Type of Entity and Services Provided AFS is a California corporation formed on January 2, 1997. AFS is owned by Pierre Ngo. Founder/owner Pierre Ngo has been in the financial services practice since 1986. Pierre Ngo also serves as the President, Chief Executive Officer, and Chief Compliance Officer of AFS. He has committed to building and sustaining a client-centric advisory firm that values teamwork and collaboration.
We provide you the following investment advisory services: Financial Planning, Business Planning, Estate Planning/Administration, Asset Management, Risk Management/Insurance Services. We also provide other advisory services. Our clients include highly compensated executives, affluent business owners, as well as high net worth individuals and families, trusts and estates. Clients may engage personnel of ours, in their individual capacities as registered representatives and investment adviser representatives, or as independent insurance agents to implement our financial, business, estate planning and consulting services. AFS provides comprehensive financial planning and/or modular planning services as detailed below. Prior to rendering any of the foregoing advisory services, clients are required to sign an Advisory Agreement with AFS setting forth the relevant terms and conditions of the advisory relationship.
Assets Under Management & Assets Under Advisement As of December 31, 2023, AFS had a total of $249,353,693 of assets under management and assets under advisement. This consists of $228,691,564 of discretionary discretionary assets under management, $856,984 of non-discretionary assets under management, and $19,805,145 of non- discretionary assets under advisement.
Comprehensive Financial Planning Financial planning is the process of determining whether and how an individual can meet life goals through the proper management of financial resources. This is an ongoing process to help you make sensible decisions about money that can help you achieve your financial goals and objectives in life. We provide a comprehensive evaluation of your current course of action and potential future outcome by using currently known variables to predict future cash flows, asset values and withdrawal plans. Throughout the financial planning process, all questions, information (both quantitative/qualitative), and analysis are considered as they will likely impact the financial and state of affairs in one’s life. Clients may choose to engage AFS to provide comprehensive financial planning service or a modular stand-alone in-depth analysis on one or more financial planning subject areas. Clients choosing this service will either receive a detailed written comprehensive financial plan or a summary with recommendations, designed to assist our client in achieving their financial goals and objectives. We encourage clients that engage AFS for only comprehensive financial planning services or modular stand-alone in-depth analysis, to coordinate and initiate the periodic review. AFS recommends clients review their financial plan and any associated recommendations on an at least an annual basis and anytime the client anticipates or has experienced changes in their financial circumstance. The process of creating a financial plan usually involves, but is not limited to the following:
• Listening to what you want to achieve and deciphering the nuances of what drives your goals and objectives.

• Defining the scope of our engagement
• Collaborating with you to refine your life vision, set realistic quantifiable financial and personal goals.

• Gathering, analyzing, and evaluating data on your current course of action, circumstances and your complete financial profile.

• Collaborating with your tax, legal and other professional counsel to develop a customized comprehensive plan to meet your goals by addressing financial weaknesses and building on financial strengths.

• Providing you with specific recommendations, as well as resources to help you understand the effect of each financial decision. We stress test the viability of each recommendation, discuss the pros and cons of each decision you make and how it can impact other areas of your life, so you will be better prepared to meet life’s changes and handle emergencies. We strive to give you a full understanding so you can make thoughtful and prudent decisions.

• Working with you to prioritize the recommendations and agree upon a time frame goal to implement the action plan. Our comprehensive approach will facilitate the implementation process to execute the plan fully.

• Collaborating with you in determining the responsibility of the appropriate parties to implement and monitor the progress of the plan.

