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F I D U C I A R Y S E R V I C E S
F I D U C I A R Y S E R V I C E S
AFG Fiduciary Services Limited Partnership
Form ADV Part 2A – Disclosure Brochure
Effective: March 5, 2026
This Form ADV 2A (“Disclosure Brochure”) provides information about the qualifications and business practices
of AFG Fiduciary Services Limited Partnership (“AFG” or the “Advisor”). If you have any questions about the
content of this Disclosure Brochure, please contact the Advisor at (781) 741-2540.
AFG is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities
authority. Registration of an investment advisor does not imply any specific level of skill or training. This
Disclosure Brochure provides information about AFG to assist you in determining whether to retain the Advisor.
Additional information about AFG and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 309943.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplements"). The Disclosure Brochure provides information about a variety of topics relating to an advisor’s
business practices and conflicts of interest. The Brochure Supplements provide information about Advisory
Persons of AFG. For convenience, the Advisor has combined these documents into a single disclosure
document.
AFG believes that communication and transparency are the foundation of its relationship with clients and will
continually strive to provide you with complete and accurate information at all times. AFG encourages all current
and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the
Advisor.
Material Changes
There have been no material changes to this Disclosure Brochure since the last annual amendment filing on
February 13th, 2025.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices,
changes in regulations, or routine annual updates as required by the securities regulators. This complete
Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material
change occurs in the business practices of AFG.
At any time, you may view the current Disclosure Brochure online at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 309943. You
may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (781) 741-2540.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 2
Item 3 – Table of Contents
Item 1 – Cover Page ...................................................................................................................................... 1
Item 2 – Material Changes ............................................................................................................................ 2
Item 3 – Table of Contents ........................................................................................................................... 3
Item 4 – Advisory Services .......................................................................................................................... 4
A. Firm Information ................................................................................................................................................... 4
B. Advisory Services Offered ................................................................................................................................... 4
C. Client Account Management ................................................................................................................................ 6
D. Wrap Fee Programs ............................................................................................................................................ 6
E. Assets Under Management ................................................................................................................................. 6
Item 5 – Fees and Compensation ................................................................................................................ 6
A. Fees for Advisory Services .................................................................................................................................. 6
B. Fee Billing ............................................................................................................................................................ 7
C. Other Fees and Expenses ................................................................................................................................... 7
D. Advance Payment of Fees and Termination ........................................................................................................ 8
E. Compensation for Sales of Securities .................................................................................................................. 8
Item 6 – Performance-Based Fees and Side-By-Side Management ......................................................... 9
Item 7 – Types of Clients .............................................................................................................................. 9
Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss ................................................ 9
A. Methods of Analysis ............................................................................................................................................. 9
B. Risk of Loss ....................................................................................................................................................... 10
Item 9 – Disciplinary Information .............................................................................................................. 11
Item 10 – Other Financial Industry Activities and Affiliations ................................................................ 11
Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading .... 12
A. Code of Ethics .................................................................................................................................................... 12
B. Personal Trading with Material Interest ............................................................................................................. 12
C. Personal Trading in Same Securities as Clients ................................................................................................ 12
D. Personal Trading at Same Time as Client ......................................................................................................... 12
Item 12 – Brokerage Practices ................................................................................................................... 12
A. Recommendation of Custodian[s] ...................................................................................................................... 12
B. Aggregating and Allocating Trades .................................................................................................................... 13
Item 13 – Review of Accounts ................................................................................................................... 13
A. Frequency of Reviews ....................................................................................................................................... 13
B. Causes for Reviews ........................................................................................................................................... 14
C. Review Reports ................................................................................................................................................. 14
Item 14 – Client Referrals and Other Compensation ............................................................................... 14
A. Compensation Received by AFG ....................................................................................................................... 14
B. Client Referrals from Promoters ........................................................................................................................ 14
Item 15 – Custody ....................................................................................................................................... 15
Item 16 – Investment Discretion ................................................................................................................ 15
Item 17 – Voting Client Securities ............................................................................................................. 15
Item 18 – Financial Information ................................................................................................................. 15
Form ADV Part 2A – Appendix 1 ............................................................................................................... 16
Form ADV Part 2B – Brochure Supplement: Kenney, Brian ................................................................... 24
Form ADV Part 2B – Brochure Supplement: McCarthy, Joseph ............................................................ 27
Form ADV Part 2B – Brochure Supplement: Skahan, Susan ................................................................. 31
Privacy Policy ............................................................................................................................................. 33
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 3
Item 4 – Advisory Services
A. Firm Information
AFG Fiduciary Services Limited Partnership (“AFG” or the “Advisor”) is a registered investment advisor with the
U.S. Securities and Exchange Commission (“SEC”). AFG is organized as a limited partnership organized under
the laws of the Commonwealth of Massachusetts. AFG was founded in June 2020 and became a registered
investment advisor in September 2020. The General Partner of AFG is AFG GP, LLC. Brian M. Kenney is the
Principal Officer of AFG. This Disclosure Brochure provides information regarding the qualifications, business
practices, and the advisory services provided by AFG.
B. Advisory Services Offered
AFG offers advisory services to individuals, high net worth individuals, families, trusts, estates, businesses, and
retirement plans (each referred to as a “Client”).
The Advisor serves 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. AFG’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.
AFG provides a holistic approach to its wealth advisory services. Client engagements typically include
comprehensive financial planning and investment management services as described below. Services are
tailored to the unique needs of each Client.
Wealth Management Services
AFG provides customized wealth management solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management and planning
services. AFG works closely with each Client to identify their investment goals and objectives as well as risk
tolerance and financial situation in order to create an investment strategy. AFG customizes its investment
management services for its Clients. Portfolios may be constructed using open-end mutual funds, exchange-
traded funds (“ETFs”), individual equity securities, and or individual fixed income securities. For certain Clients,
the Advisor may utilize tax-free municipal bonds and other types of investments. For certain Clients, the Advisor
may employ leveraged ETFs and or the short-term use of margin. For mutual funds, the Advisor selects active
and passive managers and will seek institutional share classes when available. The Advisor may retain other
types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related
reasons, or other reasons as identified between the Advisor and the Client.
AFG’s investment approach is primarily long-term investment 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. AFG will construct, implement and monitor the portfolio to ensure it meets the goals,
objectives, circumstances, and risk tolerance agreed to by the Client. 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.
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
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 earns a new
(or increases 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.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 4
At no time will AFG 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 their designated account[s] at the
Custodian, pursuant to the advisory agreement. Please see Item 12 – Brokerage Practices.
Financial Planning Services
AFG will typically provide a variety of financial planning and consulting services to Clients either as a component
of wealth management services or as a separate service, pursuant to the terms of the agreement with the
Client. Services are offered in several areas of a Client’s financial situation, depending on their goals and
objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a
specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting
may encompass one or more areas of need, including but not limited to investment planning, retirement
planning, personal savings, education savings, insurance needs, and other areas of a Client’s financial situation.
A financial plan developed for or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings, and/or charitable giving programs.
In certain circumstances, AFG may also refer Clients to an accountant, attorney, or other specialists, as
appropriate for the Client’s unique situation. For certain financial planning engagements, the Advisor will
generally provide a written report that contains 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 (6) months of the contract date, assuming all information and documents requested are provided
promptly.
Financial planning 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
amount of 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 the transaction through
the Advisor.
Retirement Plan Advisory Services
AFG provides 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:
Investment Policy Statement (“IPS”) Design and Monitoring
Investment Oversight Services (ERISA 3(21))
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
•
•
• Discretionary Investment Management (ERISA (3(38))
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
These services are provided by AFG 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 AFG’s fiduciary status, the specific services to be rendered,
and all direct and indirect compensation the Advisor reasonably expects under the engagement.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 5
C. Client Account Management
Prior to engaging AFG to provide 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 – AFG will develop a strategy that seeks to achieve the Client’s
goals and objectives.
