Item 5: Additional Compensation ............................................................................. 20 Item 6: Supervision .................................................................................................. 20 Firm Description As used in this Firm Brochure, “FOCUS” refers to the entity Focus Wealth Planning, Inc. FOCUS was established in August 2018 and the principal owner of FOCUS is the Revocable Declaration of Trust for Jon L. Aldrich, Jon L. Aldrich trustee. Prior to the acquisition by FOCUS, Focus Financial Advisors, Inc. was in existence since 1984. Jon was an employee and principal of Focus Financial Advisors, Inc. from December 2004 to July 2018, and served as its president since April 2015. FOCUS provides personalized investment management, investment advice and financial planning services to individuals, trusts, estates, charitable organizations, and small businesses. Advice is provided through consultation with the client and may include identification of financial goals and objectives, gathering relevant details, analyzing the information to formulate a plan, recommending a financial plan, implementing recommendations, and monitoring the plan. FOCUS is strictly a fee-only financial planning and investment management firm. The firm does not sell commission-based securities. No commissions in any form are accepted. No finder’s fees are accepted. FOCUS does not provide tax and/or legal advice. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. Conflicts of interest will be disclosed to the client in the unlikely event they should occur. The initial meeting is free of charge and is considered an exploratory interview to determine the extent to which financial planning and investment management may be beneficial to the client. Types of Advisory Services FOCUS provides financial planning and investment advisory services, as more fully described below. FOCUS’ services are tailored to the individual needs of clients. FOCUS assists clients in determining their financial goals and objectives and creating a financial plan and investment program that will help them reach these goals. FOCUS will either implement the investment strategy utilizing the services of an unaffiliated investment manager and/or through its internal investment management. FOCUS may recommend the investment sub-advisory services of Congress Wealth Management, LLC. (“CWM”) formerly Pinnacle Advisory Group, Inc, utilizing one or more of their investment strategies, as an Independent Manager. FOCUS will provide the Client with CWM’s ADV Part 2 Brochure prior to establishing an account with them as the sub-advisor. Clients may impose restrictions on investing in certain securities or types of securities. This must be done in writing and be signed by the client. Agreements are not assigned without client consent. FOCUS manages approximately $144,913,120 in assets for approximately 168 clients. Our regulatory assets under management (RAUM), which includes assets over which we provide continuing and regular supervisory management and for which we have the ability to implement trades, is approximately $114,401,779 In addition to the assets considered RAUM, we also provide continuous and regular supervisory management, but do not have trading discretion, on approximately $7,085,042, and provide advice on a non-discretionary basis only, for approximately $23,426,299. Financial Planning Services A financial plan is designed to help the client with all aspects of financial planning. A client may choose to engage FOCUS for financial planning services alone, or in conjunction with investment advisory services as described below. Financial Planning services may include some or all the following services (other customized services may also be available):  Preparation of Net Worth Statement  Review of cash flow and annual spending along with annual budgeting  Retirement planning o How much do I need to save? o How much can I spend? o Can I accomplish my goals and dreams? o Alternative options available if my resources are not sufficient to achieve my goals. o Monte Carlo projections of the chances of success of retirement and other goals. o Determine the most tax efficient way to withdraw from assets in retirement.  Ongoing, Annual Tax Planning o Create annual projections to identify areas of tax savings and identify potential tax issues.  Future, long-term tax planning projections o Implement ideas now to provide long-term tax efficiency.  Estate & Legacy Planning o Assist in developing an outline for an estate plan and employ the services of a licensed attorney to create the appropriate documents.  Small Business Planning o Succession and transition. o Buy/Sell arrangements. o Retirement plans. o Tax planning.  Social Security Maximization o Impact of delaying Social Security. o Optimal method and time to take Social Security.  Pension analysis o Taking a lump sum versus a lifetime income stream.  Education Planning o How to best plan and fund children’s, grandchildren, or other family members education. o Optimal investment vehicles to utilize.  Charitable Planning o How to efficiently support charitable or other non-profit organizations.  Insurance Review and Risk Analysis o Is current insurance adequate? o Should additional insurance be obtained to cover unprotected risks?  Review of asset allocation o After the plan has been completed and in accordance with the client’s risk tolerance, risk capacity and long-term growth rate required by the plan. Information is obtained from personal interviews, questionnaires, and online date aggregation software. During the initial stages of developing a financial plan, several meetings spaced at regular intervals a couple of weeks apart are required. Subsequent meetings will follow a consistent review schedule to monitor and update the plan. Most plans are reviewed and modified during these planning meetings and future regular reviews. Electronic and/or hard copies of plans are available upon request.