• Meeting periodically to review, measure, reflect, and refine the plan in order to be successful after the foundation is built. It is important that you make us aware of any material changes in your personal circumstances, so that we can give you prudent advice based upon current tax laws and economic conditions throughout the different stages of your life. As the client’s needs dictate, AFS’s Comprehensive Financial Planning service may include Cash Flow Management Analysis, in which AFS reviews the client’s income and expenses with the objective of meeting the client’s goals, which may involve adjusting, changing priorities, or establishing a new monthly budget.
AFS’s Comprehensive Financial Planning service may include Education Planning, in which AFS analyzes the expected financial requirements needed for the future cost of education, establishes a plan to pay those expenses, and weighs the pros and cons of various feasible savings vehicles.
AFS’s Comprehensive Financial Planning service may also include Retirement Planning in which we assess your retirement income needs, consider any charitable giving, and develop a plan to meet those needs. This process involves:
• Estimating future needs in today’s dollars;
• Calculating that amount in future dollars based on inflation rate assumption;
• Estimating your expected income from social security, employee retirement plan and other sources;
• Calculating the additional amount needed to provide you with adequate income for the future;
• Implementing tax minimization strategies;
• Analyzing the alternatives and tax implications of various retirement plans and their funding vehicles and/or distributions at retirement age; and
• Recommending appropriate investment vehicles to meet your goals.
AFS’s Comprehensive Financial Planning services may include Real Estate Planning, in which AFS collaborates with you and your other advisors in analyzing economic and tax reasons for buying, selling, or financing property in which you have an interest.
During the financial planning process, we gather required information through in-depth personal interviews. Information gathered includes details about your current financial status, your short-term and long-term goals and objectives, your retirement goals and ambitions, and your attitude towards risk of loss in your investments. We also evaluate your anticipated liquidity needs at death, your income source in the event of your disability, and the income needs of your surviving dependents. We may review your family records, budget, personal liabilities, and income tax records. We then either prepare a detailed written comprehensive financial plan or a summary with recommendations.
It is entirely up to you to decide whether to implement some, or all of the proposed financial planning recommendations. If you so desire, however, we can implement those advisory recommendations for a separate customary and reasonable compensation. Pierre Ngo will assist you acting in his separate capacity as a registered representative of Capital Synergy Partners, Inc. AFS, doing business as Advanced Financial Strategies & Insurance Services, will assist you with insurance matters. Should you choose to implement the recommendations contained in the plan, we can also provide advice on non-securities matters. Generally, we do this in connection with rendering estate planning, estate administration, business planning, and insurance services. However, any utilization of these individuals, in their separate capacity as registered representatives and/or as independent insurance agents, is completely at your discretion.
Estate Planning & Administration For clients seeking estate planning and administration services, we assist by helping clients identify assets that might be included in your estate and analyze the control, disposition, and taxation of those assets. We then propose changes for review with your attorney and/ or tax counsel to strive to accomplish the following:
• Understand the current estate overview and identify assets in your estate.

• Develop a strategy, then structure and ultimately implement, an effective method of disposition of your estate that will meet your objectives, core values and principles.

• Minimize the impact of income, estate, and gift taxes.

• Ensure that the estate will have sufficient liquidity to pay taxes.

• Minimize the emotional and financial burden of the client’s beneficiary.

• Reevaluate and update the plan as changes in tax laws and life events occur.