• Asset Allocation – AFG 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 – AFG will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
•
Investment Management and Supervision – AFG will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
AFG includes securities transaction fees, custody fees, commission fees, administrative fees, third-party service
fees, and other investment costs together with its investment advisory fees. Including these fees into a single
asset-based fee is considered a “Wrap Fee Program.” The Advisor customizes its investment management
services for its Clients. The Advisor sponsors the AFG Wrap Fee Program solely as a supplemental disclosure
regarding the combination of fees. Depending on the level of trading required for the Client’s account[s] in a
particular year, the Client may pay more or less in total fees than if the Client paid its own transaction fees.
Please see Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this Disclosure
Brochure.
E. Assets Under Management
As of December 31, 2025, AFG manages $166,256,181 in Client assets, all of which are managed on a
discretionary basis. Clients may request more current information at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or
more written agreements with the Advisor.
A. Fees for Advisory Services
Wealth Management Services
Wealth management fees are paid monthly, in advance of each month, pursuant to the terms of the wealth
management agreement. Wealth management fees are based on the market value of assets under management
at the end of the prior month. Wealth management fees range from 0.50% to 1.50% annually based on several
factors, including the scope and complexity of the services to be provided, the level of assets to be managed, and
the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements,
portfolio restrictions, and other complexities may be charged a higher fee.
The wealth management fee in the first month of service is prorated from the inception date of the account[s] to the
end of the first month. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into
consideration the aggregate assets under management with the Advisor. All securities held in accounts managed
by AFG will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the
Custodian’s valuation to ensure accurate billing.
The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and
other related costs and expenses described in Item 5.C. below, which may be incurred by the Client. However, the
Advisor shall not receive any portion of these commissions, fees, and costs.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 6
Clients may make additions to and withdrawals from their account[s] at any time, subject to AFG’s right to
terminate an account. Additions may be in cash or securities provided that AFG reserves the right to liquidate any
transferred securities or decline to accept particular securities into a Client’s account[s]. Clients may withdraw
account assets on notice to AFG, subject to the usual and customary securities settlement procedures. However,
AFG designs its portfolios as long-term investments, and the withdrawal of assets may impair the achievement of a
Client’s investment objectives. AFG may consult with its Clients about the options and ramifications of transferring
securities. However, Clients are advised that when transferred securities are liquidated, they are subject to fees
assessed at the mutual fund level (i.e., contingent deferred sales charge) and/or tax ramifications.
Financial Planning Services
AFG may include financial planning as part of its overall wealth management services or as a separate standalone
engagement. For separate engagements, AFG offers financial planning services on either an hourly basis or a
fixed engagement fee. Hourly engagements are billed at a rate of up to $300 per hour. Fixed engagements are
negotiated based on the expected number of hours to complete the engagement at the Advisor’s hourly rate. Fees
may be negotiable at the sole discretion of the Advisor, depending on the nature and complexity of services to be
provided. An estimate for total hours and/or costs will be provided to the Client prior to engaging in these services.
Retirement Plan Advisory Services
Fees for retirement plan advisory services are charged an annual asset-based fee of up to 1.00%, billed either
monthly or quarterly (the Billing Period), pursuant to the terms of the retirement plan advisory agreement.
Retirement plan advisory fees are based on the market value of assets under management.
B. Fee Billing
Wealth Management Services
Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s]
at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be
deducted from the Client’s account[s] at the beginning of each month. The amount due is calculated by applying
the monthly rate (annual rate divided by 12) to the total assets under management with AFG at the end of the prior
month. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting the deduction of
the wealth management fee. Clients are urged to also review the statement provided by the Custodian, as the
Custodian does not perform a verification of fees. Clients provide written authorization permitting wealth
management fees to be deducted by AFG to be paid directly from their account[s] held by the Custodian as part of
the wealth management agreement and separate account forms provided by the Custodian.
Financial Planning Services
Fees for hourly and fixed fee financial planning engagements may be invoiced up to 50% upon execution of the
financial planning agreement, with the balance due upon completion of the engagement deliverable[s]. Certain
Clients may have their financial planning fees included with their overall investment advisory fees.
Retirement Plan Advisory Services
Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the
Plan, pursuant to the terms of the retirement plan advisory agreement. Fees are calculated either in advance of or
at the end of the Billing Period.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties other than AFG in connection with
investments made on behalf of the Client’s account[s]. The Advisor includes securities transaction costs as part
of its overall wealth management fee through the AFG Wrap Fee Program. Securities transaction fees for Client-
directed trades may be charged back to the Client. Please see Item 4.D. as well as Appendix 1 – Wrap Fee
Program Brochure.
In addition, all fees paid to AFG for investment advisory services are separate and distinct from the expenses
charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described
in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 7
funds, other fund expenses, account administration (e.g., custody, brokerage, and account reporting), and a
possible distribution fee. A Client may be able to invest in these products directly, without the services of AFG,
but would not receive the services provided by AFG, which are designed, among other things, to assist the
Client in determining which products or services are most appropriate for each Client’s financial situation and
objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by
AFG to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional
information.
D. Advance Payment of Fees and Termination
Wealth Management Services
AFG is compensated for its wealth management services in advance of the month in which services are rendered.
Either party may terminate the wealth management agreement, at any time, by providing advance written notice to
the other party. The Client may also terminate the wealth management agreement within five (5) business days of
signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for
bona fide advisory services rendered to the point of termination, and such fees will be due and payable by the
Client. Upon termination, the Advisor will refund any unearned, prepaid fees from the effective date of termination
to the end of the month. The Client’s wealth management agreement with the Advisor is non-transferable without
the Client’s prior consent.
Financial Planning Services
AFG may be partially compensated for its financial planning services in advance of the engagement. Either party
may terminate the financial planning agreement, at any time, by providing advance written notice to the other party.
The Client may also terminate the financial planning agreement within five (5) business days of signing the
Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide
advisory services rendered to the point of termination, and such fees will be due and payable by the Client. Upon
termination, the Client shall be responsible for planning fees based on the hours incurred or, in the event of a fixed
fee, the percentage of the engagement completed. Upon termination, the Advisor will refund any unearned,
prepaid fees. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s
prior consent.
Retirement Plan Advisory Services
AFG may be compensated for its retirement plan advisory services in advance of the Billing Period. Either party
may terminate the retirement plan advisory agreement, at any time, by providing advance written notice to the
other party. The Client may also terminate the retirement plan advisory agreement within five (5) business days of
signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for
bona fide advisory services rendered to the point of termination, and such fees will be due and payable by the
Client. Upon termination, the Advisor will refund any unearned, prepaid fees from the effective date of termination
to the end of the Billing Period. The Client’s retirement plan advisory agreement with the Advisor is non-
transferable without the Client’s prior consent.
E. Compensation for Sales of Securities
AFG does not buy or sell securities and does not receive any compensation for securities transactions in any
Client account other than the investment advisory fees noted above.
Broker-Dealer Affiliations
Advisory Persons of AFG are also Registered Representatives of Purshe Kaplan Sterling Investments, Inc.
(“PKS”), a securities broker-dealer, and a member of the Financial Industry Regulatory Authority (“FINRA”) and the
Securities Investor Protection Corporation (“SIPC”). In one’s separate capacity as a Registered Representative of
PKS, an Advisory Person will implement securities transactions under PKS and not through AFG. In such
instances, an Advisory Person will receive commission-based compensation in connection with the purchase and
sale of securities, including 12b-1 fees for the sale of investment company products. Compensation earned by an
Advisory Person in one’s capacity as a Registered Representative is separate from and in addition to advisory
fees. This practice presents a conflict of interest because Advisory Persons who are Registered Representative
have an incentive to effect securities transactions for the purpose of generating commissions rather than solely
based on Client needs. Clients are not obligated to implement any recommendation provided by the Advisor or
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 8
Advisory Persons. Neither the Advisor nor Advisory Persons will earn ongoing investment advisory fees in
connection with any products or services implemented in the Advisory Person’s separate capacity as a Registered
Representative. Please see Item 10 below.
