Four Ponds Financial Planning LLC (“Four Ponds Financial Planning” or the "firm") is a Massachusetts-based SEC-registered investment adviser that provides fee-only financial planning, portfolio design and asset management services that, depending upon each client's unique circumstances or specific request may be general in nature or focused on particular areas of interest or need. The firm holds itself to a fiduciary standard, which means Four Ponds Financial Planning and its associates will act in the utmost good faith and perform in a manner believed to be in the best interest of its clients. Mr. McPherson (noted in Item 19) is the firm’s managing member, maintains majority interest in the firm, and is its supervisory principal.
As of December 31, 2022, the firm provides asset management services to approximately $121.7 million in client assets ($111.1 million on a discretionary basis and $10.6 million dollars in client assets on a non-discretionary basis).
Investment discretion is defined in Item 16. The firm does not sponsor or serve as portfolio manager for a wrap fee investment program.
Introductory Review A complimentary interview is conducted by a qualified representative of the firm to determine the scope of services to be provided. During the initial meeting or prior to it, a current ADV Part 2 advisory brochure and privacy policy1 statement will be given to the client.
Should the client wish to engage Four Ponds Financial Planning for its services, parties must enter into a written agreement, with further discussion and analysis conducted thereafter to ascertain financial need, goals, holdings, etc., as provided by the client.
Financial advice or plans are based upon the information disclosed by the client or their legal agent and incorporate the client's financial situation at the time the plan is presented. In performing its services, the firm may, but is not required to, verify any information received from the client or from the client's agents.
Financial Planning and Consultation Services Clients choosing financial planning service may engage Four Ponds Financial Planning on a limited, "as-needed" basis or as a prelude for the firm's investment services. Limited engagements are generally project-based, meant for clients seeking specific advice or recommendations.
Advice may be provided on such subjects as cash flow management, risk management, education funding, investment planning, retirement strategies, estate planning, or other specific needs as indicated by the client.
Investment Management and Ongoing Advice Four Ponds Financial Planning currently offers our various forms of investment advisory services (as described in Item 4) under discretionary authority. Clients who engaged us for investment advisory services prior to 2016 may be grandfathered under discretionary or non-discretionary account authority; in either case, investment discretion is stated in and determined by your written engagement agreement. Four Ponds Financial Planning also offers continuous financial planning services for those who seek ongoing assistance and wish to delegate investment oversight. We believe 1In consonance with the SEC’s 2010 General Instructions for Part 2 of Form ADV (page 22) the firm provides requisite principal executive information within Item 19 of this document that might otherwise be found in Form ADV Part 2B.
Page 4 of 34 this service is appropriate for clients who have sufficient assets to make the service worthwhile and cost effective for them.
This engagement includes the creation of an investment policy statement, ongoing portfolio reviews, periodic rebalancing, as-needed financial planning updates and assistance with employer-sponsored retirement plans.
The IPS will be designed to be specific enough to provide guidance to the firm while concurrently allowing flexibility to respond to changing market conditions. Since the IPS will to a large extent be a product of information and data provided by the client, the client shall be responsible for review and final approval of the statement.
Each portfolio is customized based on the needs of the client. The firm generally employs Modern Portfolio Theory as part of its investment strategy, which is described in further detail in Item 8 of this brochure. Existing positions within a client account containing various holdings will be evaluated and maintained when deemed appropriate.
When required under the engagement agreement, the firm will provide regular and continuous monitoring of the client’s account, which may include rebalancing portfolios to maintain an optimal allocation while minimizing tax exposures and transactional costs.
Use of Third Party Managers, Outside Managers, or Sub-Advisors (TAMPs) We offer the use of Third Party Managers, Outside Managers, or Sub-Advisors (TAMPs) for portfolio management services. We assist Clients in selecting an appropriate allocation model, completing the Outside Manager’s investor profile questionnaire, interacting with the Outside Manager and reviewing the Outside Manager. Our review process and analysis of outside managers is further discussed in Item 8 of this Form ADV Part 2A. Additionally, we will meet with the Client on a periodic basis to discuss changes in their personal or financial situation, suitability, and any new or revised restrictions to be applied to the account. Fees pertaining to this service are outlined in Item 5 of this brochure.
