A. Firm Information Affinia Financial Group, LLC (“Affinia” or the “Advisor” and also doing business as “Special Needs Financial Planning”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). Affinia which is organized as a limited liability company under the laws of the Commonwealth of Massachusetts in June 2019. Affinia is currently owned by John W. Nadworny (Principal and Chief Compliance Officer), Cynthia R.
Haddad (Principal), and Alexandria Dunn (Wealth Advisor). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Affinia.
B. Advisory Services Offered Affinia offers investment advisory services to high net worth individuals, families, trusts, estates, businesses, and retirement plans (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Affinia’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.
Investment Management Services Affinia provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary and non-discretionary investment management and related advisory services.
Affinia works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Affinia will then construct an investment portfolio, consisting of low-cost mutual funds, exchange-traded funds (“ETFs”), individual equities and individual bonds.
The Advisor may also utilize options, private investments and other types of investments, as appropriate, to meet the needs of certain Clients. The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations.
Affinia’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate investments that have been held for less than one year to meet the objectives of the Client or due to market conditions. Affinia will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
Affinia evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Affinia may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Affinia may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Affinia 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.
At no time will Affinia accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed with the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 - Brokerage Practices.
Certain legacy Clients may be eligible for the Multi-Bank Insured Cash Account (“ICA”) Program through LPL. If the Clients account is eligible for the ICA program, the Client will authorize and direct LPL to automatically Page 4 deposit available cash balances (from securities transactions, dividend and interest payments, deposits and other activities) in the account into interest-bearing Federal Deposit Insurance Corporation (“FDIC”) insured deposit accounts (“Deposit Accounts”) at one or more banks or other depository institutions participating in the ICA Program (each, a “Bank”). Please see Item 8 – Risk of loss for additional information on the ICA program.
Retirement Accounts– When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary 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. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor.
Use of Independent Managers Affinia will recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Clients investment objectives and overall best interests. The Advisor will also assist the Client in the development of

the initial policy recommendations and managing the ongoing Client relationship. The Client will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures).
Retirement Plan Advisory Services Affinia provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsors”) The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: ∙Ongoing Investment Recommendation and Assistance ∙ Performance Reporting These services are provided by Affinia serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Affinia’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the agreement.
Financial Planning Services Affinia will typically provide a variety of financial planning services to Clients, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives.
Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not limited to investment planning, retirement planning, estate planning, personal savings, education savings, insurance needs, special needs and other areas of a Client’s financial situation.
A financial plan developed for or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs.
Page 5 Affinia may also refer Clients to an accountant, attorney or other specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor.
Consulting Services The Advisor will under certain circumstances provide consulting services to other investment advisors not affiliated with Affinia. In these engagements Affinia will enter into an agreement with the other advisor outlining the services to provided. These services will generally include the development of a financial planning strategy, communicating with clients to obtain client directions, investment objectives, investment recommendations, notices and instructions and communicating this information with the advisor, as well as meeting with clients to discuss overall planning goals. The advisor holds final discretion on whether to implement any changes recommended by the Advisor.
C. Client Account Management Prior to engaging Affinia to provide investment advisory services, each Client is required to enter into one or more advisory agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: ●Establishing an Investment Strategy – Affinia, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
●Asset Allocation – Affinia will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
●Portfolio Construction – Affinia will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
●Investment Management and Supervision – Affinia will provide investment management and ongoing oversight of the Client’s portfolio.
D. Wrap Fee Programs Affinia includes securities transaction fees (herein “Covered Costs”) together with its investment advisory fees Including these fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes its investment management services for its Clients. The Advisor sponsors the Affinia Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid its own transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure, which is always included as a supplement to this Disclosure Brochure.
E. Assets Under Management As of March 13, 2023 Affinia manages $362,871,404 in Client assets, $361,361,493 of which are managed on a discretionary basis and $1,509,911 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.
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