Insurance Agency Affiliations
Certain Advisory Persons are licensed as independent insurance professionals. As an independent insurance
professional, an Advisory Person may earn commission-based compensation for selling insurance products,
including insurance products offered to Clients. Insurance commissions earned by the Advisory Person are
separate and in addition to investment advisory fees. This practice presents a conflict of interest as an Advisory
Person who is also an insurance professional will have an incentive to recommend insurance products to the
Client for the purpose of generating commissions rather than solely based on the Client’s needs. Clients are
under no obligation, contractual or otherwise, to purchase insurance products through any Advisory Person
affiliated with the Advisor. Please see Item 10 below.
Item 6 – Performance-Based Fees and Side-By-Side Management
AFG does not charge performance-based fees for its investment advisory services. The fees charged by AFG
are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held
by any Client. AFG does not manage any proprietary investment funds or limited partnerships (for example, a
mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to
its Clients.
Item 7 – Types of Clients
AFG offers investment advisory services to individuals, high net worth individuals, families, trusts, estates,
businesses, and retirement plans. The amount of each type of Client is available on the Advisor’s Form ADV
Part 1A. These amounts may change over time and are updated at least annually by the Advisor. AFG generally
does not impose a minimum size for establishing a relationship. However, certain investments and strategies
may require certain minimums for effective implementation.
Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss
A. Methods of Analysis
AFG primarily employs fundamental analysis in developing investment strategies for its Clients. Research and
analysis from AFG are derived from numerous sources, including financial media companies, third-party
research materials, Internet sources, and review of company activities, including annual reports, prospectuses,
press releases, and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria
are generally ratios and trends that may indicate the overall strength and financial viability of the entity being
analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment
with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential
investment, it does not guarantee that the investment will increase in value. Assets meeting the investment
criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The
Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate.
More details on the Advisor’s review process are included below in Item 13 – Review of Accounts.
As noted above, AFG generally employs a long-term investment strategy for its Clients, as consistent with their
financial goals. AFG will typically hold all or a portion of a security for more than a year but may hold for shorter
periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, AFG may also
buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the
fundamentals of the security, sector, or asset class.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 9
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. AFG will assist Clients in determining an appropriate
strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a
Client will meet their investment goals.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that
the investment will increase in value. Assets meeting the investment criteria utilized in these methods of
analysis may lose value and may have negative investment performance. The Advisor monitors these economic
indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s
review process are included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client’s investment goals, financial situation, time horizon,
tolerance for risk, and other factors to develop an appropriate strategy for managing a Client’s account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client’s account[s]. The Advisor shall rely on financial and other information provided by the Client
or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals,
or other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client
accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio
construction process. Following are some of the risks associated with the Advisor’s investment approach:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well
as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the
overall financial markets.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of
the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a
mutual fund is typically set daily therefore, a mutual fund purchased at one point in the day will typically have the
same price as a mutual fund purchased later that same day.
Margin Borrowings
The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if
securities pledged to brokers to secure a Client’s margin accounts decline in value, the Client could be subject
to a “margin call” pursuant to which it must either deposit additional funds with the broker or be the subject of
mandatory liquidation of the pledged securities to compensate for the decline in value.
Bond Risks
Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will
fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the
coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower
rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase
at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default
risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company
defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s
downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its
debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available
market for the bond.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 10
Options Contracts
Investments in options contracts have the risk of losing value in a relatively short period of time. Option
contracts are leveraged instruments that allow the holder of a single contract to control many shares of an
underlying stock. This leverage can compound gains or losses.
Leveraged and Inverse ETFs
Leveraged and Inverse ETFs are not suitable for all investors and should be utilized only by sophisticated
investors who understand leverage risk, consequences of seeking daily leveraged investment results and intend
to actively monitor and manage their investments. Leveraged ETFs are not designed to track the underlying
index over periods longer than one trading day. The use of leverage increases the level of investment risk.
Leverage will magnify gains or losses on those investments. Inverse ETFs lose value when the underlying
investments rise in value. The investments have the risk of not meeting their stated daily investment objectives
over a long-term period.
Cryptocurrency ETF Risks
Cryptocurrency ETFs are investment vehicles designed to provide exposure to the price movements of
cryptocurrencies or cryptocurrency-related assets through exchange-listed securities. Cryptocurrencies and
cryptocurrency-related markets are highly volatile. Prices may fluctuate dramatically over short periods of time
due to factors including, but not limited to, market sentiment, technological developments, macroeconomic events,
regulatory actions, and changes in liquidity. As a result, Cryptocurrency ETFs may experience rapid and
substantial losses. A Cryptocurrency ETF’s performance may differ materially from the crypto market exposure it
seeks to provide due to fees and expenses, portfolio construction and rebalancing, and the use of derivatives,
and during periods of market stress liquidity may decline, bid-ask spreads may widen, shares may trade above or
below the value of underlying holdings, and trading may be halted or limited, which may prevent buying or selling
at desired times or prices.
Past performance is not a guarantee of future returns. Investing in securities and other investments
involves a risk of loss that each Client should understand and be willing to bear. Clients are reminded to
discuss these risks with the Advisor.
Item 9 – Disciplinary Information
There are no legal, regulatory, or disciplinary events involving AFG or its owner. AFG values the trust
Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any
advisor or service provider with whom the Client engages. The backgrounds of the Advisor and its Advisory
Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by
searching with the Advisor’s firm name or CRD# 309943.
Item 10 – Other Financial Industry Activities and Affiliations
Broker-Dealer Affiliation
Advisory Persons are also Registered Representatives of PKS conducting business under the name AFG. In
one’s separate capacity as a Registered Representative, an Advisory Person will receive commissions for the
implementation of recommendations for commissionable transactions. Clients are not obligated to implement
any recommendation provided by an Advisory Person in their separate capacity. Neither AFG nor an Advisory
Person will earn ongoing investment advisory fees in connection with any services implemented in one’s
separate capacity as a Registered Representative. Under supervision by PKS, PKS may have access to certain
confidential information of the Client, including but not limited to financial information, investment objectives,
transactions, and holdings information.
Insurance Agency Affiliations
As noted in Item 5, certain Advisory Persons are licensed insurance professionals. Implementations of
insurance recommendations are separate and apart from one’s role with the Advisor. As an insurance
professional, the Advisory Person will receive customary commissions and other related revenues from the
various insurance companies whose products are sold. Advisory Persons are not required to offer the products
of any particular insurance company. Commissions generated by insurance sales do not offset investment
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 11
advisory fees. This presents a conflict of interest in recommending certain products of the insurance companies.
Clients are under no obligation to implement any recommendations made by the Advisor or Advisory Persons.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading
A. Code of Ethics
AFG has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each
Client. This Code applies to all persons associated with AFG (“Supervised Persons”). The Code was developed
to provide general ethical guidelines and specific instructions regarding AFG’s duties to each Client. AFG and its
Supervised Persons owe a duty of loyalty, fairness, and good faith towards each Client. It is the obligation of
AFG associates to adhere not only to the specific provisions of the Code but also to the general principles that
guide the Code. The Code covers a range of topics that address ethics and conflicts of interest. To request a
copy of the Code, please contact the Advisor at (781) 741-2540.
B. Personal Trading with Material Interest
AFG allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. AFG does not act as principal in any transactions. In addition, the Advisor does
not act as the general partner of a fund or advise an investment company. AFG does not have a material
interest in any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
AFG allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Owning the same securities AFG recommends (purchase or sell) to Clients
presents a conflict of interest that, as fiduciaries, AFG must disclose to Clients and mitigate through policies and
procedures. As noted above, the Advisor has adopted a Code of Ethics, which addresses insider trading
(material non-public information controls) and personal securities reporting procedures. When trading for
personal accounts, employees of AFG have a conflict of interest if trading in the same securities. The fiduciary
duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous
terms than Client trades or by trading based on material non-public information. This risk is mitigated by AFG
requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance
Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the misuse
of material, non-public information.
