A. Firm Information
Financially In Tune, LLC (“Advisor”) is a registered investment advisor with the U.S. Securities and Exchange
Commission (“SEC”). The Advisor is organized as a Limited Liability Company (LLC) under the laws of the
Commonwealth of Massachusetts. Financially In Tune was founded in February 2011, and is owned and
operated by Jeanne Gibson Sullivan (Founder and Principal), and Amanda Magee (Principal and Operations
Manager) and Philip Lee (Principal and Chief Compliance Officer) are minority shareholders. This Disclosure
Brochure provides information regarding the qualifications, business practices, and the advisory services
provided by Financially In Tune.
B. Advisory Services Offered
Financially In Tune offers investment advisory services to individuals, high net worth individuals, trusts, estates
and businesses (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. Financially In Tune’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.
Portfolio Management Services
Financially In Tune 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. Financially In Tune works closely 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. Financially In Tune will then construct an investment portfolio, consisting of low-cost, diversified mutual
funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also
utilize individual stocks, bonds, Real Estate Investment Trusts (“REITs”), or options contracts to meet the needs
of its Clients. The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations.
Financially In Tune’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-
allocate positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. Financially In Tune 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.
Financially In Tune evaluates and selects investments for inclusion in Client portfolios only after applying its
internal due diligence process. Financially In Tune may recommend, on occasion, redistributing investment
allocations to diversify the portfolio. Financially In Tune 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. Financially In Tune 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 the Client,
generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
At no time will Financially In Tune 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 within the designated
account[s] at the Custodian, pursuant to the terms of the advisory agreement, please see Item 12 – Brokerage
Practices.
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Retirement Plan Accounts – When deemed to be in the Client’s best interest, the Advisor will recommend that a
Client roll over its retirement plan account into an account managed by the Advisor. In such instances,
the
Advisor will serve as an investment fiduciary as that term is defined under The Employee Retirement Income
Security Act of 1974 (“ERISA”). Such a recommendation creates a conflict of interest as the Advisor will earn a
new (or increase its current) advisory fee as a result of the rollover. No client is under any obligation to roll over
retirement plan assets to an account managed by the Advisor.
Financial Planning Services
Financially In Tune will typically provide a variety of financial planning and consulting services to Clients, either
as a component of portfolio management services or 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 involve preparing a formal financial plan or rendering a specific
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,
personal savings, education savings 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.
Financially In Tune may also refer Clients to an accountant, attorney or other specialists, as appropriate for their
unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the
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 (6) 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.
C. Client Account Management
Prior to engaging Financially In Tune to provide investment advisory services, each Client is required to enter
into one or more 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 – Financially In Tune, in connection with the Client, will develop a
strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Financially In Tune 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 – Financially In Tune will develop a portfolio for the Client that is intended to meet
the stated goals and objectives of the Client.
• Investment Management and Supervision – Financially In Tune will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Financially In Tune does not manage or place Client assets into a wrap fee program. Investment management
services are provided directly by Financially In Tune.
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E. Assets Under Management
As of December 31, 2023, Financially In Tune manages $222,571,272 in Client assets, $215,689,132 of which
are managed on a discretionary basis and $6,882,140 on a non-discretionary basis. Clients may request more
current information at any time by contacting the Advisor.