exchange for any services or products from brokers. WRFA also receives marketing and other materials used in communicating with current and prospective clients from Fund families in which we invest client assts. These institutions also provide continuing education for WRFA personnel. These services are designed to assist WRFA plan and design its services for business growth. WRFA does not consider these benefits when investing client assets. 16  As disclosed in Item 10, WRFA is affiliated with the accounting firm WebsterRogers LLP (WR). Certain members and employees of WRFA are also partners and employees of WR. WRFA has agreements with WR partners and employees who are not otherwise involved in the business of WRFA (WR Personnel) to compensate them with a portion of the advisory fees received by WRFA for new clients in the first year of an advisory relationship. To be eligible to receive such fees, WR Personnel must also adhere to WRFA’s Code of Ethics and provide referrals of accounting clients or other persons to WRFA . Item 15 – Custody Clients should receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains client’s investment assets. WRFA urges you to carefully review such statements and compare such official custodial records to the account statements that we provide to you. Our statements at times will vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Item 16 – Investment Discretion For discretionary accounts, WRFA requests that it be provided with written authority to determine which securities and the amounts of securities that are bought or sold. Any limitations on this discretionary authority shall be included in this written authority statement. Clients change/amend these limitations as required. Such amendments shall be submitted in writing. Item 17 – Voting Client Securities As a matter of firm policy and practice, WRFA does not have any authority to and does not vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Clients will receive applicable proxies directly from the issuer of securities held in clients’ investment portfolios. WRFA will provide advice to clients regarding the clients’ voting of proxies on request of the client. In certain limited circumstances, clients have granted WRFA authority to submit corporate actions on the client's behalf. The firm documents all corporate action decisions and its affirmation that any conflicts have been addressed prior to acting. Item 18 – Financial Information Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about WRFA’s financial condition. WRFA has no 17  financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. 18