D. Personal Trading at Same Time as Client
While AFG allows Supervised Persons to purchase or sell the same securities that may be recommended to
and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward.
At no time will any associated person of AFG transact in any security to the detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
AFG does not have discretionary authority to select the broker-dealer/custodian for custody and execution
services. The Client will engage the broker-dealer/custodian (herein the “Custodian”) to safeguard Client assets
and authorize AFG to direct trades to the Custodian as agreed upon in the investment advisory agreement.
Further, AFG does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-
by-trade basis. Where AFG does not exercise discretion over the selection of the Custodian, it may recommend
the Custodian to clients for custody and execution services. Clients are not obligated to use the recommended
Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not
recommended by AFG. However, the Advisor may be limited in the services it can provide if the recommended
Custodian is not engaged. AFG may recommend the Custodian based on criteria such as, but not limited to, the
reasonableness of commissions charged to the Client, services made available to the Client, its reputation,
and/or the location of the Custodian’s offices.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 12
AFG will generally recommend that Clients establish their account[s] at Fidelity Clearing and Custody Solutions
and related divisions and entities of Fidelity Investments, Inc., including National Financial Services, LLC and
Fidelity Brokerage Services, LLC (collectively “Fidelity”), a FINRA-registered broker-dealer and member SIPC.
Fidelity will serve as the Client’s “qualified custodian.” AFG maintains an institutional relationship with Fidelity,
whereby the Advisor receives economic benefits from Fidelity.
AFG has established an institutional relationship with Fidelity to assist the Advisor in managing Client account[s].
Access to the Fidelity platform is provided at no charge to the Advisor. The Fidelity platform includes brokerage,
custody, administrative support, record keeping, technology, and related services designed to support registered
investment advisors like AFG in serving Clients. These services are intended to serve the best interests of the
Advisor’s Clients.
Fidelity may charge brokerage commissions (securities transaction fees) for effecting certain securities
transactions. Fidelity enables the Advisor to obtain certain no-load mutual funds without securities transaction fees
and other no-load funds at nominal transaction charges. Fidelity’s commission rates are generally considered
discounted from customary retail commission rates. However, the commissions and transaction fees charged by
Fidelity may be higher or lower than those charged by other custodians and broker-dealers. Please see Item 14
below for additional information.
Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars – Soft dollars are revenue programs offered by broker-dealers/custodians whereby an
advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for
research and other services. AFG does not participate in soft dollar programs sponsored or offered by
any broker-dealer/custodian. However, the Advisor receives certain economic benefits from the
Custodian. Please see Item 14 below.
2. Brokerage Referrals – AFG does not receive any compensation from any third party in connection with
the recommendation for establishing an account.
3. Directed Brokerage – All Clients are serviced on a “directed brokerage basis,” where AFG will place
trades within the established account[s] at the Custodian designated by the Client. Further, all Client
accounts are traded within their respective account[s]. The Advisor will not engage in any principal
transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with
other Client accounts (i.e., purchase of a security into one Client account from another Client’s
account[s]). AFG will not be obligated to select competitive bids on securities transactions and does not
have an obligation to seek the lowest available transaction costs. These costs are determined by the
Custodian. Clients. Please also see Item 14.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain
the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of
execution, 4) confidentiality and 5) skill required of the Custodian. AFG will execute its transactions through the
Custodian. AFG may aggregate orders in a block trade or trades when securities are purchased or sold through
the Custodian for multiple (discretionary) accounts. If a block trade cannot be executed in full at the same price
or time, the securities actually purchased or sold by the close of each business day must be allocated in a
manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way
that does not consistently advantage or disadvantage particular Client accounts.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons of AFG and
periodically by Brian Kenney, the CCO. Formal reviews are generally conducted at least annually or more
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 13
frequently depending on the needs of the Client. Clients are offered an annual financial plan, subject to the
scope of their agreement with the Advisor.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least
annually. Reviews may be conducted more or less frequently at the Client’s request. Accounts may be reviewed
as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or
large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify AFG if changes occur
in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional
reviews may be triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage
statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to
the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage
statements will include all positions, transactions, and fees relating to the Client’s account[s]. The Advisor may
also provide Clients with periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by AFG
AFG may refer Clients to various third parties to provide certain financial services necessary to meet the goals
of its Clients. Likewise, AFG may receive referrals of new Clients from a third party. However, AFG and certain
Supervised Persons do receive compensation and other economic benefits from PKS as detailed in Item 10
above.
Participation in Institutional Advisor Platform
As noted in Item 12, AFG has established an institutional relationship with Fidelity to assist the Advisor in
managing Client account[s].
As part of the arrangement, Fidelity also makes available to the Advisor, at no additional charge to the Advisor,
certain research and brokerage services, including research services obtained by Fidelity directly from
independent research companies. The Advisor may also receive additional services and support from Fidelity. As
a result of receiving such services for no additional cost, the Advisor may have an incentive to continue to use or
expand the use of Fidelity’s services. The Advisor examined this potential conflict of interest when it chose to enter
into the relationship with Fidelity and has determined that the relationship is in the best interests of the Advisor’s
Clients and satisfies its Client obligations, including its duty to seek best execution. Please see Item 12 above.
The Advisor receives access to software and related support without cost because the Advisor renders investment
management services to Clients that maintain assets at Fidelity. The software and related systems support may
benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times
to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from
a Custodian creates a conflict of interest since these benefits may influence the Advisor’s recommendation of this
Custodian over one that does not furnish similar software, systems support, or services. In addition, Fidelity has
provided the Advisor with financial support in the launch of the Advisor and reimbursements for various third-party
service providers.
B. Client Referrals from Promoters
The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for
Client referrals.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 14
Item 15 – Custody
The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place all
assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and securities
and direct the Advisor to utilize that Custodian for security transactions in the account[s]. The Client should review
statements provided by the Custodian, as the Custodian does not perform this review. For more information about
custodians and brokerage practices, see Item 12 – Brokerage Practices.
If the Client gives the Advisor authority to move money from one account to another account, the Advisor may
have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor
have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s
instructions.
Item 16 – Investment Discretion
AFG generally has discretion over the selection and amount of securities to be bought or sold in Client accounts
without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to
specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by AFG.
Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will
be evidenced by the Client’s execution of an Investment Advisory Agreement containing all applicable limitations to
such authority. All discretionary trades made by AFG will be in accordance with each Client’s investment objectives
and goals
Item 17 – Voting Client Securities
AFG does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from
the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the
sole responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither AFG nor its management has any adverse financial situations that would reasonably impair the ability of
AFG to meet all obligations to its Clients. Neither AFG nor any of its advisory persons have been subject to a
bankruptcy or financial compromise. AFG is not required to deliver a balance sheet along with this Disclosure
Brochure as the Advisor does not collect fees of $1,200 or more for services to be performed six months or
more in advance.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 15
F I D U C I A R Y S E R V I C E S
F I D U C I A R Y S E R V I C E S
AFG Fiduciary Services Limited Partnership
Form ADV Part 2A – Appendix 1
(“Wrap Fee Program Brochure”)
Effective: March 5, 2026
This Form ADV2A – Appendix 1 (“Wrap Fee Program Brochure”) provides information about the qualifications
and business practices for AFG Fiduciary Services Limited Partnership (“AFG” or the “Advisor”) services when
offering services pursuant to a wrap program. This Wrap Fee Program Brochure shall always be accompanied
by the AFG Disclosure Brochure, which provides complete details on the business practices of the Advisor. If
you did not receive the complete AFG Disclosure Brochure or you have any questions about the contents of this
Wrap Fee Program Brochure or the AFG Disclosure Brochure, please contact the Advisor at (781) 741-2540.
