A. Description of the Advisory Firm Defined Financial Planning LLC (hereinafter “DFP”) is a Limited Liability Company organized in the State of California. The firm was formed in February 2020, and the principal owner is Samuel Vasquez Gaeta.
B. Types of Advisory Services Portfolio Management Services Core Investment Management DFP offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. DFP constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: ▪ ▪
•Investment strategy Personal investment policy Asset allocation
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•Risk tolerance Asset selection Regularportfolio monitoring DFP evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. DFP will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client.
Foundational Financial Planning Includes comprehensive financial planning in addition to Core Investment Management.
Advanced Financial Planning Includes our most robust financial planning in addition to Foundational Financial Planning as well as Core Investment Management. All of the portfolio management services listed above will be made available prior to completion of the Limited Scope Engagement – SOFP.
DFP seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of DFP’s economic, investment, or other financial interests. To meet its fiduciary obligations, DFP attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, DFP’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is DFP’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time.
Selection of Other Adviser Services DFP provides investment advice, recommendations and utilizes the investment strategies of Outside Investment Managers (“Managers”) through a sub-adviser relationship. Selected Managers are evaluated by us for use in a client’s account. Managers selected by us may offer multiple strategies. Our Firm will monitor Managers to ensure that it adheres to the philosophy and investment style for which it was selected and to ensure that its performance, portfolio strategies, and management remain aligned with the client’s overall investment goals and objectives. We will retain discretionary authority to hire and fire the Manager. Our ongoing review includes but is not limited to, assessment of the Manager’s disclosure brochure, performance information, materials, personnel turnover, and regulatory events.
When we engage a Manager to invest in a separately managed account (“SMA”), the SMA will be traded by either the Manager (externally-traded) or by our Firm (internally-traded). In both cases, all research, investment selections, and portfolio decisions are the responsibility of the Manager, not by our Firm. Performance reporting will be provided by the Manager.
Such performance reports will be provided quarterly to the client. Our Firm has entered into agreements with various independent Managers. Under these agreements, we offer clients various types of programs sponsored by these Managers. All third-party Managers to whom we will refer or engage for clients will be licensed as registered investment advisers by their resident state and any applicable jurisdictions or registered investment advisers with the U.S.
Securities and Exchange Commission (“SEC”).
Third-party managed programs generally have account minimum requirements that will vary from investment adviser to investment adviser. A complete description

of the Manager’s services, fee schedules, and account minimums will be disclosed in the Manager’s Form ADV or similar Disclosure Brochure which will be provided to clients at the time an agreement for services is executed and account is established.
401(k) and Pension Consulting Services DFP offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to:
•identifying investment objectives and restrictions
•providing guidance on various assets classes and investment options
•recommending money managers to manage plan assets in ways designed to achieve objectives
•monitoring the performance of money managers and investment options, and making recommendations for changes
•recommending other service providers, such as custodians, administrators
•and broker-dealers
•creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants.
Financial Planning Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning.
For clients engaging in financial planning services, there is no separate fee for estate planning services. However, the client’s ongoing or one-time financial planning fees may be higher if we anticipate at the start of the engagement that estate planning services are needed as part of their comprehensive financial planning arrangement. Depending on the client’s needs and desires for estate planning document review, preparation, or updates DFP will engage with a third-party scrivener service or estate planning attorneys.
In offering financial planning, a conflict exists between the interests of the investment adviser and the interests of the client. The client is under no obligation to act upon the investment adviser’s recommendation, and, if the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through the investment adviser. This statement is required by the California Code of Regulations, 10 CCR Section 260.235.2.
DFP offers the following ongoing or one-time financial planning services
•Comprehensive
•Life Stages
•Special Circumstances
•Business Consulting
•401k and Pension Consulting Services Limited to Specific Types of Investments DFP generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation-linked bonds, commodities, non-U.S. securities, structured notes, venture capital funds, and private placements. DFP may recommend the use of other investments such as cryptocurrencies and direct investment into real estate to help diversify a portfolio when applicable. DFP may also utilize other investment advisers.
C. Client Tailored Services and Client Imposed Restrictions DFP will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by DFP on behalf of the client. DFP may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets.
Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent DFP from properly servicing the client account, or if the restrictions would require DFP to deviate from its standard suite of services, DFP reserves the right to end the relationship.
D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. DFP does not participate in any wrap fee programs.
E. Assets Under Management DFP has the following assets under management: Discretionary Amounts:Non-discretionary Amounts:Date Calculated: $ 112,766,604$1,641,158April 24, 2024