• Postmortem Estate Administration.
Risk Management and Insurance Services AFS helps analyze your financial exposure relative to mortality, disability, or long-term care requirements. We assess your insurance needs, review and analyze existing coverage to determine its structure and sufficiency, and summarize costs and benefits based on your current financial circumstances, goals, and objectives. Based on our findings, we will explore what actions and plans to put into place, if appropriate, to provide a superior level of protection that is consistent with your current goals.
As outlined in Item 10 of this Firm Brochure, AFS and Mr. Ngo are licensed insurance agents through CPS Insurance Services, Inc, as well as other independent brokerage agencies. As such, AFS and Mr. Ngo receive commissions as a result of insurance sales, specifically for the sale of individual life, disability, annuity, and long-term care insurance. AFS therefore has an incentive to recommend insurance products based on the compensation earned. To mitigate this conflict, AFS will only recommend insurance products when determined to be in the client’s best interest. In addition, at the client’s request, we may also work in conjunction with your other insurance brokers/ advisors regarding liability, business, and property insurances. When we collaborate with your other insurance brokers/ advisors, your team of brokers/ advisors will design your risk management and insurance needs to optimize asset protection, as well as ensuring up- to-date coverage of risk and that your needs are met. AFS may also refer clients to a specialist, or work with your current agent/ broker for advice pertaining to liability, casualty, business, and/or property insurance policy coverage. AFS does not receive compensation for the referral to a property and casualty specialist. We provide solutions for life, disability, long-term care, and health insurance coverage, which aim to ensure that each client reaches their financial planning goals, even when the unexpected happens.
AFS may refer clients to third-party benefit and insurance agents/brokers for facilitating group insurance products, including but not limited to group health, vision, dental, disability, etc. AFS receives a portion of the commissions generated from its referrals. This arrangement creates a conflict of interest for not only AFS to recommend third-party benefit and insurance agents/brokers, but also to specifically recommend agents/brokers that share a larger portion of the commissions. To mitigate this conflict, AFS will only refer clients to third-party benefit and insurance agents/brokers when determined to be in the client’s best interest.
An insurance policy is a legal contract between the insurance company (the insurer) and the person(s), business, or entity being insured (the insured). Reading your policy helps you verify that the policy meets your needs and that you understand your and the insurance company’s responsibilities if a loss occurs. Many insureds purchase a policy without understanding what is covered, the exclusions that take away coverage, and the conditions that must be met in order for coverage to apply when a loss occurs. It is important to understand what coverage you have in your policy(ies). We highly recommend that you review and understand your insurance coverage, its exclusion, and conditions of the policy(ies). All planning and analysis is based on the goals, objectives, time horizon, and risk tolerance of the client at the time the service is rendered. If the client’s circumstances change, it is the client’s responsibility to promptly notify AFS of any material changes. Failure to disclose all such relevant information will limit AFS’ ability to provide prudent advice.
We do not provide legal advice. You should consult a qualified attorney for any legal questions or preparation, or modification, of any legal documents. We do not guarantee any particular outcome or any planning result that can be achieved in the future as those may be impacted by factors over which we have no control.
Business/Employee Benefit Planning AFS offers business