AFG is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Wrap Fee Program Brochure has not been approved or verified by the SEC or by any state
securities authority. Registration of an investment advisor does not imply any specific level of skill or training.
This Wrap Fee Program Brochure provides information about AFG to assist you in determining whether to retain
the Advisor.
Additional information about AFG and its advisory persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching for the Advisor’s firm name or CRD# 309943.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 16
Item 2 – Material Changes
Form ADV 2A – Appendix 1 provides information about a variety of topics relating to an Advisor’s business
practices and conflicts of interest. In particular, this Wrap Fee Program Brochure discusses the Wrap Fee
Program offering of the Advisor.
Material Changes
There have been no material changes to this Disclosure Brochure since the last annual amendment filing on
February 13th, 2025.
Future Changes
From time to time, we may amend this Wrap Fee Program Brochure to reflect changes in our business
practices, changes in regulations, and routine annual updates as required by the securities regulators. This
complete Wrap Fee Program Brochure (along with the complete AFG Disclosure Brochure) or a Summary of
Material Changes shall be provided to each Client annually and if a material change occurs in the business
practices of AFG.
At any time, you may view this Wrap Fee Program Brochure and the current Disclosure Brochure online at the
SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching for the Advisor’s
firm name or CRD# 309943. You may also request a copy of this Disclosure Brochure at any time by contacting
the Advisor at (781) 741-2540.
Item 3 – Table of Contents
Form ADV Part 2A – Appendix 1 ............................................................................................................... 16
Item 2 – Material Changes .......................................................................................................................... 17
Item 3 – Table of Contents ......................................................................................................................... 17
Item 4 – Services Fees and Compensation .............................................................................................. 18
Item 5 – Account Requirements and Types of Clients ............................................................................ 19
Item 6 – Portfolio Manager Selection and Evaluation ............................................................................. 19
Item 7 – Client Information Provided to Portfolio Managers .................................................................. 21
Item 8 – Client Contact with Portfolio Managers ..................................................................................... 21
Item 9 – Additional Information ................................................................................................................. 21
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 17
Item 4 – Services Fees and Compensation
A. Services
AFG Fiduciary Services Limited Partnership (“AFG,” or the “Advisor”) provides customized investment advisory
services for its Clients. This Wrap Fee Program Brochure is provided as a supplement to the AFG Disclosure
Brochure (Form ADV 2A). This Wrap Fee Program Brochure is provided along with the complete Disclosure
Brochure to provide full details of the business practices and fees when selecting AFG as your investment
advisor.
As part of the wealth management fees noted in Item 5 of the Disclosure Brochure, AFG includes normal
securities transaction fees, custody fees, commission fees, administrative fees, third party service fees, and
other investment costs (herein “Covered Costs’) as part of the overall investment advisory fee. Securities
regulations often refer to this combined fee structure as a “Wrap Fee Program.” The Advisor’s recommended
Custodian does not charge securities transaction fees for exchange-traded funds (“ETFs”) and equity trades in
Client accounts but typically charges for mutual funds and other types of investments. The Advisor sponsors
AFG Wrap Fee Program.
The primary purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating to the
combination of securities transaction fees into the single “bundled” wealth management fee. This Wrap Fee
Program Brochure references back to the AFG Disclosure Brochure in which this Wrap Fee Program Brochure
serves as an Appendix. Please see Item 4 – Advisory Services of the Disclosure Brochure for details on
AFG’s investment philosophy and related services.
B. Program Costs
Advisory services provided by AFG are offered in a wrap fee structure whereby Covered Costs are included in
the overall wealth management fee paid to AFG. As the level of activity in a Client’s account[s] may vary from
year to year, the annual cost to the Client may be more or less than engaging for advisory services where the
Covered Costs are borne separately by the Client. The cost of the Wrap Fee Program varies depending on
services to be provided to each Client; however, the Client is not charged more if there is higher trading activity
or other Covered Costs. A Wrap Fee structure presents a conflict of interest as the Advisor is incentivized to
limit the number of trades placed in the Client’s account[s] or to utilize securities that do not have transaction
fees. As noted above, the Advisor’s recommended Custodian does not charge securities transaction fees for
ETFs and equity trades in Client accounts but typically charges for mutual funds and other types of investments.
As such, the Advisor is incentivized to utilize ETFs and other equity securities to limit the overall cost to the
Advisor. The Advisor will only place Client assets into a Wrap Fee Program when it is believed to be in the
Client’s best interest. Please see Item 5 – Fees and Compensation of the Disclosure Brochure for
complete details on fees.
C. Fees
Wealth Management Services
Wealth management fees are paid monthly, in advance of each month, pursuant to the terms of the wealth
management agreement. Wealth management fees are based on the market value of assets under management
at the end of the prior month. Wealth management fees range from 0.50% to 1.50% annually based on several
factors, including the scope and complexity of the services to be provided, the level of assets to be managed, and
the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements,
portfolio restrictions, and other complexities may be charged a higher fee.
The wealth management fee in the first month of service is prorated from the inception date of the account[s] to the
end of the first month. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into
consideration the aggregate assets under management with the Advisor. All securities held in accounts managed
by AFG will be independently valued by the Custodian. AFG will conduct periodic reviews of the Custodian’s
valuations.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 18
As noted above, the Wrap Fee Program includes Covered Costs incurred in connection with the discretionary
investment management services provided by AFG as part of its overall wealth management fee.
Clients may incur certain fees or charges imposed by third parties in connection with investments made on behalf
of the Client’s account[s]. Under this Wrap Fee Program, AFG includes securities transaction costs as part of its
overall investment advisory fee.
In addition, all fees paid to AFG for wealth management services or part of the Wrap Fee Program are separate
and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees
and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay
management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage, and
account reporting), and a possible distribution fee. Securities transaction fees for Client-directed trades will be
charged back to the Client. In connection with the discretionary investment management services provided by
AFG, the Client will incur other costs assessed by the Custodian or other third parties other than the Covered
Costs noted above, such as wire transfer fees, fees for trades executed away from the Custodian, and other fees.
The Advisor does not control nor share in these fees. The Client should review both the fees charged by the
fund[s] and the fees charged by AFG to fully understand the total fees to be paid. Please see Item 5.C. – Other
Fees and Expenses in the Disclosure Brochure (included with this Wrap Fee Program
D. Compensation
AFG is the sponsor and portfolio manager of this Wrap Fee Program. AFG receives wealth management fees
paid by Clients for participating in the Wrap Fee Program and pays the Custodian for the costs associated with
the normal trading activity in the Client’s account[s].
Item 5 – Account Requirements and Types of Clients
AFG offers investment advisory services to individuals, high net worth individuals, families, trusts, estates,
businesses, and retirement plans. AFG generally does not impose a minimum account size for establishing a
relationship. Please see Item 7 – Types of Clients in the Disclosure Brochure for additional information.
Item 6 – Portfolio Manager Selection and Evaluation
Portfolio Manager Selection
AFG serves as sponsor and as portfolio manager for the services under this Wrap Fee Program.
Related Persons
AFG personnel serve as portfolio managers for this Wrap Fee Program. AFG does not serve as a portfolio
manager for any third-party Wrap Fee Programs.
Performance-Based Fees
AFG does not charge performance-based fees for its investment advisory services. The fees charged by AFG
are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held
by any Client. AFG does not manage any proprietary investment funds or limited partnerships (for example, a
mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to
its Clients.
Supervised Persons
AFG Advisory Persons serve as portfolio managers for all accounts, including the services described in this
Wrap Fee Program Brochure. Details of the advisory services provided are included in Item 4.A. of the
Disclosure Brochure.
