About FFS FFS was founded in 2004 and became registered with the SEC as an Investment Advisor in 2006. FFS is a wholly owned subsidiary of Founders Financial, LLC. Listed below is a description of the various investment advisory services offered by FFS through registered individuals associated with FFS as Investment Adviser Representatives (“IARs”). IARs hold themselves out to the public using business names other than FFS. These are known as “doing business as” names or, more commonly, “DBAs.” IARs must disclose on their advertising and correspondence materials that they are an IAR of FFS and that securities and investment advisory services are offered through FFS. Description of Services Available FFS does not determine investment philosophies and strategies for IARs. Investment philosophies and strategies will vary by IAR based upon how they understand individual client investment needs. IARs are responsible for recommending and implementing investment advice under the supervision of FFS. Clients are advised that there is no guarantee, stated or implied, that the client’s investment goals or objectives will be achieved. FFS’ IARs provide investment advisory services on both a discretionary and non-discretionary basis. These services include, but are not limited to, providing ongoing investment advice, management of investment advisory accounts, and recommendation of third-party money managers. IARs also provide advice to clients on matters not directly involving securities, such as financial planning, retirement planning and estate planning. FFS’ IARs approach to financial planning can include a review of a client’s financial assets, liabilities, and cash flows through the lens of their goals and objectives. When such a review is provided, the IAR will work with the client to create a financial plan that considers savings goals, projections about a client’s potential ability to achieve their goals and objectives, the impact of different rates of return and possible future variations in cash flow. Further, the IAR will work with the client to determine a prudent asset allocation considering existing assets, client risk tolerance and time horizon, and the potential benefits of diversification. FFS IARs approach to investment management and advisory services can include personal discussions in which a client’s goals and objectives are discussed and established. The IAR will develop an investment plan that considers each client’s investment objectives, risk tolerance, time frame, and future need for the funds. The FFS IAR will use various tools, resources, and questionnaires to understand these factors and then build and recommend or manage the portfolio according to the criteria. FFS IARs will provide continuous investment management advice based on the client’s individual needs. FFS’s IARs assist clients that are trustees or other fiduciaries to retirement plans by providing fee-based consulting and/or advisory services. If client elects to engage FFS and IAR to perform ongoing investment monitoring and ongoing investment recommendation services to a retirement plan, such services will constitute “investment advice” under Section 3(21)(A)(ii) of ERISA. Depending upon the scope of services offered by the IAR, clients may also have the option of engaging FFS to provide certain investment advisory services on a discretionary basis as an “investment manager” under Section 3(38) of ERISA. Therefore, FFS and the IAR will be deemed a “fiduciary” as such term is defined under ERISA when providing either non- discretionary investment advice for a fee or discretionary investment manager services, as designated in the client account agreement. Clients should understand that to the extent FFS and IAR are engaged to perform services other than ongoing investment monitoring and recommendations (for example, investment education and general financial information), those services are not “investment advice” under ERISA and therefore, FFS and IAR will not be a “fiduciary” under ERISA with respect to those other services. ERISA and Individual Retirement Accounts Disclosure When FFS and the IAR provides investment advice for a fee to a client regarding a retirement plan account, FFS and the IAR are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. When an FFS IAR provides investment advice to an Individual Retirement Account both FFS and the IAR are acting as a fiduciary under the Investment Advisors Act of 1940.The way both FFS and the IAR make money creates some conflicts with client interests, so both FFS and the IAR operate under a special rule that requires us to act in the client’s best interest and not put the interests of FFS or the IAR ahead of theirs. Under this special rule's provisions, FFS and the IAR must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put FFS and the IAR financial interests ahead of the clients when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that FFS and the IAR give advice that is in the clients best interest;
• Charge no more than is reasonable for FFS and the IAR services; and