CGN Advisors, LLC:We may engage CGN Advisors, LLC, an unaffiliated registered investment adviser firm, to provide investment management sub-advisory services for our clients. Through this type of engagement, the sub-advisor will implement our investment strategy or strategies that we define together. Four Ponds Financial Planning, LLC will generally serve as the communication conduit between the client and the sub-advisor. We will be available to answer questions the client may have regarding their account and will provide account reviews on a schedule agreed upon with the client. The sub-advisor

will generally have discretionary authority to determine the securities to be purchased and sold for the client’s accounts consistent with our investment strategy and the client's investment policy statement or similar document. Discretionary authority is described in more detail in Item 16 of this brochure. Client should obtain and read CGN Advisors, LLC’s Disclosure Brochure (Form ADV Part 2A) for a complete description of their services, fee schedules, and account minimums.
Financial Planning & Investment Management ● An ongoing service that combines a financial plan with ongoing investment management service.
● Begins with a financial plan that measures your progress toward a financially secure retirement and reviews your overall financial health.
● Ensures implementation of investment recommendations and provides support during times of market volatility.
● Findings and recommendations from the planning review are outlined in a presentation meeting and provided in writing. Supporting reports include retirement planning projections, net-worth statements and portfolio comparisons.
Page 5 of 34 ● An Investment Policy Statement establishes written guidelines for how the portfolio is managed.
Core Financial Plan ● A detailed financial plan designed to measure your progress toward a financially secure retirement and other financial goals.
● Most appropriate for clients in their mid 40s and above.
● Includes help with fund selection for workplace retirement savings plans.
● Seeks to ensure your investments are helping you reach that goal rather than hindering your efforts.
● Findings and recommendations from the planning review are outlined in a presentation meeting and provided in writing. Supporting reports include retirement planning projections, net-worth statements and portfolio comparisons.
● An overall review of your financial health with an emphasis on retirement planning and investments. Seeks to identify other issues that may require attention including insurance, estate planning and cash flow.
Financial Checkup ● A single 90-minute meeting with a financial planner.
● Entry-level service focused on your most pressing financial issues.
● A short summary of recommendations and access to our financial planning program provided after the meeting.
● Most appropriate for clients with fairly simple circumstances such as those in their late 20s or early 30s.
● Not appropriate for clients with complex needs or those seeking detailed investment recommendations.
● Appropriate topics for discussion include budgeting strategies, basic retirement planning, college savings options and student loans.
Customized Engagements ● We provide customized financial planning engagements for those with particularly unique or complex circumstances.
Small Business Retirement Planning ● Assistance for small business owners seeking help setting up retirement plans appropriate for themselves and their employees. Options include SEP IRAs, SIMPLE IRAs and small business 401(k) plans. This service includes retirement planning and financial education seminars for employees.
When financial planning services focus only on certain areas of client interest or need, the client must understand that their overall financial situation or needs may not be fully addressed due to limitations they have established.
The client retains absolute judgment over all implementation decisions and is free to accept or reject any recommendation made by the firm. Further, it remains each client's responsibility to promptly notify Four Ponds Financial Planning if there is a material change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising the firm's recommendations or services.
Page 6 of 34 Workshop Presentations Appropriately trained and registered firm personnel may provide educational workshops on an “as announced” basis for groups desiring general advice on investments and personal finance. Topics may include issues related to wealth management, financial planning, retirement strategies, or various other economic and investment topics.
Such workshops or programs are purely educational in nature and do not involve the sale of any investment products.
Information presented will not be based on any one person’s need, nor does the firm provide individualized investment advice to attendees during these sessions.
Other Professionals The firm does not provide accounting, legal or property and casualty insurance services. With the client's consent, the firm may work with the client's other advisers (accountants, attorney, etc.) to assist with coordination and implementation of agreed upon strategies. The client should be aware that their other advisers will bill them separately for their services and these fees will be in addition to those of the firm.
The firm will use its best judgment and good faith effort in rendering its services to its clients. Four Ponds Financial Planning cannot warrant or guarantee any particular level of account performance, or that account will be profitable over time. Past performance is not necessarily indicative of future results.
Except as may otherwise be provided by law, the firm will not be liable to the client, heirs, or assignees for any loss an account may suffer by reason of an investment decision made or other action taken or omitted in good faith by the firm with that degree of care, skill, prudence and diligence under the circumstances that a prudent person acting in a fiduciary capacity would use; any loss arising from the firm's adherence to the client or their legal agent's direction; or any act or failure to act by a service provider maintaining an account.
Federal and state securities laws impose liabilities under certain circumstances on persons who act in good faith and, therefore, nothing contained in this document shall constitute a waiver of any rights that a client may have under federal and state securities laws.