Methods of Analysis
Please see Item 8 of the Disclosure Brochure (included with this Wrap Fee Program Brochure) for details on the
research and analysis methods employed by the Advisor.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 19
Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. AFG will assist Clients in determining an appropriate
strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a
Client will meet their investment goals.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that
the investment will increase in value. Assets meeting the investment criteria utilized in these methods of
analysis may lose value and may have negative investment performance. The Advisor monitors these economic
indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s
review process are included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk, and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on financial and other information provided by the Client
or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals,
or other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client
accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio
construction process. Following are some of the risks associated with the Advisor’s investment approach:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well
as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the
overall financial markets.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of
the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a
mutual fund is typically set daily therefore, a mutual fund purchased at one point in the day will typically have the
same price as a mutual fund purchased later that same day.
Margin Borrowings
The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if
securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject
to a "margin call" pursuant to which it must either deposit additional funds with the broker or be the subject of
mandatory liquidation of the pledged securities to compensate for the decline in value.
Options Contracts
Investments in options contracts have the risk of losing value in a relatively short period of time. Option
contracts are leveraged instruments that allow the holder of a single contract to control many shares of an
underlying stock. This leverage can compound gains or losses.
Leveraged and Inverse ETFs
Leveraged and Inverse ETFs are not suitable for all investors and should be utilized only by sophisticated
investors who understand leverage risk, consequences of seeking daily leveraged investment results and intend
to actively monitor and manage their investments. Leveraged ETFs are not designed to track the underlying
index over periods longer than one trading day. The use of leverage increases the level of investment risk.
Leverage will magnify gains or losses on those investments. Inverse ETFs lose value when the underlying
investments rise in value. The investments have the risk of not meeting their stated daily investment objectives
over a long-term period.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 20
Cryptocurrency ETF Risks
Cryptocurrency ETFs are investment vehicles designed to provide exposure to the price movements of
cryptocurrencies or cryptocurrency-related assets through exchange-listed securities. Cryptocurrencies and
cryptocurrency-related markets are highly volatile. Prices may fluctuate dramatically over short periods of time
due to factors including, but not limited to, market sentiment, technological developments, macroeconomic events,
regulatory actions, and changes in liquidity. As a result, Cryptocurrency ETFs may experience rapid and
substantial losses. A Cryptocurrency ETF’s performance may differ materially from the crypto market exposure it
seeks to provide due to fees and expenses, portfolio construction and rebalancing, and the use of derivatives,
and during periods of market stress liquidity may decline, bid-ask spreads may widen, shares may trade above or
below the value of underlying holdings, and trading may be halted or limited, which may prevent buying or selling
at desired times or prices.
Past performance is not a guarantee of future returns. Investing in securities and other investments
involves a risk of loss that each Client should understand and be willing to bear. Clients are reminded to
discuss these risks with the Advisor.
Proxy Voting
AFG does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from
the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the
sole responsibility for proxy decisions and voting.
Item 7 – Client Information Provided to Portfolio Managers
AFG is the sponsor and sole portfolio manager for the Program. The Advisor does not share Client information
with other portfolio managers because it is the sole portfolio manager for this Wrap Fee Program. Please also
see the AFG Privacy Policy (included after this Wrap Fee Program Brochure).
Item 8 – Client Contact with Portfolio Managers
AFG is a full-service investment management advisory firm. Clients always have direct access to the Portfolio
Managers at AFG.
Item 9 – Additional Information
A. Disciplinary Information and Other Financial Industry Activities and Affiliations
There are no legal, regulatory, or disciplinary events involving AFG or its owner. AFG values the trust
Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any
advisor or service provider with whom the Client engages. The backgrounds of the Advisor and its Advisory
Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by
searching with the Advisor’s firm name or CRD# 309943.
Please see Item 9 of the AFG Disclosure Brochure as well as Item 3 of each Advisory Person’s Brochure
Supplement (included with this Wrap Fee Program Brochure) for additional information on how to research the
background of the Advisor and its Advisory Persons.
Other Financial Activities and Affiliations
Broker-Dealer Affiliation
Advisory Persons are also Registered Representatives of PKS conducting business under the name AFG. In
one’s separate capacity as a Registered Representative, an Advisory Person will receive commissions for the
implementation of recommendations for commissionable transactions. Clients are not obligated to implement
any recommendation provided by an Advisory Person in their separate capacity. Neither AFG nor an Advisory
Person will earn ongoing investment advisory fees in connection with any services implemented in one’s
separate capacity as a Registered Representative. Under supervision by PKS, PKS may have access to certain
confidential information of the Client, including but not limited to financial information, investment objectives,
transactions, and holdings information.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 21
Insurance Agency Affiliations
As noted in Item 5 of the Disclosure Brochure, certain Advisory Persons are licensed insurance professionals.
Implementations of insurance recommendations are separate and apart from one’s role with the Advisor. As an
insurance professional, the Advisory Person will receive customary commissions and other related revenues
from the various insurance companies whose products are sold. Advisory Persons are not required to offer the
products of any particular insurance company. Commissions generated by insurance sales do not offset
investment advisory fees. This presents a conflict of interest in recommending certain products of the insurance
companies. Clients are under no obligation to implement any recommendations made by the Advisor or
Advisory Persons.
B. Code of Ethics, Review of Accounts, Client Referrals, and Financial Information
AFG has implemented a Code of Ethics that defines our fiduciary commitment to each Client. This Code of
Ethics applies to all persons subject to AFG’s compliance program (our “Supervised Persons”). Complete details
on the AFG Code of Ethics can be found under Item 11 – Code of Ethics, Participation in Client Transactions
and Personal Trading in the Disclosure Brochure (included with this Wrap Fee Program Brochure).
Review of Accounts
Investments in Client accounts are monitored on a regular and continuous basis by Advisory Persons of AFG
under the supervision of the Chief Compliance Officer (“CCO”). Details of the review policies and practices are
provided in Item 13 of the Form ADV Part 2A – Disclosure Brochure.
Other Compensation
Participation in Institutional Advisor Platform
AFG will generally recommend that Clients establish their account[s] at Fidelity Clearing and Custody Solutions
and related divisions and entities of Fidelity Investments, Inc., including National Financial Services, LLC and
Fidelity Brokerage Services, LLC (collectively “Fidelity”), a FINRA-registered broker-dealer and member SIPC.
Fidelity will serve as the Client’s “qualified custodian.” AFG maintains an institutional relationship with Fidelity,
whereby the Advisor receives economic benefits from Fidelity.
AFG has established an institutional relationship with Fidelity to assist the Advisor in managing Client account[s].
Access to the Fidelity platform is provided at no charge to the Advisor. The Fidelity platform includes brokerage,
custody, administrative support, record keeping, technology, and related services designed to support registered
investment advisors like AFG in serving Clients. These services are intended to serve the best interests of the
Advisor’s Clients.
As part of the arrangement, Fidelity also makes available to the Advisor, at no additional charge to the Advisor,
certain research and brokerage services, including research services obtained by Fidelity directly from
independent research companies. The Advisor may also receive additional services and support from Fidelity. As
a result of receiving such services for no additional cost, the Advisor may have an incentive to continue to use or
expand the use of Fidelity's services. The Advisor examined this potential conflict of interest when it chose to enter
into the relationship with Fidelity and has determined that the relationship is in the best interests of the Advisor’s
Clients and satisfies its Client obligations, including its duty to seek best execution. Please see Item 12 above.
The Advisor receives access to software and related support without cost because the Advisor renders
investment management services to Clients that maintain assets at Fidelity. The software and related systems
support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor
endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt
of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the
Advisor's recommendation of this Custodian over one that does not furnish similar software, systems support, or
services. In addition, Fidelity has provided the Advisor with financial support in the launch of the Advisor and
reimbursements for various third-party service providers.