Clients also have the ability through a client portal to access information online. Detailed investment advice and specific recommendations may be provided as part of a financial plan. Implementation of the recommendations is at the discretion of the client. FOCUS formulates financial plans based on the information provided by the client. Inaccurate or incomplete information may result in an inaccurate or incomplete financial plan. To create a financial plan, FOCUS makes certain assumptions with respect to interest and inflation rates, past trends, and future projections of the performance of the market and economy. Past performance is no indication of future performance, and future market results may differ substantially from our projections, and, thus, FOCUS cannot offer any guarantees or promises that clients’ goals and objectives will be met. Changes to the client’s personal financial circumstances, goals, or objectives may cause the financial plan to become inaccurate and out of date. FOCUS recommends that clients promptly notify us of any changes so that the financial plan can be updated. Investment Advisory Services Most financial planning clients also choose to have FOCUS provide investment advisory services to manage their assets on a discretionary basis. Although FOCUS recommends that a financial plan be prepared first, to provide a thorough understanding of the client’s financial circumstances and objectives, investment advisory services may also be available on a stand-alone basis, without financial planning services. FOCUS’ investment advisory services considers the client’s individual personal and financial circumstances, investment objectives, tolerance, and capacity for risk (as disclosed to FOCUS in response to discussions with the client or in responses to a questionnaire), cash flow needs and consideration of income tax and estate tax concerns. FOCUS’ investment advisory services would also include, as appropriate, the following:  Evaluate the client’s current holdings, strategy, and goals.  Provide assistance in identifying a target portfolio asset allocation.  Consider tax ramifications of making changes to the current portfolio.  Manage concentrated positions and provide recommendations on how to hedge these positions or create a plan to reduce the concentrated position.  If a client prefers that certain stocks or sectors are excluded or would like to employ environmental, social and governance (ESG) criteria, this can be accommodated.  Utilize asset location as much as possible to effectively locate their investments in the most tax efficient accounts.  Utilize tax harvesting, the process of offsetting gains with losses from investments to reduce the tax burden on an annual basis. Clients are responsible for providing FOCUS with information regarding their personal financial circumstances, investment objectives, and tolerance for risk, Clients are also required to notify FOCUS of any changes in their personal financial circumstances, investment objectives, goals, cash needs, and other information pertinent to their financial situation. Although the Investment Advisory Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or FOCUS may terminate an Agreement by verbal or written notice to the other party. Occasionally, depending on the complexity of financial services in relation to the amount of assets under management, FOCUS may charge a fixed fee for its combined financial planning and investment advisory services. In addition, FOCUS reserves the right to provide services at no charge to family and friends. Assets are invested primarily in individual stocks, exchange traded funds (ETFs), insured certificates of deposit, no-load mutual funds, exchange-listed options contracts, individual treasury, corporate or municipal bonds, and exchange-traded notes (ETNs). Custodians may charge a transaction fee for the purchase or sale of securities; however, FOCUS makes every effort to keep transaction fees for purchase and sales as low as possible. FOCUS typically conducts periodic reviews, and regularly sends investment reports to our clients along with their billing statements. If FOCUS is providing discretionary asset management, FOCUS places trades for clients under a limited power of attorney. As noted above, FOCUS may recommend that a Client implement the sub-advisory services of CWM for discretionary investment management services. FOCUS will assist and advise the Client in establishing investment objectives, selection of investment strategies and communications with CWM. FOCUS will serve as the Client’s primary advisor and relationship manager for the account(s). FOCUS will also provide ongoing oversight of CWM’s investment strategy(ies) to ensure they are managed consistent to the investment mandate(s). FOCUS does not receive any compensation, in any form, relating to the purchase or sale of specific investments. Initial public offerings (IPOs) are not available through FOCUS. ERISA When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (ERISA) and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflict of interest, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Continuity and Succession Focus has entered into a continuity planning agreement with CWM in the event of Jon Aldrich’s death, disability, or retirement. This arrangement provides for the continued operation of Focus that would give Focus clients the opportunity to become clients of CWM should one of these qualifying events occur. This agreement is revocable at any time, for any reason, and CWM currently does not hold any equity interest in Focus. Termination of Agreement The client or FOCUS may terminate an Agreement by verbal or written notice to the other party.