Beacon Financial Advisors Ltd.

Firm Brochure (Part 2A of Form ADV) BEACON FINANCIAL ADVISORS, LTD. ("BEACON") 1800 ST. JAMES PLACE, SUITE 101 HOUSTON, TEXAS 77056 PHONE 713.622.9981 FAX 713.622.5814 Website: www.bfaltd.com This brochure provides information about the qualifications and business practices of BEACON. If you have any questions about the contents of this brochure or would like to request a copy free of charge, please contact Joshua J. Hebert at 713.622.9981 or josh@bfaltd.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about BEACON is available on the SEC’s website at http://www.adviserinfo.sec.gov. Beacon’s CRD # is 106164. BEACON is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. June 9, 2026 Beacon Financial Advisors, Ltd.  Item 2 - Material Changes Annual Update The Material Changes section of this brochure will be updated annually when material changes occur since the previous release of the Firm Brochure. Material Changes since the Last Update Since our Annual Updating Amendment dated March 24, 2025, we have material changes to report: • Revisions were made across various sections of our Firm Brochure to enhance clarity, completeness, and consistency with the instructions to Form ADV Part 2. The revisions were made to ensure that disclosures are presented in a manner that is more closely aligned with regulatory expectations and to improve the readability and transparency of the information provided to clients and prospective clients. These changes include refinements to the organization, formatting, and description of certain advisory services, fees, conflicts of interest, and related disclosures. These revisions are primarily clarifying in nature and do not reflect any material changes to our advisory services, fee structure, or business practices, except as otherwise specifically noted in our Firm Brochure. We encourage clients to review our Firm Brochure in its entirety and contact us with any questions regarding the updates. i Beacon Financial Advisors, Ltd.  Item 3 - Table of Contents Item 2 - Material Changes .............................................................................................. i Annual Update ............................................................................................................ i Material Changes since the Last Update .................................................................... i Item 4 - Advisory Business .......................................................................................... 1 Firm Description ......................................................................................................... 1 Types of Advisory Services ........................................................................................ 1 Investment Management Agreement ......................................................................... 2 Tailored Relationships ............................................................................................... 3 Wrap Fee Programs ................................................................................................... 3 Types of Investments ................................................................................................. 3 Item 5 - Fees and Compensation ................................................................................. 4 Description ................................................................................................................. 4 Fee Billing .................................................................................................................. 4 Other Fees ................................................................................................................. 5 Expense Ratios .......................................................................................................... 5 Item 6 - Performance-Based Fees and Side-By-Side Management ........................... 5 Why we do not use Performance-Based Fees ........................................................... 5 Item 7 - Types of Clients ............................................................................................... 6 Description ................................................................................................................. 6 Account Minimums ..................................................................................................... 6 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ................... 7 Methods of Analysis ................................................................................................... 7 Investment Strategies ................................................................................................ 7 Risk of Loss ............................................................................................................... 8 Item 9 - Disciplinary Information .................................................................................. 9 Legal and Disciplinary ................................................................................................ 9 Item 10 - Other Financial Industry Activities and Affiliations .................................... 9 Financial Industry Activities ........................................................................................ 9 Affiliations .................................................................................................................. 9 TOC 1 Beacon Financial Advisors, Ltd.  Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................................................................................................... 10 Code of Ethics.......................................................................................................... 10 Participation or Interest in Client Transactions ......................................................... 10 Personal Trading...................................................................................................... 11 Item 12 - Brokerage Practices .................................................................................... 11 Selecting Brokerage Firms ....................................................................................... 11 Best Execution ......................................................................................................... 14 Soft Dollars .............................................................................................................. 