Client Referrals from Promoters
The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for
Client referrals.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 22
Financial Information
Neither AFG nor its management has any adverse financial situations that would reasonably impair the ability of
AFG to meet all obligations to its Clients. Neither AFG nor any of its advisory persons have been subject to a
bankruptcy or financial compromise. AFG is not required to deliver a balance sheet along with this Disclosure
Brochure as the Advisor does not collect fees of $1,200 or more for services to be performed six months or
more in advance.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 23
F I D U C I A R Y S E R V I C E S
F I D U C I A R Y S E R V I C E S
Form ADV Part 2B – Brochure Supplement
for
Brian M. Kenney
Principal and Chief Compliance Officer
Effective: March 5, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Brian M. Kenney (CRD# 1694580) in addition to the information contained in the AFG Fiduciary Services
Limited Partnership (“AFG” or the “Advisor,” CRD# 309943) Disclosure Brochure. If you have not received a
copy of the Disclosure Brochure or if you have any questions about the contents of the AFG Disclosure
Brochure or this Brochure Supplement, please contact the Advisor at (781) 741-2540.
Additional information about Mr. Kenney is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or individual CRD# 1694580.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 24
Item 2 – Educational Background and Business Experience
Brian M. Kenney, born in 1964, is dedicated to advising Clients of AFG as its Principal and Chief Compliance
Officer. Mr. Kenney earned a Bachelor of Arts degree in Economics from the University of Connecticut in 1986.
Additional information regarding Mr. Kenney’s employment history is included below.
Employment History:
12/2020 to Present
12/2020 to Present
10/2015 to 12/2020
07/2009 to 10/2015
Principal, AFG Fiduciary Services Limited Partnership
Registered Representative, Purshe Kaplan Sterling Investments, Inc.
Financial Advisor, Wells Fargo Advisors Financial Network, LLC
Financial Advisor, Raymond James Financial Services Advisors, Inc., and
Raymond James Financial Services, Inc.
Item 3 – Disciplinary Information
There are no legal, civil, or disciplinary events to disclose regarding Mr. Kenney. Mr. Kenney has never
been involved in any regulatory, civil, or criminal action. There have been no client complaints, lawsuits,
arbitration claims, or administrative proceedings against Mr. Kenney.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have
been found liable in a legal, regulatory, civil, or arbitration matter that alleges violation of securities and other
statutes; fraud; false statements or omissions; theft, embezzlement, or wrongful taking of property; bribery,
forgery, counterfeiting, or extortion; and/or dishonest, unfair, or unethical practices. As previously noted, there
are no legal, civil, or disciplinary events to disclose regarding Mr. Kenney.
However, the Advisor encourages you to independently view the background of Mr. Kenney on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or individual
CRD# 1694580.
Item 4 – Other Business Activities
Broker-Dealer Affiliation
Mr. Kenney is also a Registered Representative of Purshe Kaplan Sterling Investments, Inc. (“PKS”). PKS is a
registered broker-dealer (CRD# 35747), member FINRA, SIPC. In Mr. Kenney’s separate capacity as a
Registered Representative, Mr. Kenney will receive commissions for the implementation of recommendations
for commissionable transactions. Clients are not obligated to implement any recommendation provided by Mr.
Kenney. Neither the Advisor nor Mr. Kenney will earn ongoing investment advisory fees in connection with any
products or services implemented in Mr. Kenney’s separate capacity as a Registered Representative. Mr.
Kenney spends less than 10% of his time per month in his role as a Registered Representative of PKS.
Insurance Agency Affiliations
Mr. Kenney is also a licensed insurance professional. Implementations of insurance recommendations are
separate and apart from Mr. Kenney’s role with AFG. As an insurance professional, Mr. Kenney will receive
customary commissions and other related revenues from the various insurance companies whose products are
sold. Mr. Kenney is not required to offer the products of any particular insurance company. Commissions
generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in
recommending certain products of the insurance companies. Clients are under no obligation to implement any
recommendations made by Mr. Kenney or the Advisor. Mr. Kenney spends less than 10% of his time per month
in this capacity.
Item 5 – Additional Compensation
Mr. Kenney has additional business activities where compensation is received that are detailed in Item 4 above.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 25
Item 6 – Supervision
Mr. Kenney serves as the Principal and Chief Compliance Officer of AFG. Mr. Kenney can be reached at (781)
741-2540.
AFG has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person
in meeting their fiduciary obligations to Clients of AFG. Further, AFG is subject to regulatory oversight by various
agencies. These agencies require registration by AFG and its Supervised Persons. As a registered entity, AFG
is subject to examinations by regulators, which may be announced or unannounced. AFG is required to
periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 26
F I D U C I A R Y S E R V I C E S
F I D U C I A R Y S E R V I C E S
Form ADV Part 2B – Brochure Supplement
for
Joseph W. McCarthy, CFP®
Financial Advisor
Effective: March 5, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Joseph W. McCarthy, CFP® (CRD# 1017415) in addition to the information contained in the AFG Fiduciary
Services Limited Partnership (“AFG” or the “Advisor,” CRD# 309943) Disclosure Brochure. If you have not
received a copy of the Disclosure Brochure or if you have any questions about the contents of the AFG
Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (781) 741-2540.
Additional information about Mr. McCarthy is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with his full name or individual CRD# 1017415.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 27
Item 2 – Educational Background and Business Experience
Joseph W. McCarthy, CFP®, born in 1958, is dedicated to advising Clients of AFG as a Financial Advisor. Mr.
McCarthy earned a Bachelor of Arts from Stonehill College in 1981. Additional information regarding Mr.
McCarthy’s employment history is included below.
Employment History:
12/2020 to Present
12/2020 to Present
10/2015 to 12/2020
10/2010 to 10/2015
Financial Advisor, AFG Fiduciary Services Limited Partnership
Registered Representative, Purshe Kaplan Sterling Investments, Inc.
Financial Advisor, Wells Fargo Advisors Financial Network, LLC
Financial Advisor, Raymond James Financial Services Advisors, Inc., and
Raymond James Financial Services, Inc
CERTIFIED FINANCIAL PLANNER® Professional
I am certified for financial planning services in the United States by Certified Financial Planner Board of
Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER®
Professional or a CFP® Professional, and I may use these and the other certification marks (the “CFP Board
Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning, Inc. has
licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state law or
regulation requires financial planners to hold the CFP® certification. You may find more information about the
CFP® certification at www.cfp.net.
CFP® Professionals have met CFP Board’s high standards for education, examination, experience, and ethics.
To become a CFP® Professional, an individual must fulfill the following requirements:
● Education – Earn a bachelor’s degree or higher from an accredited college or university and complete
CFP Board-approved coursework at a college or university through a CFP Board Registered Program.
The coursework covers the financial planning subject areas CFP Board has determined are necessary
for the competent and professional delivery of financial planning services, as well as a comprehensive
financial plan development capstone course. A candidate may satisfy some of the coursework
requirement through other qualifying credentials. CFP Board implemented the bachelor’s degree or
higher requirement in 2007 and the financial planning development capstone course requirement in
March 2012. Therefore, a CFP® Professional who first became certified before those dates may not
have earned a bachelor’s or higher degree or completed a financial planning development capstone
course.
● Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed
to assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in
the context of real-life financial planning situations.
● Experience – Complete 6,000 hours of Professional experience related to the personal financial
planning process, or 4,000 hours of apprenticeship experience that meets additional requirements.
● Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP®
Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and
Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for
CFP® Professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements to
remain certified and maintain the right to continue to use the CFP Board.
Certification Marks:
● Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to
CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 28
Client, at all times when providing financial advice and financial planning. CFP Board may sanction a
CFP® Professional who does not abide by this commitment, but CFP Board does not guarantee a CFP®
Professional’s service. A Client who seeks a similar commitment should obtain a written engagement
that includes a fiduciary obligation to the Client.
● Continuing Education – Complete 30 hours of continuing education every two years to maintain
competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with
developments in financial planning. Two of the hours must address the Code and Standards.
Item 3 – Disciplinary Information
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have
been found liable in a legal, regulatory, civil, or arbitration matter that alleges violation of securities and other
statutes; fraud; false statements or omissions; theft, embezzlement, or wrongful taking of property; bribery,
forgery, counterfeiting, or extortion; and/or dishonest, unfair, or unethical practices. There are no legal, civil, or
disciplinary events requiring disclosure regarding Mr. McCarthy.
