A. Firm Information The Financial Advisors, LLC (“TFA” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of Massachusetts. TFA was founded in 2008. TFA is primarily owned and operated by Robert C. Miller (Member and Chief Compliance Officer), and Michael P. Kumph (Managing Member). TFA maintains two offices in Andover, MA and Newburyport, MA.
This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by TFA. If you have any questions relating to this Disclosure Brochure, please contact Mr.
Miller at (978) 463-6660.
B. Advisory Services Offered TFA offers investment management and financial planning services to individuals, trusts, estates, charitable organizations, businesses and retirement plans (each referred to as a “Client”). TFA offers its services as a fee-based advisory firm. No finder’s fees are accepted.
The Advisor acts as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. TFA’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.
Our investment management and financial planning services are typically provided together as a comprehensive wealth management relationship.
Wealth Management Services TFA may provide Clients with wealth management services, which generally includes discretionary and non-discretionary management of investment portfolios in connection with a broad range of comprehensive financial planning and consulting services. Advice is provided through consultation with the Client and may include: determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning.
TFA utilizes a multi-disciplinary team approach to addressing each Client’s financial planning and investment management needs. The Advisor’s team includes a Certified Public Accountant, IRS Enrolled Agents, and Certified Financial Planners. Most Clients hire an attorney to work on estate plans or other legal issues. In addition, some Clients engage other professionals, e.g., accountants or insurance agents. TFA will consult with all such professionals as planning recommendations are formulated and/or implemented for the Client.
The initial meeting with prospective Clients is free of charge and is considered an exploratory interview to determine the extent to which financial planning and investment management may be beneficial to the Client.
TFA actively seeks to avoid, or at least minimize, conflicts of interest which may exist between the Advisor and our Clients. However, all investment advisory firms will likely possess some unavoidable conflicts of interest. In those instances, when conflicts of interest arise, TFA has adopted policies which seek to keep our Clients’ best interests paramount at all times.
TFA offers two types of wealth management solutions for its Clients based on the size and complexity of the relationship. Both wealth management services include financial planning and investment management services.
Wealth Management Advisory (“WM”) services are provided based a percentage of assets under management with TFA pursuant to the terms of the advisory agreement. Please see Item 5.A for fees. The financial planning Page 5 services typically consists of 3 to 4 meetings between the Advisor and the Client. The financial planning topics discussed during those meeting may include, but are not limited to: a summary of holdings statement; a cash flow statement; a review of investment accounts, including reviewing asset allocation and providing repositioning recommendations; strategic tax planning; a review of retirement accounts and plans including recommendations; a review of insurance policies and recommendations for changes, if necessary; one or more retirement scenarios; estate planning review and recommendations; and education planning with funding recommendations.
Detailed investment advice and specific recommendations are provided as part of a financial plan.
Wealth Management Level Fee Advisory (“WMLF”) services are generally offered when it is more appropriate to incorporate investment management services on a fixed-fee basis, which is detailed in a Wealth Management Level Fee Advisory Agreement. Please see Item 5.A for fees. The planning process typically consists of 3 to 4 meetings between the Advisor and the Client. The financial planning topics discussed during those meeting may include, but are not limited to: a summary of holdings statement; a cash flow statement; a review of investment accounts, including reviewing asset allocation and providing repositioning recommendations; strategic tax planning; a review of retirement accounts and plans including recommendations; a review of insurance policies and recommendations for changes, if necessary; one or more retirement scenarios; estate planning review and recommendations; and education planning with funding recommendations. Detailed investment advice and specific recommendations are provided as part of a financial plan.
WM and WMLF services are generally provided on a discretionary basis. TFA works closely with each Client to develop and implement an investment plan for each Client in connection with the financial planning outcomes and the specific needs of the Client.
Investment Management: TFA will generally construct a portfolio, consisting of institutional no-load mutual funds with low annual expense ratios and other low-cost investment solutions such as exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. While TFA generally does not recommend individual common stocks, Clients may at times, desire to retain certain existing holdings, or to purchase additional stocks. Reasons for a Client’s desire might include emotional ties to the stock and/or the presence of substantial unrealized capital gains. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
TFA’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. TFA will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. TFA evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. TFA may recommend, on occasion, redistributing investment allocations to diversify the portfolio. TFA may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. TFA may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk, exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
At no time will

TFA accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary 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. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to Page 6 another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor.
Financial Planning Services TFA will typically provide a variety of financial planning and consulting services to Clients integrated into a WM or WMLF relationship. However, TFA also provides financial planning services on a standalone engagement pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. A financial plan is designed to help the Client with all aspects of financial planning without necessarily including ongoing investment management after the financial plan is completed.
The planning process typically involves 3 to 4 meetings between the Advisor and the Client. The financial planning topics discussed during those meeting may include, but are not limited to: a summary of holdings statement; a cash flow statement; a review of investment accounts, including reviewing asset allocation and providing repositioning recommendations; strategic tax planning; a review of retirement accounts and plans including recommendations; a review of insurance policies and recommendations for changes, if necessary; one or more retirement scenarios; estate planning review and recommendations; and education planning with funding recommendations.
Detailed investment advice and specific recommendations are provided as part of a financial plan.
Implementation of the recommendations is at the discretion of the Client.
TFA may also refer Clients to an accountant, attorney or another specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement these transactions through the Advisor.
Retirement Plan Advisory Services TFA provides 3(21) retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Plan Participant Enrollment and Education Tracking These services are provided by TFA serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of TFA’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement.
Donor Advised Fund Services The Advisor also provides the Schwab Charitable Donor Advised Fund (“DAF”) to Clients via Schwab Charitable, a web-based interface and administrative solution for charitable giving to philanthropic vehicles via the Schwab Page 7 Charitable Fund (“SCF”), an IRS approved philanthropic vehicle established for the purpose of managing charitable donations contributed by or on behalf of donor clients. The DAF allows the Advisor to actively manage assets that have been donated to and are owned by SCF, with the ability of charging an investment management fee. At this time, TFA does not charge an investment management fee on these accounts. The Advisor’s DAF participation is in conjunction with approval by the SCF Investment Committee for the Advisor to operate as an advisory manager on the platform. The Schwab Charitable Fund is an independent company and unaffiliated with the Advisor.
C. Client Account Management Prior to engaging TFA to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: ●Establishing an Investment Strategy – TFA, in connection with the Client, will develop a strategy that seeks to achieve the Client’s investment goals and objectives.
●Asset Allocation – TFA will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
●Portfolio Construction – TFA will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
●Investment Management and Supervision – TFA will provide investment management and ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs TFA typically includes the securities trading costs for the purchase or sale of investments (herein “Covered Costs”) under its WM orWMLFservices as part of its overall investment advisory fee. The bundling of trading costs and advisory fees in considered a “Wrap Fee Program”. While many Wrap Fee Programs include pre-defined investment options, TFA customizes its WM andWMLFservices for its Clients. The Wrap Fee Program is solely offered by TFA to provide these services for a single fee. The Wrap Fee Program Brochure supplements the disclosures in this section and Item 5: Fees and Compensation below. The Wrap Fee Program Brochure is included as Appendix 1 of this Disclosure Brochure.
E. Assets Under Management As of December 31, 2023, TFA manages $981,135,403 in Client assets, $970,420,607 of which are managed on a discretionary basis and $10,714,796 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.