TIM provides financial planning and investment management services through a series of asset management platform offerings. Prior to engaging TIM to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with TIM, setting forth the terms and conditions under which TIM renders its services (collectively the “Agreement”). TIM has been in business since 1998 and is principally owned by John Edward Foster II and Todd Michael Foster. As of December 31, 2023, the firm had $1,196,267,919 in assets under management. Although TIM offers non- discretionary services, that vast majority of its assets were managed on a discretionary basis (85%). This Disclosure Brochure describes the business of TIM. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of TIM’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on TIM’s behalf and is subject to TIM’s supervision or control. Financial Planning and Consulting Services TIM offers its clients a broad range of comprehensive financial planning services. Income tax preparation services are available from an independent tax and accounting firm. These services are only offered to certain ongoing investment management clients, as described below. Investment Management Services Clients can engage TIM to manage all or a portion of their assets on a discretionary basis. The firm offers three different levels of investment management services, which are discussed below:
• TIM Basic - This is a service where clients have TIM manage their employer-sponsored retirement plans. TIM Basic is only available to clients who are unable to take fees out of their employer-sponsored retirement accounts and is the only service these clients are able to select. Under this program, the Firm offers one actively traded investment model portfolio, which generally consists of mutual funds and exchange-traded funds (“ETFs”). The program also consists of weekly commentary and weekly webcasts and is targeted to aviation professionals designed to give them an understanding of their employer- sponsored retirement plans. For clients who wish to subscribe to TIM’s commentary and webcast and receive model portfolio trade allocations but retain the authority to trade their accounts, TIM offers a Basic subscription service with allocations but no investment supervisory or investment management services. Moreover, the Firm’s investment professionals are available to clients in this program to answer any questions. This program does not include financial planning, and clients are able to engage the firm for financial planning at an additional fee.
• TIM Portfolio - The Firm has a more enhanced offering to TIM Basic, known as “TIM Portfolio,” which is a more comprehensive investment management program. TIM Portfolio is available to clients whose employer airlines are able to take fees out directly from their employer-sponsored retirement accounts. TIM Portfolio is also available for a variety of accounts including Individual Retirement Accounts (IRAs), trust accounts, individual and joint accounts, and other accounts that TIM may accept in its discretion for investment management services. TIM Portfolio includes all the same benefits as TIM Basic but offers clients the opportunity to invest in one of the five model portfolios, which generally consist of mutual funds and ETFs, and are managed by the Firm based on the client’s age and risk tolerance. In addition, while TIM’s advisers are available to answer questions, TIM Portfolio clients also have one scheduled annual checkup call per year with the Firm to discuss developments in their financial situations. This program does not include financial planning, and clients are able to engage the firm for financial planning at an additional fee.
• TIM Premier - The Firm’s most encompassing service offering is TIM Premier, which offers clients a more robust wealth management platform that includes all the services of TIM Portfolio. TIM Premier is available to clients whose employer airlines are able to take fees out directly from their employer- sponsored retirement accounts. TIM Premier is also available for a variety of accounts including Individual Retirement Accounts (IRAs), trust accounts, individual and joint accounts, and other accounts that TIM may accept in its discretion for investment management services. While the model portfolios available to TIM Premier clients are generally comprised of mutual funds and ETFs, TIM may incorporate other types of securities into TIM Premier client accounts, as appropriate for the client’s investment objectives. Moreover, in addition to receiving a scheduled annual call to review their financial plan,

TIM Premier clients also receive scheduled quarterly check-in calls. TIM Premier offers clients financial planning, insurance needs analysis, tax preparation provided by an independent tax and accounting firm (discussed in Item 14), estate planning consultation provided by an independent law firm (discussed in Item 14), and social security optimization services, which are included in the overall fee. Clients are advised to promptly notify TIM if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon TIM’s management services. TIM Portfolio and Premier clients can impose reasonable restrictions on the management of their account if, in TIM’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Information Regarding Potential Conflicts of Interest Although we seek to avoid them, our firm has actual or potential conflicts of interest arising from our advisory services. These include, but are not limited to:
• Conflicts related to allocating time and resources between client accounts, allocation of brokerage commissions and investment opportunities generally. For further information on our brokerage and allocation policies, and related conflicts of interest, please refer to Item 12 below.
• Conflicts related to asset-based fees. At times our investment professionals will recommend that a client move assets from another investment account to one managed by our firm. This would result in a higher total advisory fee for that investment professional and generate revenue for the firm. See the disclosure in Item 4 discussing the recommendation of rollovers and transfers to TIM for more information. There is a conflict of interest whenever we encourage clients to move their assets to our firm. For further information, please refer to Item 5 which discusses the fees we earn when providing advisory services.
• Conflicts related to investing in securities recommended to clients and contemporaneous trading of securities (i.e., personal trading) by the firm and its related persons. Please refer to Item 11 for further information.
• Conflicts related to third parties. When appropriate, we will recommend third parties to advise a client on matters including but not limited to: legal, tax or accounting advice. These recommendations are sometimes made because of existing relationships our firm and its employees have with these groups or individuals. We do not currently have any formal solicitor or referral arrangements. Actual or potential conflicts of interest generally can be addressed in several ways, including prohibiting the conduct that gives to the conflict of interest, implementing procedures to prevent a person from gaining or utilizing knowledge that potentially give rise to a conflict; establishing parameters for conduct that are designed to protect client interests or limit the benefit that creates the conflict of interest, or disclosing the conflict of interest to our clients. Our firm has adopted a Code of Ethics. (Please refer to Item 11 below for further information on our Code of Ethics) and we also have policies and procedures in place to mitigate and address conflicts of interest. We believe that such policies and procedures are reasonably designed to treat clients equitably and to advance the best interests of the clients. The clients' best interest is paramount in any situation involving a conflict of interest. Recommending Rollovers and Transfers to TIM Our firm has an inherent conflict of interest in recommending you rollover or transfer your accounts to an account managed by us since we have an incentive to generate compensation for the firm. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we 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. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. It is important that you understand the differences between these types of accounts and to decide whether a rollover is best for the client. Prior to proceeding, if you have any questions, please contact the firm’s Chief Compliance Officer, or call TIM’s main number as listed on the cover page of this brochure.