However, the Advisor encourages you to independently view the background of Mr. McCarthy on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or individual
CRD# 1017415.
Item 4 – Other Business Activities
Broker-Dealer Affiliation
Mr. McCarthy is also a Registered Representative of Purshe Kaplan Sterling Investments, Inc. (“PKS”). PKS is a
registered broker-dealer (CRD# 35747), member FINRA, SIPC. In Mr. McCarthy’s separate capacity as a
Registered Representative, Mr. McCarthy will receive commissions for the implementation of recommendations
for commissionable transactions. Clients are not obligated to implement any recommendation provided by Mr.
McCarthy. Neither the Advisor nor Mr. McCarthy will earn ongoing investment advisory fees in connection with
any products or services implemented in Mr. McCarthy’s separate capacity as a Registered Representative. Mr.
McCarthy spends approximately 10% of his time per month in his role as a Registered Representative of PKS.
Insurance Agency Affiliations
Mr. McCarthy is also a licensed insurance professional. Implementations of insurance recommendations are
separate and apart from Mr. McCarthy’s role with AFG. As an insurance professional, Mr. McCarthy will receive
customary commissions and other related revenues from the various insurance companies whose products are
sold. Mr. McCarthy is not required to offer the products of any particular insurance company. Commissions
generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in
recommending certain products of the insurance companies. Clients are under no obligation to implement any
recommendations made by Mr. McCarthy or the Advisor. Mr. McCarthy spends approximately 10% of his time
per month in this capacity.
Item 5 – Additional Compensation
Mr. McCarthy has additional business activities where compensation is received that are detailed in Item 4
above.
Item 6 – Supervision
Mr. McCarthy serves as a Financial Advisor of AFG and is supervised by Brian Kenney, the Chief Compliance
Officer. Mr. Kenney can be reached at (781) 741-2540.
AFG has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person
in meeting their fiduciary obligations to Clients of AFG. Further, AFG is subject to regulatory oversight by various
agencies. These agencies require registration by AFG and its Supervised Persons. As a registered entity, AFG
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 29
is subject to examinations by regulators, which may be announced or unannounced. AFG is required to
periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 30
F I D U C I A R Y S E R V I C E S
F I D U C I A R Y S E R V I C E S
Form ADV Part 2B – Brochure Supplement
for
Susan A. Skahan
Registered Operations Manager
Effective: March 5, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Susan A. Skahan (CRD# 2388770) in addition to the information contained in the AFG Fiduciary Services
Limited Partnership (“AFG” or the “Advisor,” CRD# 309943) Disclosure Brochure. If you have not received a
copy of the Disclosure Brochure or if you have any questions about the contents of the AFG Disclosure
Brochure or this Brochure Supplement, please contact the Advisor at (781) 741-2540.
Additional information about Ms. Skahan is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with her full name or individual CRD# 2388770.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 31
Item 2 – Educational Background and Business Experience
Susan A. Skahan, born in 1969, is dedicated to advising Clients of AFG as a Registered Operations Manager.
Ms. Skahan earned a Bachelor’s degree from the University of Massachusetts in 1991. Additional information
regarding Ms. Skahan’s employment history is included below.
Employment History:
Registered Operations Manager, AFG Fiduciary Services Limited Partnership
Registered Sales Assistant, Purshe Kaplan Sterling Investments, Inc.
Registered Representative, Wells Fargo Advisors Financial Network, LLC
Registered Sales Assistant, Raymomnd James Financial Services, Inc.
12/2020 to Present
12/2020 to Present
10/2015 to 12/2020
01/2009 to 10/2015
Item 3 – Disciplinary Information
There are no legal, civil, or disciplinary events to disclose regarding Ms. Skahan. Ms. Skahan has never
been involved in any regulatory, civil, or criminal action. There have been no client complaints, lawsuits,
arbitration claims, or administrative proceedings against Ms. Skahan.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have
been found liable in a legal, regulatory, civil, or arbitration matter that alleges violation of securities and other
statutes; fraud; false statements or omissions; theft, embezzlement, or wrongful taking of property; bribery,
forgery, counterfeiting, or extortion; and/or dishonest, unfair, or unethical practices. As previously noted, there
are no legal, civil, or disciplinary events to disclose regarding Ms. Skahan.
However, the Advisor encourages you to independently view the background of Ms. Skahan on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or individual
CRD# 2388770.
Item 4 – Other Business Activities
Broker-Dealer Affiliation
Ms. Skahan is also a Registered Sales Assistant (Registered Representative) of Purshe Kaplan Sterling
Investments, Inc. (“PKS”). PKS is a registered broker-dealer (CRD# 35747), member FINRA, SIPC. Ms. Skahan
spends approximately 10% of her time per month in her role as a Registered Sales Assistant for PKS business.
Item 5 – Additional Compensation
Ms. Skahan has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Ms. Skahan serves as a Registered Operations Manager of AFG and is supervised by Brian Kenney, the Chief
Compliance Officer. Mr. Kenney can be reached at (781) 741-2540.
AFG has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person
in meeting their fiduciary obligations to Clients of AFG. Further, AFG is subject to regulatory oversight by various
agencies. These agencies require registration by AFG and its Supervised Persons. As a registered entity, AFG
is subject to examinations by regulators, which may be announced or unannounced. AFG is required to
periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 32
Privacy Policy
Effective Date: March 5, 2026
Our Commitment to You
AFG Fiduciary Services Limited Partnership (“AFG” or the “Advisor”) is committed to safeguarding the use of
personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment
Advisor, as described here in our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your
private information, and we do everything that we can to maintain that trust. AFG (also referred to as "we," "our,"
and "us”) protects the security and confidentiality of the personal information we have and implements controls
to ensure that such information is used for proper business purposes in connection with the management or
servicing of our relationship with you.
AFG does not sell your non-public personal information to anyone. Nor do we provide such information to others
except for discrete and reasonable business purposes in connection with the servicing and management of our
relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set
forth in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of
servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs
to disclose how we collect, share, and protect your personal information.
What information do we collect from you?
Social security or taxpayer identification number Assets and liabilities
Name, address, and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage, and advisory agreements
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment questionnaires and suitability
documents
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use, we maintain physical, procedural,
and electronic security measures. These include such safeguards as secure passwords, encrypted file storage,
and a secure office environment. Our technology vendors provide security and access control over personal
information and have policies over the transmission of data. Our associates are trained on their responsibilities
to protect Clients’ personal information.
We require third parties that assist in providing our services to you to protect the personal information they
receive from us.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
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How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list
some reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you limit?
Yes
No
No
Not Shared
Yes
Yes
No
Not Shared
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties (such as administrators, broker-dealers, custodians, regulators,
credit agencies, other financial institutions) as necessary for us to provide
agreed upon services to you, consistent with applicable law, including but
not limited to: processing transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
AFG shares Client information with Purshe Kaplan Sterling Investments,
Inc. (“PKS”) due to the oversight PKS has over certain supervised
persons of the Advisor. You may also contact us at any time for a copy of
the PKS Privacy Policy.
Marketing Purposes
AFG does not disclose and does not intend to disclose personal
information with non-affiliated third parties to offer you services. Certain
laws may give us the right to share your personal information with
financial institutions where you are a customer and where AFG or the
Client has a formal agreement with the financial institution. We will only
share information for purposes of servicing your accounts, not for
marketing purposes.
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
Information About Former Clients
AFG does not disclose and does not intend to disclose non-public
personal information to non-affiliated third parties with respect to persons
who are no longer our Clients.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter
the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public
personal information other than as described in this notice unless we first notify you and provide you with an
opportunity to prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by
contacting us at (781) 741-2540.
AFG Fiduciary Services Limited Partnership
Primary Office: 2 Essington Drive, Hingham, MA 02043
Phone: (781) 741-2540 | Fax: (781) 741-2541
www.afgfiduciary.com
Page 34