Firm Description FAI is an investment adviser providing investment advisory services on a discretionary basis for a variety of clients, including individuals, high net worth individuals, pension and profit-sharing plans, trusts, and estates, charitable organizations, and various for-profit business entities. FAI also provides clients with an opinion regarding the suitability of their current investment strategy as well as the investments selected to achieve those stated objectives without further management. In addition, FAI also provides tax advice including income tax preparation, where suitable. FAI was founded in 1989. Principal Owners FAI’s principal owner is Dennis P. Fagan, President, Chief Compliance Officer, and Portfolio Manager. Types of Advisory Services FAI offers the following types of advisory services: Financial planning services and portfolio management for individuals and/or small business. Investment Advisory Services FAI provides investment advisory services, defined as giving continuous advice to a client, and selecting investments for a client based on the individual needs of the client. Through personal discussions, goals and objectives are established based on a client’s particular circumstances. FAI assists the client in developing the client’s personal investment policy, and then creates and manages a portfolio based on that policy. Services may be provided on a discretionary or non- discretionary basis. Clients establish accounts only after meeting with a Portfolio Manager (Dennis P. Fagan) where financial data will be obtained. The interview(s) will also include a discussion of the goals of the client, their current financial position, tolerance to risk, family specifics and health information as well as a discussion of employer sponsored plans, where applicable. Each client is advised that it remains his/her responsibility to promptly notify FAI of any changes to their respective financial situation and consequently, their investment objectives. FAI develops portfolios based upon a client’s goals, objectives, investment time horizon and risk tolerance, as well as their core financial-related values. Investment strategies generally include long-term and short-term purchases depending upon the individual needs of the client. FAI uses asset allocation or spreading investments among a number of asset classes and sectors (domestic stocks vs. foreign stocks; large cap stocks vs. small cap stocks; corporate bonds vs. government securities) for most client portfolios. Financial Planning Services FAI offers financial planning services, which may include a review of all aspects of a client’s current financial situation, including the following components: cash management, risk management, insurance, education funding, goal setting, retirement planning, estate and charitable giving planning, tax planning, and capital needs planning. FAI meets with the client to review risk tolerance, financial goals and objectives, and time horizons. Additional meetings may include a review of additional financial information; sources of income, assets owned, existing insurance, liabilities, wills, trusts, business agreements, tax returns, investments, and personal and family obligations. Financial planning clients may receive a written report, providing a detailed financial plan designed to achieve their stated financial goals and objectives. FAI gathers required information through in-depth personal interviews. Information gathered includes a client’s current financial status, future goals and attitudes towards risk. Related documents including a questionnaire completed by the client, supplied by the client are carefully reviewed, and a

written report is prepared. If a client chooses to implement the recommendations contained in the plan, FAI suggests the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the client’s discretion. Financial planning recommendations are not limited to any specific product or service offered by a broker dealer or insurance company. Financial planning services may be integrated or may focus on certain components. Clients understand that when FAI is engaged to address only certain components, the client’s overall financial and investment issues may not be taken into consideration. FAI generally does not charge a separate fee for financial planning services. Tailored Relationships FAI tailors investment advisory services to the individual needs of the client. The goals and objectives for each client are documented in our client relationship management system. FAI clients are allowed to impose restrictions on the investments in their account. FAI may accept any reasonable limitation or restriction to discretionary authority on the account placed by the client. All limitations and restrictions placed on accounts must be presented to FAI in writing. Fiduciary Statement We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries 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. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably. Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner, when working with clients. We will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Wrap Fee Programs FAI does not participate in a Wrap Fee Program. Client Assets As of January 24, 2023, FAI manages $583,233,874 in assets under management; $580,968,876 is managed on a discretionary basis, and $2,265,798 is managed on a non-discretionary basis.