AFFILIATED FINANCIAL ADVISORS INC

Item 1: Cover Page F O R M A D V P A R T 2 A D I S C L O S U R E B R O C H U R E Office Address: 2600 North Mayfair Road, Suite 200 Milwaukee, WI 53226 Tel: Fax: (414) 476-4999 (414) 476-4889 Email: info@affiliatedfa.com Website: https://www.affiliatedfa.com February 26, 2026 This brochure provides information about the qualifications and business practices of Affiliated Financial Advisors, Inc.. Being registered as an investment adviser does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at (414) 476-4999. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by ADDITIONAL INFORMATION ABOUT AFFILIATED FINANCIAL ADVISORS, INC. (CRD any state securities authority. #108154) IS AVAILABLE ON THE SEC’S WEBSITE AT WWW.ADVISERINFO.SEC.GOV i  Item 2: Material Changes Annual Update Material Changes since the Last Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. There have been a number of material changes to the Form ADV brochure since the last filing made on December 1, 2025. • Item 4 has been updated with the firm’s most recent assets under management calculation. Full Brochure Available This Firm Brochure being delivered is the complete brochure for the Firm. ii  Item 3: Table of Contents Form ADV – Part 2A – Firm Brochure Item 1: Cover Page .................................................................................................................................. i Item 2: Material Changes .................................................................................................................... ii Annual Update ................................................................................................................................................................... ii Material Changes since the Last Update.................................................................................................................. ii Item 3: Table of Contents ................................................................................................................... iii Full Brochure Available .................................................................................................................................................. ii Item 4: Advisory Business .................................................................................................................. 1 Firm Description ............................................................................................................................................................... 1 Types of Advisory Services ........................................................................................................................................... 1 Client Tailored Services and Client Imposed Restrictions ............................................................................... 1 Wrap Fee Programs ......................................................................................................................................................... 1 Item 5: Fees and Compensation ....................................................................................................... 1 Client Assets Under Management .............................................................................................................................. 1 Method of Compensation and Fee Schedule .......................................................................................................... 1 Client Payment of Fees ................................................................................................................................................... 2 Additional Client Fees Charged ................................................................................................................................... 2 Prepayment of Client Fees ............................................................................................................................................ 2 Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 2 External Compensation for the Sale of Investment Related Products to Clients ................................... 2 Item 7: Types of Clients ....................................................................................................................... 3 Sharing of Capital Gains ................................................................................................................................................. 2 Description .......................................................................................................................................................................... 3 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 3 Account Minimums .......................................................................................................................................................... 3 Methods of Analysis ......................................................................................................................................................... 3 Investment Strategy ........................................................................................................................................................ 3 Item 9: Disciplinary Information ..................................................................................................... 6 Security Specific Material Risks .................................................................................................................................. 4 Criminal or Civil Actions ................................................................................................................................................ 6 iii Administrative Enforcement Proceedings ............................................................................................................. 6  Item 10: Other Financial Industry Activities and Affiliations ............................................... 6 Self- Regulatory Organization Enforcement Proceedings ............................................................................... 6 Broker-Dealer or Representative Registration .................................................................................................... 6 Futures or Commodity Registration ......................................................................................................................... 6 Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................... 6 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ................ 7 Trading ..................................................................................................................................................... 7 Code of Ethics Description ............................................................................................................................................ 