• Give the client basic information about conflicts of interest. The following is a list and description of the FFS advisory programs: I. Independence Advisory Independence Advisory is an investment advisory platform available to IARs who manage client accounts through their own investment process. Management and trading in these accounts may be discretionary or non-discretionary. These accounts are custodied at Pershing LLC (“Pershing”), Axos Clearing LLC (“Axos”) or Charles Schwab & Co, Inc. (“Schwab”). The IAR and client will decide which custodial platform will serve the client’s needs after a discussion of their investment objectives, risk tolerance and investment goals. The IAR can also offer advisory services for accounts not directly held with FFS custodians. This is accomplished through the management of Held Away 401k Accounts, via a partnered program with Pontera. See Item 12 for more information on each custodian’s practices. The IAR will develop an investment allocation that considers each client’s investment objectives, risk tolerance, time frame, and future need for the funds. The FFS IAR will use various tools, resources, and questionnaires to understand these factors and then build a portfolio subject to the investment choices available within the platform. The investment selections for Held Away 401k Accounts are limited to the choices offered through the specific account and custodian. FFS IARs will provide continuous investment management advice based on the client’s individual needs. Client accounts typically hold mutual funds, stocks, and exchange traded funds (ETFs). Held Away 401k Account holdings can also include money market funds, investments with third party managers, and other types of securities. For Held Away 401k accounts, FFS IARs leverage an Order Management System from Pontera to implement asset allocation and rebalancing strategies on behalf of the Client. Fees for the investment advisory services for held away accounts are typically charged to a different account of the client that is managed directly by the IAR through another FFS advisory program or such fee can be paid directly by client. Fees are not deducted from the held away accounts. II. Third-Party Asset Managers FFS enters into agreements with various unaffiliated third-party asset managers or sub-advisors to provide investment management, investment advice, consultation, and direction to FFS and the IAR concerning the management of the client account. In instances where sub-advisors are engaged, the client acknowledges that they receive all pertinent contracts, agreements, and disclosure documents. Each IAR shall assist their client in formulating an investment plan based on the client's investment objectives, risk tolerance, and time horizon. Once an investment plan is formulated, a suitable third- party asset manager is selected to implement and manage the investments in the client’s account. In preparing the investment plan, each IAR will set appropriate restrictions or limitations on the management based on client’s investment profile and explain to the client the discretionary nature of the account activity transacted by the third-party asset manager. Also, FFS will periodically conduct due diligence and surveillance reviews of third-party managers. The relationship of FFS with the third- party asset manager will be clearly communicated to the client in the third-party asset manager’s Client Services Agreement and/or other similar documentation. Each third-party asset manager is required to provide FFS and each of the IARs with disclosure documents, including among other items, a copy of their Form ADV 2A. Upon request, FFS will provide the client with a copy of any Brochure Documents of sub-advisers managing the client's assets, either on paper or electronically in accordance with the SEC's guidance on the use of electronic media. III. The Managed Portfolio Program (MPP) MPP is a fee-based platform through which an IAR constructs risk tolerance-based investment models utilizing a combination of mutual funds, exchange-traded funds (ETFs), and investment strategies sub-advised by third-party asset managers in an effort to meet the stated investment objectives of each client. Based on the information provided by the client, the IAR will determine which model(s) of the Managed Portfolio Program are appropriate for each client. FFS and IAR will monitor the sub-advised investment strategies, mutual funds, and exchange-traded funds (ETFs) that are selected for the Managed Portfolio Program and will assume discretionary authority, via the Investment Advisory Agreement, to manage the accounts. Custodial services are provided by Axos. In instances where sub-advisors are engaged or FFS has discretion, FFS obtains authorization from the clients to accept delivery of all disclosure documents, ADV, and trade confirmations. IV. Freedom Capital Management Strategies® Freedom Capital Management Strategies® (“FCMS”) is a comprehensive suite of investment advisory programs managed by FFS. FFS delivers investment solutions through the IARs, which include professionally managed investment advisory accounts, investment fiduciary services for qualified retirement plans, and investment education for retirement plan participants, as detailed below. In certain situations, FFS engages independent investment sub-advisors or model delivery providers to assist in the management of the investment strategies available through FCMS. In instances where sub-advisors are engaged or FFS has discretion, FFS obtains authorization from the clients to accept delivery of all disclosure documents, ADV, and trade confirmations.
• FCMS Managed Accounts – Through FCMS Managed Accounts, FFS offers a curated suite of managed investment strategies that incorporate strategic, dynamic, and alternative asset allocation methodologies. The IAR will assist each client in developing and implementing a personalized investment allocation based on the client’s investment objective, risk tolerance, and time horizon. The client accounts in FCMS are managed by FFS and the IAR on a discretionary basis, as detailed in the Client Advisory Agreement. The client accounts invested through this program are held in custody at Axos.