and employee benefit planning which includes assisting a client to determine the best choice of entity type and business structure best suited for your current or future business, assesing your current and possible future business needs in conjunction with your attorneys and tax advisors (e.g., buy- sell agreements, employment agreements, deferred compensation arrangements, etc.), examining your employee benefit needs (e.g., company group health, life, and long-term care and disability insurance, 401(k) and retirement plans, employee stock option plans, etc.) and evaluating the possible tax consequences and economic impact of the foregoing on your business/employee benefits.
AFS Asset Management Services Our asset management service begins with an analysis of your goals, risk tolerance, investment experience, and net worth in order to better direct the investment of your assets and meet your financial goals. In providing investment management, we consider your existing assets and liabilities, the anticipated time horizon, risk profile, diversification of your existing portfolio, anticipated liquidity needs, and objectives. We place asset allocation at the core of our investment process. Our framework for investment extends beyond traditional asset classes of equities, fixed income, and cash equivalents. We also consider real asset and alternative investments as an important asset class in a well-diversified portfolio that can benefit our clients.
Clients may request restrictions or mandates on the management of their accounts. AFS will determine, in its sole discretion, whether those conditions would materially impact the performance of a management strategy or prove overly burdensome to AFS’s management efforts. AFS educates clients on market trends, economic forces, and investment fundamentals to cultivate a better understanding of investment decisions. However, if the we are not able to honor the request due to the nature of the investments or because the restriction prevents us from properly servicing the client’s account, we will notify the client accordingly and the client or AFS have the right to terminate the relationship.
AFS utilizes long-term, strategic asset allocation to assist you in meeting your investment objectives. We then make intermediate and short-term, tactical changes to different classes of assets as macro-economic and market conditions dictate. In your investment management agreement with us, you give us the discretion to determine the investments to buy and sell on your behalf and the authority to select independent investment managers. This means we will make the ultimate decision regarding the investments purchased and sold in your account. You will complete an Investor Risk Profile Questionnaire to determine which of the following five investment profiles are appropriate for you: (1) Aggressive Growth, (2) Growth, (3) Moderate Growth, (4) Conservative Growth, and (5) Emphasis on Income. Each investment profile defines a different time horizon, return goal, and risk tolerance. In turn, your investment profile is primarily used to dictate the portfolio structure. Each of the foregoing investment profiles are described within the Risk Profile Questionnaire. Additionally, we may also customize your investment strategy and profile to achieve your specific needs and desires. Your investment account(s) will then be managed in accordance with the asset allocation investment strategy, investment profile(s), and your specific goals.
Strategic asset allocation consists of diversifying your portfolio among various asset classes, specifically including, but not limited to stocks, bonds, mutual funds (open-end, close-end, and interval funds), alternative mutual fund vehicles, as well as exchange traded funds (ETFs), CDs, and money market instruments. It is possible that a client’s investments may include other types of investments or securities as the Firm deems appropriate for the client. This may include alternatives funds that take long/short positions or invest in real estate, currencies, derivatives, arbitrage strategies, global macro, hedge funds, options and other instruments or strategies. Funds in this group may attempt to move in the opposite direction of the market or may have performance that is not correlated with the broad markets. For some Accredited Investors, AFS may recommend that clients invest in private placement securities, which may include debt, equity, and/ or pooled investment vehicles (e.g., Delaware Statutory Trusts (DST)), when consistent with the client’s overall objective.
AFS is dedicated to understanding and meeting our client’s needs. We monitor the investment assets we manage on a continuous basis and review managed accounts at least quarterly. We rebalance the portfolio on an “as-needed” basis and not on any periodic schedule. As macroeconomics and market environment change, we tactically allocate the amount invested in various asset classes in response to the changing market environments within the strategic framework. This is done according to your risk profile as well as your goals and objectives.
We also periodically provide assets under advisement for certain clients on a non-discretionary basis (you make the ultimate decision regarding the investment purchase and sale) for held-away accounts, including but not limited to 401k plans, 403b plans, 529 plans, deferred compensation, stock option accounts, etc.
Envestnet/Selection of Independent Investment Managers In addition to AFS’s direct asset management services, AFS will also utilize Envestnet Asset Management, Inc. (“Envestnet”) to select certain independent managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an independent manager will be set forth in a separate written agreement with the designated independent manager. In addition to this brochure, AFS will provide clients a copy of Envestnet’s Disclosure Brochure and other independent investment manager disclosure documents prior to or concurrently with any investment through the Envestnet program.
Envestnet utilizes the brokerage, execution, and custody services of Schwab. By participating in this program, Envestnet provides our clients with access to institutional independent investment managers and their expertise. These managers (using their own proprietary methodologies) invest in a wide range of asset classes and use multiple investment strategies.
AFS evaluates a variety of information about independent managers, which includes the independent managers’ public disclosure documents, materials supplied by the independent managers themselves and other third-party materials AFS believes are reputable. To the extent possible, AFS seeks to assess the independent managers’ investment strategies, past performance, and risk results in relation to its client’s individual portfolio allocations and risk exposure. We also take into consideration, along with other related factors, each independent manager’s underlying holdings, concentrations and leverages used by any manager in which our client’s assets are invested as part of our overall risk assessment. We monitor the performance of those accounts being managed by independent managers on a periodic basis to ensure the independent managers’ strategies and target allocations remain aligned with the client’s investment objectives and overall best interests. However, we do not control the independent manager’s daily business operations or internal controls.
IRA Rollover Considerations AFS may recommend, as part of AFS advisory services, that you withdraw the assets from your former employer’s retirement plan and roll the assets over to an individual retirement account (“IRA”), which we will manage on your behalf. Before you consider rolling over the assets to an IRA, assuming the following options are available, you should understand the tradeoffs associated with: (1) leaving the assets in your former employer’s retirement plan, (2) rolling over your assets to a new employer’s retirement plan, (3) cashing out your employer’s plan and receiving an after-tax distribution, and (4) rolling over your assets into an IRA.
Each option has its various benefits and drawbacks, depending on factors like investment options, services, fees, withdrawal choices, required minimum distributions, tax consequences, and the investor’s unique financial needs and retirement goals. As fiduciaries, we must evaluate these aspects, disclose potential conflicts, and work with you to create a strategy aligned with your best interests.
As your financial advisor, we have a fiduciary obligation when suggesting a rollover or transfer of assets from an employer-sponsored retirement plan to an Individual Retirement Account (IRA) under our management.
Consequently, a recommendation to transfer plan assets to an IRA, rather than retaining them in a former employer’s plan or transferring them to a new employer’s plan, must take into account various factors. The significance of these factors depends on the client’s individual needs and circumstances. Some of the factors include:
•Investment Options: An IRA serves as an alternative to maintaining your retirement funds within your employer’s plan. An IRA often provides access to a wider array of investment opportunities compared to a plan. The significance of this factor may partly depend on your satisfaction with the available options in the plan being considered.