7 Investment Recommendations Involving a Material Financial Interest and Conflict of Interest.... 7 Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest ... 7 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Item 12: Brokerage Practices ........................................................................................................... 8 Transactions and Conflicts of Interest ..................................................................................................................... 8 Factors Used to Select Broker-Dealers for Client Transactions .................................................................... 8 Item 13: Review of Accounts ............................................................................................................. 9 Aggregating Securities Transactions for Client Accounts ................................................................................ 9 Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved ................................................................................................................................................................................ 9 Review of Client Accounts on Non-Periodic Basis .............................................................................................. 9 Item 14: Client Referrals and Other Compensation ................................................................ 10 Content of Client Provided Reports and Frequency ........................................................................................... 9 Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest ............................................................................................................................................................................... 10 Item 15: Custody .................................................................................................................................. 10 Advisory Firm Payments for Client Referrals .................................................................................................... 10 Item 16: Investment Discretion ..................................................................................................... 10 Account Statements ...................................................................................................................................................... 10 Item 17: Voting Client Securities ................................................................................................... 10 Discretionary Authority for Trading...................................................................................................................... 10 Item 18: Financial Information ...................................................................................................... 11 Proxy Votes ...................................................................................................................................................................... 10 Balance Sheet .................................................................................................................................................................. 11 iv  Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients ............................................................................................................................................................................ 11 Bankruptcy Petitions during the Past Ten Years .............................................................................................. 11 v  Item 4: Advisory Business Firm Description Types of Advisory Services Affiliated Financial Advisors, Inc. (“AFA”) was founded in 1992. George M. Schmidley is 100% owner. Client Tailored Services and Client Imposed Restrictions ASSET MANAGEMENT AFA offers discretionary and non-discretionary asset management services to advisory Clients. AFA will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The Client will authorize AFA discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. Wrap Fee Programs The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. In the event of change of ownership of AFA, client retains the right to opt-out of investment advisor agreement and services with 30 day notice. Client Assets Under Management AFA does not sponsor any wrap fee programs. AFA has the following Client assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $0 $541,478,694 12/31/2025 Item 5: Fees and Compensation Method of Compensation and Fee Schedule ASSET MANAGEMENT AFA offers discretionary direct asset management services to advisory Clients. AFA charges an annual investment advisory fee based on the total assets under management. AFA’s standard fee for Investment Supervisory Services is an annual fee, payable quarterly in arrears, of 1/2 of 1% to 1% (0.50%-1.0%) of the value of assets maintained in the account subject to AFA’s supervision. This is a flat fee, the entire portfolio is charged the same asset management fee. For example, a Client with $750,000 under management would pay a maximum of $7,500 on an annual basis. $750,000 x 1.0% = $7,500. The annual fee is negotiable based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with - 1 -  Clients, etc.). Fees are billed quarterly in arrears based on the amount of assets managed at the close of business on the last business day of the previous quarter. Client Payment of Fees Lower fees for comparable services may be available from other sources. Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement with no obligation and without penalty. After the initial five (5) business days, the agreement may be terminated by AFA with thirty (30) days written notice to Client and by the Client at any time with written notice to AFA. If cash and/or securities are deposited into or withdrawn from an existing account mid-billing period, a prorated fee will be charged for that portion of the account. For accounts opened or closed mid-billing period, fees will be prorated based on the days services are provided during the given period. All unpaid earned fees will be due to AFA. Client shall be given thirty (30) days prior written notice of any increase in fees. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. Additional Client Fees Charged Fees for asset management services are deducted from a designated Client account. The Client must consent in advance to direct debiting of their investment account. Prepayment of Client Fees Custodians may charge transaction fees and other related costs on the purchases or sales of mutual funds, equities, bonds, options and exchange-traded funds. Mutual funds, money market funds and exchange-traded funds also charge internal management fees, which are disclosed in the fund’s prospectus. AFA does not receive any compensation from these fees. All of these fees are in addition to the management fee you pay to AFA. For more details on the brokerage practices, see Item 12 of this brochure. External Compensation for the Sale of Investment Related Products to Clients AFA does not require any prepayment of fees. Investment Advisor Representatives of AFA receive external compensation from sales of investment related products such as insurance as licensed insurance agents. This represents a conflict of interest because it gives an incentive to recommend products based on the commission received. This conflict is mitigated by disclosures, procedures, and AFA’s fiduciary obligation to place the best interest of the Client first and Clients are not required to purchase any products or services. Clients have the option to purchase these products through another insurance agent of their choosing. Item 6: Performance-Based Fees and Side-by-Side Management Sharing of Capital Gains Fees are not based on a share of the capital gains or capital appreciation of managed securities. AFA does not use a performance-based fee structure because of the conflict of interest. Performance based compensation may create an incentive for an advisor to recommend an investment that may carry a higher degree of risk to the Client. - 2 -  Item 7: Types of Clients Description Account Minimums AFA generally provides investment advice to individuals, high net worth individuals, trusts, estates and small business entities. Client relationships vary in scope and length of service. AFA does not require a minimum to open or maintain an account. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include Efficient Market Theory, fundamental analysis, technical analysis, and cyclical analysis. Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Efficient Market Theory is an investment concept that suggests financial markets are generally efficient at pricing securities. According to this theory, publicly available information is quickly reflected in current market prices, making it difficult to consistently achieve returns that outperform the overall market through active security selection or market timing. Under this theory, a portfolio’s performance is largely influenced by overall market movements rather than individual security selection. As a result, investment strategies aligned with Efficient Market Theory often emphasize long-term investing, diversification, and, in some cases, the use of low-cost index or passive investment products. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns. Investment Strategy Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are twofold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. The investment strategy for a specific Client is based upon the objectives stated by the Client during consultations. The Client may change these objectives at any time by providing written notice to AFA. Each Client executes a Client profile form or similar form that documents their objectives and their desired investment strategy. Other strategies may include long-term purchases, short-term purchases. - 3 -  Security Specific Material Risks All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment • Market Risk risks and should discuss these risks with AFA: • : The prices of securities in which clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by a fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines Interest-rate Risk in market value. • : Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less Inflation Risk attractive, causing their market values to decline. : When any type of inflation is present, a dollar today will buy more than a • Currency Risk dollar next year, because purchasing power is eroding at the rate of inflation. : Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as • Reinvestment Risk exchange rate risk. • Liquidity Risk : This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Management Risk: : Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Equity Risk: The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the expected time frame, the overall performance of the client’s portfolio may suffer. • Fixed Income Risk: Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the client’s overall portfolio. Small-cap and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, - 4 -  • the value of fixed income securities held by a fund is likely to decrease. A nominal Investment Companies Risk: interest rate is the sum of a real interest rate and an expected inflation rate. • Cash and Cash Equivalents Risk: When a client invests in open end mutual funds or ETFs, the client indirectly bears their proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, which may be duplicative. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. Adviser has no control over the risks taken by the underlying funds in which client invests. • Derivatives Risk: Cash and cash equivalents consist of investments like money market funds, certificates of deposit (CDs), Treasury bills, and short-term government bonds. They are generally considered low-risk compared to other asset classes. While they offer safety, liquidity, and stability, they come with certain risks, such as inflation, interest rate fluctuations, and opportunity costs. • Long-term purchases Funds in a client’s portfolio may use derivative instruments. The value of these derivative instruments derives from the value of an underlying asset, currency or index. Investments by a fund in such underlying funds may involve the risk that the value of the underlying fund’s derivatives may rise or fall more rapidly than other investments, and the risk that an underlying fund may lose more than the amount that it invested in the derivative instrument in the first place. Derivative instruments also involve the risk that other parties to the derivative contract may fail to meet their obligations, which could cause losses. • Short-term purchases : Long-term investments are those vehicles purchased with the intention of being held for more than one year. Typically the expectation of the investment is to increase in value so that it can eventually be sold for a profit. In addition, there may be an expectation for the investment to provide income. One of the biggest risks associated with long-term investments is volatility, the fluctuations in the financial markets that can cause investments to lose value. : Short-term investments are typically held for one year or less. Generally there is not a high expectation for a return or an increase in value. Typically, short-term investments are purchased for the relatively greater degree of principal protection they are designed to provide. Short-term investment vehicles may be subject to purchasing power risk — the risk that your investment’s return will not keep up with • Trading risk inflation. : Investing involves risk, including possible loss of principal. There is no • Trading on Margin: assurance that the investment objective of any fund or investment will be achieved. In a cash account, the risk is limited to the amount of money that has been invested. In a margin account, risk includes the amount of money invested plus the amount that has been loaned. As market conditions fluctuate, the value of marginable securities will also fluctuate, causing a change in the overall account balance - 5 -  • Leveraged Risk and debt ratio. As a result, if the value of the securities held in a margin account depreciates, the client will be required to deposit additional cash or make full payment of the margin loan to bring account back up to maintenance levels. Clients who cannot comply with such a margin call may be sold out or bought in by the brokerage firm. • Counterparty Risk : The risks involved with using leverage may include compounding of returns (this works both ways – positive and negative), possible reset periods, volatility, use of derivatives, active trading and high expenses. : The risk that the other party to an agreement will default or fail to perform its contractual obligations. In an options contract, counterparty risk is the risk to the option buyer that the option writer will not buy or sell the underlying as agreed. Item 9: Disciplinary Information Criminal or Civil Actions Administrative Enforcement Proceedings AFA and its management have not been involved in any criminal or civil action. Self- Regulatory Organization Enforcement Proceedings AFA and its management have not been involved in administrative enforcement proceedings. AFA and its management have not been involved in any self-regulatory organizational enforcement proceedings that are material to a Client’s or prospective Client’s evaluation of AFA or the integrity of its management. Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration Futures or Commodity Registration AFA is not registered as a broker-dealer and no affiliated representatives of AFA are registered representatives of a broker-dealer. Material Relationships Maintained by this Advisory Business and Conflicts of Interest Neither AFA nor its affiliated representatives are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor. Some Investment Advisor Representatives of AFA are independent insurance agents. Approximately 2% of certain Investment Advisor Representatives of AFA’s time is spent on these activities. The Investment Advisor Representatives will offer Clients services from those activities. As an insurance agent, Investment Advisor Representatives will receive separate yet typical compensation. These practices represent conflicts of interest because it gives an incentive to recommend products based on the commission amount received. This conflict is mitigated by disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the Client first and the Clients are not required to purchase any products. Clients have the option to purchase these products through another insurance agent of their choosing. - 6 -  Recommendations or Selections of Other Investment Advisors and Conflicts of Interest AFA does not select or recommend other investment advisors. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Description include employees and/or The affiliated persons (affiliated persons independent contractors) of AFA have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of AFA affiliated persons and addresses conflicts that may arise. The Code defines acceptable behavior for affiliated persons of AFA. The Code reflects AFA and its supervised persons’ responsibility to act in the best interest of their Client. One area which the Code addresses is when affiliated persons buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow any affiliated persons to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our Clients. AFA’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other affiliated person, officer or director of AFA may recommend any transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. AFA’s Code is based on the guiding principle that the interests of the Client are our top priority. AFA’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our Clients and must diligently perform that duty to maintain the complete trust and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of either affiliated persons or the company. The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-public information regarding any Clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. AFA will provide a copy of the Code of Ethics to any Client or prospective Client upon Investment Recommendations Involving a Material Financial Interest and Conflict of request. Interest AFA and its affiliated persons do not recommend to Clients securities in which we have a material financial interest. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest AFA and its affiliated persons may buy or sell securities that are also held by Clients. In order to mitigate conflicts of interest such as trading ahead of Client transactions, affiliated persons are required to disclose all reportable securities transactions as well as provide AFA with copies of their brokerage statements. - 7 -  Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest AFA does not have a material financial interest in any securities being recommended. However, affiliated persons may buy or sell securities at the same time they buy or sell securities for Clients. In order to mitigate conflicts of interest such as front running, affiliated persons are required to disclose all reportable securities transactions as well as provide AFA with copies of their brokerage statements. The Chief Compliance Officer of AFA is George M. Schmidley. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Item 12: Brokerage Practices Factors Used to Select Broker-Dealers for Client Transactions AFA will recommend the use of a particular broker-dealer based on their duty to seek best execution for the client, meaning they have an obligation to obtain the most favorable terms for a client under the circumstances. The determination of what may constitute best execution and price in the execution of a securities transaction by a broker involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is affected, the ability to affect the transaction where a large block is involved, the operational facilities of the broker-dealer, the value of an ongoing relationship with such broker and the financial strength and stability of the broker. AFA will select appropriate brokers based on a number of factors including but not limited to their relatively low transaction fees, reporting ability, execution capability (speed and accuracy), financial stability and reputation, access to markets, technology and reporting platforms, quality of client service and availability of investment research and other brokerage services. AFA relies on