• FCMS Private Wealth Solutions – FFS has partnered with Maple Capital Management, Inc. (“Maple Capital”), a Registered Investment Advisor that is not affiliated with FFS, to create customized portfolio solutions that are typically comprised of individual stocks and bonds. FFS and the IAR are responsible for client management which includes, but is not limited to, such things as: account setup, identifying client investment objectives, suitability, risk tolerance, time horizon, and client relationship management. Maple Capital is responsible for investing activities, which include but is not limited to such things as: selecting and monitoring investments, portfolio construction, and executing transactions in accordance with the client’s investment objectives and risk tolerance. The terms and conditions under which the client shall engage Maple Capital through FFS will be set forth in an investment advisory agreement between the client, FFS and Maple Capital. FCMS Private Wealth Solutions incorporates a private client service model where the portfolio management team from Maple Capital works alongside the IAR to develop and implement a custom investment portfolio for each client based upon each client’s investment objectives, suitability, risk tolerance, and time horizon. The client accounts in this program are managed on a discretionary basis, as detailed in the investment advisory agreement and are held in custody at Schwab.
• FCMS Freedom Independence Plan – The Freedom Independence Plan is a discretionary investment advisory program for company qualified retirement plans. Through this program, FFS serves as a fiduciary investment manager, as defined in section 3(38) of the Employee Retirement Income Securities Act (ERISA). FFS selects, manages, and monitors the investments made available in the retirement plan of each plan sponsor client using this program and also develops an investment policy statement for each of the retirement plans. IARs assist the plan sponsor in determining if the program is appropriate for their plan and also provide plan design consultation to plan sponsors and investment education to plan participants. The program is currently available at several retirement plan recordkeepers that are unaffiliated with FFS.
• TheFreedomStrategies.com – This is an investment education software offering assistance to clients with participant-directed retirement accounts that are held away from FFS. This subscription-based service delivers asset allocation guidance through FFS and the IARs to support clients in managing their retirement plan accounts that are not held with FFS. More information is available at TheFreedomStrategies.com. V. Nationwide Variable Annuity This is a fee-based variable annuity issued by Nationwide. As with all variable annuities, the Nationwide product can provide certain tax advantages for non-qualified client assets. The IAR develops an investment allocation that considers each client’s investment objective, suitability, risk tolerance, time horizon, and future need for the funds. FFS’ IARs will use various tools, resources, and questionnaires to understand each of these factors and then build and manage the portfolio according to the criteria within the Nationwide product subject to the sub-accounts available within Nationwide Variable Annuities. FFS’ IARs will provide on-going investment management advice based on the client’s individual needs. The investment selections for the variable annuity are limited to the choices offered through the particular Nationwide product. Specifics regarding the annuity are found in the annuity prospectus and application documents. The IAR builds and recommends an appropriate asset allocation for each client

based on their risk tolerance, using sub-accounts available within the Nationwide Variable Annuity. On-going monitoring of the account is performed by the IAR and recommendations for changes to asset allocations or sub-accounts must be approved by the client. VI. Financial Planning Services FFS IARs offer financial planning and consulting. Financial planning typically involves providing a variety of services to individuals or entities regarding the management of their overall financial resources based upon an analysis of their individual needs. Generally, financial planning services involve preparing a financial analysis for a client based on the client’s stated life goals, income, and financial needs, and could also include a review of the client’s investment objectives, suitability, and risk tolerance. The information provided as part of this service would normally cover present and anticipated assets and liabilities, including insurance, savings, investments, and anticipated retirement benefits or other employee benefits. Traditional financial planning involves meeting with the client to determine financial goals and objectives and then developing and delivering a financial plan. The financial planning advice that is provided by the IAR will include general recommendations for a course of action or specific actions to be taken. Typical financial planning and consulting will include the following:
• Initial Client Meeting o The purpose of an initial meeting is to discuss specific areas of concern and potential planning areas. During this meeting, the IAR will work with the client to determine whether a financial plan is appropriate or whether the client seeks investment advice only. o As part of the initial meeting, or as a separate meeting, the IAR will review necessary documents to develop a financial plan. These documents can include, but are not limited to, brokerage statements, insurance policies, income tax statements, estate documents, previously completed financial plans, business agreements and retirement information.
• Developing a Financial Plan, Investment Analysis, or Both o Based on the information the IAR gathers, a financial plan or investment analysis will be developed. The IAR can use various computer software tools to assist in creating the financial plan or investment analysis. While the IAR will not provide tax or legal advice, with client permission the IAR can speak with and gather information from the client’s attorney or tax professional. Financial plans typically consist of a combination of one or more of the following services:
• Financial Position o Financial position review encompasses a review of current financial position, including a review of current cash flow. This type of review typically involves reviewing client net worth, cash flow, budget, debt, and investment accounts.
• Retirement Planning o Retirement planning typically consists of analyzing current or expected future retirement needs. Based on the current level of retirement savings, additional retirement accounts (such as an IRA or Roth IRA) could be recommended, or additional contributions to existing company retirement plan could be recommended. o If the client has an account in a company retirement plan that falls under ERISA (such as a 401(k), defined benefit plan, etc.), the IAR can provide education on the company’s retirement account and/or recommendations for the allocation of client investments based on the client’s investment objectives, suitability, risk tolerance and time horizon.