•Services: It may be beneficial to evaluate the varying service levels offered by each option, including the provision of investment advice, financial planning, and related services.

•Fees and Expenses: Both plans and IRAs typically involve (i) investment-related expenses and (ii) plan or account fees. Some employers may cover part or all of the plan’s administrative expenses, while IRA custodians might not charge or may waive such expenses. Investment-related expenses can include sales loads, commissions, mutual fund expenses, and investment advisory fees.

•Penalty-Free Withdrawals: If you depart from your job between the ages of 55 and 59½, you might be able to make penalty-free withdrawals from a plan. Conversely, penalty-free withdrawals from an IRA are generally not permitted until the age of 59½, with a few exceptions. Borrowing from a plan may also be an option.

•Creditor and Legal Judgment Protection: In general, plan assets receive unlimited protection from creditors under federal law, while IRA assets are safeguarded only in bankruptcy proceedings. State laws differ in terms of IRA asset protection in lawsuits.

•Required Minimum Distributions: Upon reaching the age of 73, both plans and IRAs mandate the periodic withdrawal of specific minimum amounts, referred to as required minimum distributions. However, if you continue working past the age of 73, you are generally not obligated to make required minimum distributions from your current employer’s plan. This can be advantageous if you intend to work into your 70s.

•Employer Stock: If you possess significantly appreciated employer stock in a plan, it is essential to consider the adverse tax consequences of transferring the stock to an IRA. If employer stock is moved in-kind to an IRA, stock appreciation may be taxed as ordinary income upon distribution. Balancing the tax advantages of retaining employer stock in a non-qualified account with the potential risk of being overly concentrated in employer stock is crucial. Holding excessive employer stock in one’s retirement account can be risky; for some investors, liquidating the holdings and transferring the value to an IRA may be advisable, despite losing long-term capital gains treatment on the stock’s appreciation.

•Conflicts of Interest: A recommendation to transfer plan assets to an IRA within a managed account inherently involves a conflict of interest, as we will earn a management fee for overseeing the assets. In contrast, suggesting that you keep your plan assets with your previous employer or transfer them to a new employer’s plan likely results in minimal or no compensation for us. This conflict must be disclosed to you, and your evaluation of the conflict is one of the factors to be considered. It’s important to discern the differences between these types of accounts, services offered, and the total compensation received by AFS. This is not a complete list of all the benefits and drawbacks associated with rolling over your assets into an IRA, and therefore should not be solely relied on for decision making purposes.
Qualified Plan Consulting Services for Business Entities AFS provides qualified plan consulting services to business entities with their qualified retirement plans as a 3(21) fiduciary. As part of this advisory service, AFS typically provides the following consulting to plan sponsor/trustee(s) (although some plan clients may select only a few of these options):
• Consult with the plan sponsor/trustee(s) to understand the goals and objectives for the plan.

• Research and provide recommendations of service providers to the plan sponsor/trustee(s) for selection to set up a qualified plan.

• Consult with the plan sponsor/trustee(s) in designing the plan with a third-party administrator (“TPA”).

• Consult with the plan sponsor/trustee(s) offering solutions to the investments menu, including
• delegation of responsibilities among service providers.

• Consult with the plan sponsor/trustee(s) on providing enrollment meetings, education materials,
• services and seminars for plan participants.

• Consult with the plan sponsor/trustee(s) in meeting the participants needs and suggest recommendations for changes when necessary.