its broker to provide its execution services at the best prices available. Lower fees for comparable services may be available from other sources. Clients pay for any and all custodial fees in addition to the advisory fee charged by AFA. AFA does not receive any portion of the trading fees. • Research and Other Soft Dollar Benefits AFA will recommend the use of Charles Schwab & Company as custodian. The Securities and Exchange Commission defines soft dollar practices as arrangement under which products or services other than execution services are obtained by AFA from or through a broker-dealer in exchange for directing Client transactions to the broker-dealer. Although AFA has no formal soft dollar arrangements, AFA may receive products, research and/or other services from custodians or broker-dealers connected to client transactions or “soft dollar benefits”. As permitted by Section 28(e) of the Securities Exchange Act of 1934, AFA receives economic benefits as a result of commissions generated from securities transactions by the custodian or broker-dealer from the accounts of AFA. AFA cannot ensure that a particular client will benefit from soft dollars or the client’s transactions paid for the soft dollar benefits. AFA does not seek to proportionately - 8 -  allocate benefits to client accounts to any soft dollar benefits generated by the accounts. • Brokerage for Client Referrals A conflict of interest exists when AFA receives soft dollars which could result in higher commissions charged to Clients. This conflict is mitigated by the fact that AFA has a fiduciary responsibility to act in the best interest of its Clients and the services received are beneficial to all Clients. • Directed Brokerage AFA does not receive client referrals from any custodian or third party in exchange for using that broker-dealer or third party. Aggregating Securities Transactions for Client Accounts Clients who direct brokerage outside our recommendation may be unable to achieve the most favorable execution of client transactions as client directed brokerage may cost clients more money. For example, in a directed brokerage account, you may pay higher brokerage commissions because we may not be able to aggregate orders to reduce transaction costs, or you may receive less favorable prices. Not all advisors require their clients to direct brokerage. Not all advisors require their clients to direct brokerage. AFA manages each account separately, and therefore, does not aggregate purchases and sales and other transactions. If orders are not aggregated, some clients purchasing securities around the same time may receive a less favorable price than other clients which may cost clients more money. Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Review of Client Accounts on Non-Periodic Basis Account reviews are performed on a regular basis, but no less than annually, by the Chief Compliance Officer of AFA, George M. Schmidley. Account reviews are performed more frequently when market conditions dictate. Reviews of Client accounts include, but are not limited to, a review of Client documented risk tolerance, adherence to account objectives, investment time horizon, and suitability criteria, reviewing target allocations of each asset class to identify if there is an opportunity for rebalancing, and reviewing accounts for tax loss harvesting opportunities. Content of Client Provided Reports and Frequency Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new investment information, and changes in a Client's own situation. Clients receive written account statements no less than quarterly for managed accounts. Account statements are issued by AFA’s custodian. Client receives confirmations of each transaction in account from custodian and an additional statement during any month in which a transaction occurs. Performance reports will be provided by AFA at least annually to Clients with assets under management - 9 -  Item 14: Client Referrals and Other Compensation Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest Advisory Firm Payments for Client Referrals AFA receives additional economic benefits from external sources as described above in Item 12. AFA does not compensate for Client referrals. Item 15: Custody Account Statements All assets are held at qualified custodians, which means the custodians provide account statements directly to Clients at their address of record at least quarterly. Clients are urged to carefully compare the account statements received directly from their custodians to any documentation or reports prepared by AFA. AFA is deemed to have limited custody solely because advisory fees are directly deducted from Client’s accounts by the custodian on behalf of AFA. Item 16: Investment Discretion Discretionary Authority for Trading AFA requires discretionary authority to manage securities accounts on behalf of Clients. AFA has the authority to determine, without obtaining specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The client will authorize AFA discretionary authority as stated within the Investment Advisory Agreement. AFA allows Clients to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar document. These restrictions must be provided to AFA in writing. The Client approves the custodian to be used. AFA does not receive any portion of the transaction fees or commissions paid by the Client to the custodian. Item 17: Voting Client Securities Proxy Votes AFA will vote proxies on behalf of a Client if, in its investment agreement with AFA, the Client has delegated to AFA the authority to vote proxies on its behalf. AFA has adopted and implemented policies and procedures (“Proxy Voting Procedures”) to ensure that, where it has voting authority, proxy matters are handled in the best interest of the Clients, in accordance with AFAs fiduciary duties. AFA has adopted procedures to implement the firm's policy and conducts reviews to monitor and ensure the firm's policy is observed, implemented properly and amended or updated, as appropriate. These policies and procedures, which are maintained in a separate document available upon request, include but are not limited to, the following: • • General Policies Disclosure to Third Parties - 10 -  • • • Proxy Voting Designee Conflicts of Interest Recordkeeping and Disclosure Item 18: Financial Information Balance Sheet A balance sheet is not required to be provided to Clients because AFA does not serve as a custodian for Client funds or securities and AFA does not require prepayment of fees of more than $500 per Client and six months or more in advance. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients Bankruptcy Petitions during the Past Ten Years AFA has no condition that is reasonably likely to impair our ability to meet contractual commitments to our Clients. AFA has not had any bankruptcy petitions in the last ten years. - 11 -