• Insurance Analysis o Insurance analysis typically consists of analyzing current or expected insurance needs. Based on the client’s specific circumstances such as, liability risks, number of dependents and the age of the members in a household, the IAR could suggest the need to increase or decrease the amount of insurance or modify or change the type of policy. The types of policies that the analysis covers could include, but are not limited to, life insurance, long-term care insurance, disability insurance, health insurance, and property and casualty insurance.
• Education Planning o The IAR can review current or future needs as it relates to paying for education expenses for the client or their dependents. This type of review typically analyzes the amount of money being saved for education expenses in addition to what might be needed based on the client’s education goals. Further, the review could include recommendations on how to invest funds that are earmarked for educational needs.
• Estate and Wealth Transfer The IAR can review the goals of the client as it relates to the client’s financial legacy. This type of review typically assesses account ownership structure, beneficiary designations, and whether the client has appropriate legal documentation. The IAR cannot provide any legal or tax advice and will commonly recommend the client seek appropriate counsel from legal and/or tax professionals.
• Investment Analysis Investment Analysis involves the IAR interviewing the client to understand the client’s goals and objectives of current portfolio(s) and investable assets. This analysis typically consists of the client completing a risk tolerance interview and/or assessment. Upon completion the IAR will typically compare the client’s current portfolio to the client’s determined risk tolerance. The investment analysis can include, but is not required to contain, security and/or product analysis of client investments, a broad asset allocation review, and a review of the tax efficiency of the client’s overall investment portfolio. As part of the consulting services, the IAR cannot provide tax advice. Upon completion of the analysis, the IAR can provide the client with recommendations regarding the client’s investment portfolio that will take into consideration the financial planning objectives, asset accumulation goals, time frame, and investment experience.
• Recommendations The client is under no obligation to implement financial planning or investment recommendations provided by the IAR. If the client chooses to act on any of the advice given, client is under no obligation to open any accounts with FFS or the IAR and may choose to open accounts with firms that are not affiliated with FFS. If the client implements any investment recommendations through FFS, this will create a conflict of interest for the IAR and FFS because the IAR and FFS will receive compensation for recommendations that are implemented through FFS. If the Client implements such recommendations by using another broker-dealer, investment advisor or dealing directly with an issuer of mutual funds, neither FFS nor the IAR will be compensated. VII. 1031 Planning As part of Financial Planning Services, FFS’ IARs may also provide consulting services to clients initiating 1031 exchanges of real property and seeking advice towards re-investment of assets received from the exchange. FFS IARs can provide recommendations regarding the reinvestment of assets into Delaware Statutory Trusts (DST) or any real property instrument. Although FFS IARs may assist clients with the preparation of direct application purchase, the IAR does not facilitate the exchange or purchase of such properties or any investment. Further, the FFS IAR will not receive any compensation from the 1031 provider, nor accept any responsibility for ongoing assessment or advice concerning the 1031 exchange and property that was selected by the client. Clients may choose to not accept the recommendations made by the IAR. Finally, FFS IARs will not be listed as advisors of record as the transaction will occur through a nonaffiliated outside broker dealer. VIII. Wrap Fee Programs FFS does not sponsor or manage any wrap fee programs. IARs are permitted to recommend the use of third-party asset managers that offer wrap fee programs. The third-party asset managers recommended by IARs that offer wrap fee programs include, but are not limited to, AssetMark, SEI Asset Management, and Orion Portfolio Solutions. These are considered “wrap fee” programs because the client pays a specified fee for the overall portfolio management services and trade execution. Wrap fee programs differ from other programs in that the asset management fee structure for wrap fee programs is intended to be largely all-inclusive, whereas non-wrap fee programs assess trade execution costs or separate administrative fees that are typically in addition to the asset management fee. For example, the FCMS Managed Account and FFS Independence Advisory programs are not considered wrap fee programs because clients generally pay trade-by-trade transaction costs, if any, and a separate administrative fee that is in addition to the asset management fee. Third-party asset managers that offer wrap fee programs are available through FFS and are managed in accordance with the investment methodology and philosophy used by the respective third-party asset managers, investment advisers, or strategists. Clients should refer to the specific program documents and the third-party asset manager’s wrap fee brochure for a full description of their services and all related terms, conditions, fees, and expenses. Individualized Services and Client-Imposed Restrictions The investment advisory services provided by FFS’ IARs depend largely on the personal information the client provides to the IAR. For FFS IARs to provide appropriate investment advice to, or in the case of discretionary accounts, make appropriate investment decisions for the client, it is very important that clients provide accurate and complete responses to their IAR’s questions about their financial condition, needs and objectives, time horizon and any reasonable restrictions they wish to apply to the securities or types of securities to be bought, sold, or held in their account(s). It is also important that clients promptly inform their IAR of any changes in their financial condition, investment objectives, personal circumstances, time horizon and reasonable investment restrictions if any, that could affect the client’s overall investment goals and strategies. Each of the programs described above has its own independent set of agreements and documents that will be provided to the client for review and execution. Each agreement identifies specific roles of the IAR and includes information about program fees, charges, and risks. Clients should refer to the specific program documents for a full description of their products and services and all related terms, conditions, fees, and expenses. Program Choice Conflicts of Interest FFS and the IAR have a fiduciary duty to act in the best interest of the client. A conflict of interest arises when FFS and/or the IAR have competing interests between the professional obligation of doing what is best for the client, and the self-interest of the IAR and/or of FFS, and that self-interest could influence the professional obligation. For example, the IAR has a certain level of discretion regarding the fee he/she charges a client. An IAR has a financial incentive to charge a higher fee, which creates a conflict of interest for the IAR. Another example involves compensation to FFS and the IAR: compensation will differ according to the specific advisory program or services chosen. FFS and the IAR have an incentive to recommend or select an advisory program that will provide one or both of them with more, rather than less, compensation. The program administrative fees, management fees, administrative servicing fees, and other compensation to FFS and the IAR vary across different platforms and could be more than the amounts that would otherwise be received if a client participated in another program, purchased a different mutual fund, or paid for investment advice, brokerage, and/or other relevant services separately. For example, FFS and/or its IARs typically receive a higher level of compensation for participating in the Freedom Capital Management Strategies program than other advisory programs available through FFS. Also, FFS receives compensation for assets held by Axos and Schwab that is not received for assets held by Pershing, although in neither instance does the IAR receive any portion of such compensation. For clients that hold accounts in multiple FFS Advisory programs, FFS does not calculate the combined account balances across FFS Advisory programs to determine an opportunity for tiered or breakpoint pricing for each program individually. Aggregating tiered or breakpoint pricing for multiple accounts may only apply to accounts held within the same FFS program. Encouraging clients to open accounts across different programs could result in higher fees to the client which creates a conflict of interest for the IAR and the Firm. FFS and the IAR also have a financial incentive to maintain non-invested cash within the client account for operational purposes and/or as a liquid holding position until investment recommendations and decisions are made by the client, which creates a conflict of interest for the IAR and FFS. In addition, clients may find higher interest-bearing alternatives for non-invested cash outside of accounts held through custodians utilized by FFS. For the Independence Advisory, Managed Portfolio Program, and FCMS Managed accounts FFS typically maintains at least 2.0% of the account value in the custodian’s cash sweep account for operational purposes, including the payment of fees and transaction charges. This practice could result in a lower investment return than that which might be obtained if such value was otherwise invested. The custodian will ordinarily utilize a bank sweep option or non-interest-bearing cash account to allocate idle cash in each client account, as selected by the client at the time an account is established. This is done by automatically investing idle cash in the account’s selected option. To the extent the Axos Insured Deposit Program is selected by the client, this action is primarily taken so that idle cash has the opportunity to earn interest for a liquid cash holding in the account. This bank sweep option or non-interest-bearing cash account is also the default option from which the custodian will withdraw funds from to pay any debits on the account, including but not limited to advisory fees. Client should ask the IAR for information concerning the bank sweep option or non-interest-bearing cash account. Alternatively, clients may find that a money market fund or interest- bearing liquid accounts not held at the custodian will credit higher interest and as such should consider this as an option for the liquid cash positions in client account that are greater than the 2% the FFS typically maintains for operational purposes. As a result of the differences in fee schedules and sources of compensation that exist among the various advisory programs, custodial relationships, and services offered, FFS and the IAR have a financial incentive to recommend one program or service over another program or services available through FFS, creating a conflict of interest for the IAR and the Firm. The results of such a recommendation cannot be determined in advance, but only with the benefit of hindsight. FFS and the IAR will always endeavor to act in the client’s best interest. Assets Under Management As of December 31, 2023, FFS manages $2,908,968,688 of advisory assets. FFS manages $2,632,738,312 on a discretionary basis, and $276,230,376 is managed on a non-discretionary basis.