14 Order Aggregation ................................................................................................... 14 Item 13 - Review of Accounts ..................................................................................... 15 Periodic Reviews ..................................................................................................... 15 Review Triggers ....................................................................................................... 15 Regular Reports ....................................................................................................... 15 Item 14 - Client Referrals and Other Compensation ................................................. 15 Incoming Referrals ................................................................................................... 15 Referrals Out ........................................................................................................... 15 Other Compensation ................................................................................................ 16 Item 15 - Custody ........................................................................................................ 16 Account Statements ................................................................................................. 16 Performance Reports ............................................................................................... 16 Net Worth Statements .............................................................................................. 17 Item 16 - Investment Discretion ................................................................................. 17 Discretionary Authority for Trading ........................................................................... 17 Limited Power of Attorney ........................................................................................ 17 Item 17 - Voting Client Securities............................................................................... 18 Proxy Votes ............................................................................................................. 18 Item 18 - Financial Information .................................................................................. 18 Financial Condition .................................................................................................. 18 TOC 2 Beacon Financial Advisors, Ltd.  Item 4 - Advisory Business Firm Description Beacon Financial Advisors, Ltd., (“BEACON”) is a registered investment adviser primarily based in Houston, Texas. We are organized as a Limited Liability Company (“LLC”) under the laws of the State of Texas. BEACON was founded in 1993. Our founding member had over forty (40) years’ experience in financial services, succeeded by our current principal member with over twenty (20) years’ experience. Presently Joshua J. Hebert is a 100% member. The following paragraphs describe our advisory services and fees. As used in this brochure, the words "we," "our," and "us" refer to Beacon Financial Advisors, Ltd. The words "you," "your," and "client" refer to you as either a client or prospective client of our firm. Types of Advisory Services BEACON provides two advisory services as described below. Our services are generally provided to individuals and families, and their related pension and profit-sharing plans, 401k plans, trusts, charitable entities, and estates. • identification of your risk profile, and Investment Management - determination of your investment OBJECTIVES and CONSTRAINTS, the implementation and management of an investment plan we jointly agree is appropriate for you. • Financial Planning - identification of your financial assets and liabilities, cash flow management, tax planning, insurance review, education funding, retirement planning, and estate planning. An important consideration for you is BEACON provides investment management services for all our clients. We provide financial planning services solely as part of, and in connection with, our investment advisory services upon engagement. We do not offer stand‑alone financial planning services independent of investment management. Participation in our advisory services requires that the client signs an agreement prior to our firm conducting services. - 1 - Beacon Financial Advisors, Ltd.  Investment Management Agreement As noted above in Types of Advisory Services you choose to have BEACON manage your assets. Realistic and measurable goals (OBJECTIVES and CONSTRAINTS) are recorded in your investment policy statement. As goals and objectives change over time, recommendations are made and implemented on an ongoing basis. The scope of work and fee for an Investment Management Agreement is provided to you in writing prior to the start of the engagement. Our Investment Management Agreement includes: BEACON'S Services • Develop, with you, a written Investment Policy Statement which specifies your investment OBJECTIVES and CONSTRAINTS. • Prepare an Investment Recommendation Matrix which identifies how your portfolio should be allocated by asset class, and also lists the individual investments deemed to be suitable for your portfolio. The asset allocation target may be periodically changed or your portfolio re-balanced due to changes in your circumstances or market conditions. Implement the agreed-upon Investment Recommendation Matrix. • • Monitor the portfolio to assure current asset allocation is in line with target asset allocation and make re-balancing changes as needed. Also, review the individual investments and report to you with Investment MEMOs, ADVISORYs, and ALERTs as necessary, and during client meetings. • Measure and Report investment results to you via your online, secure Client Portal and Document Vault. Additionally, on a monthly basis you will receive statements directly from the brokerage firm (e.g., Schwab Advisor Services) as well as confirmations of any transactions in each portfolio sub-account. BEACON will also receive this information from the broker. You can elect to receive either postal or email statements for the brokerage statements. • You are always urged to compare the custodians (Schwab Advisor Services et al) account statements with your Client Portal. Your Responsibility • Participate in meetings with BEACON as scheduled for review. • Notify BEACON of significant cash flows (deposits and withdrawals) affecting your portfolio sub-accounts if not previously part of your Investment Policy Statement. • Update BEACON of any material changes in your financial circumstances that may alter your Investment Policy Statement. • Permit BEACON to execute agreed-upon trades in your portfolio sub- accounts with your written authorization to the broker or asset custodian. Your authorization will be evidenced by a limited power of attorney in favor of BEACON and will follow those terms and conditions. - 2 - Beacon Financial Advisors, Ltd.  • Acknowledge that investment results are not guaranteed by BEACON. As noted above, we provide financial planning services solely as part of, and in connection with, our investment advisory services upon engagement. A financial plan is designed to help you with all aspects of financial planning coupled with ongoing investment management. Our Financial Planning Agreement considers two phases: • Compilation and Data Confirmation - the initial phase of collecting your financial information, compiling your present financial situation, and confirming accuracy and completeness with you, etc. • Ongoing Plan Implementation - this second (and ongoing) phase takes the form of client meetings to review our recommendations and those of your other advisors (as applicable). BEACON prepares a Meeting Itinerary prior to the meetings, and afterwards we prepare a meeting follow-up memo detailing the major points and action items. The Meeting Itinerary and meeting follow-up memo may include, but is not limited to: a net worth statement; a cash flow statement; a review of investment accounts, including reviewing asset allocation and providing rebalancing recommendations; strategic income tax planning; a review of retirement accounts and plans including recommendations; a review of insurance policies and recommendations for changes, if necessary; one or more retirement scenarios; estate planning review and recommendations; and education planning with funding recommendations. Tailored Relationships Your unique goals and objectives are documented in our client relationship management and portfolio management systems. In developing your investment policy, you may impose constraints (restrictions) on investing in certain broad asset classes. We call these client mandates. Wrap Fee Programs We do not participate in any wrap fee program. Types of Investments Another important consideration for you is BEACON'S investment research and advice primarily covers regulated investment companies, commonly known as mutual funds. Guidance may be offered on a broad range of investments aligned with your stated financial goals and objectives. We discuss this more fully later in the Investment Strategies sub-section of Methods of Analysis, Investment Strategies and Risk of Loss. - 3 - Beacon Financial Advisors, Ltd.  Regulatory Assets Under Management As of 12/31/2025, BEACON had approximately $296,912,883 in assets under management. Approximately $292,635,158 is managed on a discretionary basis, and $4,277,725 is handled on a non-discretionary basis. Discretion means you have given us the authority to place buy and sell orders in your accounts, and non-discretion means. We can only place buy and sell orders in your accounts each time per your approval. BEACON segregates and includes both types in our portfolio performance reporting to you. Item 5 - Fees and Compensation Description BEACON bases its investment management fees on a percentage of assets under management, an approach that is widely used in the industry. The annual Investment Management Agreement fee is based on a percentage of the investable assets according to the following sliding-scale (tiered) schedule: Discretionary (managed) accounts: • 1.00%_ on the first $1,000,000; • 0.75%_ on the next $1,000,000 (from $1,000,001 to $2,000,000); and • 0.50%_ on the assets above $2,000,000. Non-Discretionary (client directed) accounts*: from tax-lot accounting, income • 0.35%_ on $all; (*if you want an institutional account with BEACON to benefit tax reporting, and performance measurement reporting; often a non-discretionary account is used when you have given us a client-mandate to hold specified prior position(s) for personal, investment, tax, other reasons). The minimum annual fee for investment management is $5,000 and is negotiable. BEACON, in its sole discretion, may waive its minimum fee and/or charge a lesser investment management fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with clients, etc.). This is depicted on your quarterly Fee- For-Service Schedule as a professional courtesy discount. Fee Billing Investment management fees are billed quarterly, in advance, meaning that we invoice you before the three-month billing period has begun. Payment in full is expected upon invoice presentation. Your fees may be deducted (debited) from your designated client brokerage account to facilitate billing (see later section on Custody). - 4 - Beacon Financial Advisors, Ltd.  You must consent in advance to direct debiting of your brokerage account. This is always done per a limited power of attorney form you sign with the custodian of your account(s). You select the account debit approach or opt to be billed directly. Other Fees Custodians and brokers may charge transaction fees on purchases or sales of certain no-load mutual funds. These fees are in addition to the advisory fee and are paid directly by the client. The amount and frequency of such charges will vary depending on the custodian, the specific investment, and account activity. Clients should consider the impact of these transaction costs on their overall investment returns. For additional information, please see Brokerage Practices. Expense Ratios Mutual funds generally charge a management fee for their services as investment managers. The management fee is the largest part of what is called an expense ratio. For example, an expense ratio of 0.54 means that the mutual fund company charges 0.54% for all their services. The mutual fund expense ratio is in addition to the fees you pay BEACON. Performance figures quoted by mutual fund companies in various publications are after their expense ratio has been deducted. Termination of Agreement Either party may terminate the Agreement at any time upon written notification by the other at the address of record of Beacon or you. If you cancel the Agreement within five (5) business days of acceptance, you will receive a full refund of any fees paid. Thereafter, refunds will be pro-rated based on the date written notice of termination is received. Item 6 - Performance-Based Fees and Side-By-Side Management Why we do not use Performance-Based Fees Our fees are not based on a share of the capital gains or capital appreciation of your managed securities nor do we participate in side-by-side management. BEACON does not use a performance-based fee structure because of the potential conflict of interest and the high cost to you. Our general observation about Performance-based compensation is: • Performance-based compensation may create an incentive for the adviser to recommend an investment that may carry a higher degree of risk to the client, and often include investments that are highly illiquid like private placement equities, etc., or are unusually complex. - 5 - Beacon Financial Advisors, Ltd.  • Performance-based fees are commonly quite high. For example, in the hedge-fund industry performance-based fees typically range from 1% to 2% of the assets managed, plus 20% to 25% of the gains/appreciation (not of the losses). • Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. Our fees are described in the Fees and Compensation section above. Item 7 - Types of Clients Description BEACON primarily provides our services to individuals and families, and their related pension and profit-sharing plans, 401k plans, trusts, charitable entities, and estates. These individuals and families include professionals like attorneys and physicians, as well as corporate employees. Many of our clients are retired from the workplace. Our client engagements vary in scope and length of service. The scope of service is primarily dependent on your complexity and needs. Regarding length of service, our goal is an evergreen working relationship with you. We have provided continuous service to many clients for ten, twenty, and thirty years or more. Account Minimums BEACON’s minimum annual fee for investment management is $5,000. Using our fee schedule this translates to a starting account size of $500,000 or more. BEACON, in its sole discretion, may waive its minimum fee and/or charge a lesser investment management fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with clients, etc.). This is depicted on your annual Fee-For- Service Schedule as a professional courtesy discount. While every client engagement is unique, clients' engaging BEACON for both investment management plus financial planning services typically have investable assets of $1,000,000 or more, and clients' engaging BEACON for only investment management typically have $500,000 or more. - 6 - Beacon Financial Advisors, Ltd.  Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods generally may include charting, fundamental analysis, technical analysis, and cyclical analysis. We primarily use mutual fund partners that apply fundamental analysis for the holdings in your account/portfolio. Fundamental Analysis involves evaluating individual companies and their industries by reviewing financial statements, product lines, management expertise, and overall market outlook. The goal is to determine a company’s intrinsic value and compare it to its current market price. Risk: The accuracy of fundamental analysis depends on the reliability of the information used. Misinterpretation or incorrect data can lead to flawed valuations. Additionally, if market prices adjust quickly to new information, fundamental analysis may not yield favorable investment outcomes. The main source of information we use to select our mutual fund partners is conducting meetings either face-to-face, online, or by phone. We review research papers they present as foundational principals on their methods, as well as their proxy materials and shareholder letters. As supporting materials, we also use purchased and/or publicly available research resources. Investment Strategies No investment strategy can assure a profit or protect against loss, and no strategy is successful in all market environments. Periods of underperformance relative to relevant benchmarks or other investment strategies may occur. We rely on strategic asset allocation combined with limited tactical adjustments. Strategic asset allocation is a long-term investment strategy in which targeted allocations are set across asset classes based on factors like risk tolerance and financial goals. Strategic asset allocation reflects our long-term views regarding appropriate exposure to various asset classes; however, asset allocation decisions are subject to market risk and may not produce the intended results if capital markets perform differently than anticipated. Tactical allocation is the process of taking an active stance on the strategic asset allocation itself and adjusting long-term target weights for a short period to capitalize on the market or economic opportunities. Tactical allocations are based on our assessment of economic conditions and capital market factors and involve the risk that our judgments regarding market trends or conditions may be incorrect or may change over time. We primarily implement our strategies using mutual funds managed by third-party investment managers, most often active managers. Active management involves the risk that the investment manager’s research, analysis, and security selection decisions may - 7 - Beacon Financial Advisors, Ltd.  not perform as expected and may underperform relevant market indexes or other investment strategies, either over short or extended periods. Our investment approach emphasizes long-term investing with ongoing monitoring and periodic rebalancing. Portfolio rebalancing is intended to maintain target asset allocations and manage risk; however, rebalancing may result in transaction costs and, in taxable accounts, may generate taxable gains. Rebalancing and monitoring should not be interpreted as market timing or as an assurance that losses can be avoided. The use of international and emerging market investments involves additional risks, including differences in accounting standards, political and economic instability, foreign regulatory environments, currency exchange rate fluctuations, and reduced liquidity. Investments in emerging markets may involve heightened risks relative to investments in more developed markets. Investments in real estate-related securities (such as REITs) and commodity-linked assets may be more volatile than traditional equity and fixed income investments and may be subject to risks such as changes in interest rates, property values, commodity supply and demand, inflation expectations, and regulatory or tax considerations. Cash equivalents and fixed income investments are subject to interest rate risk, credit risk, and inflation risk, and may lose value in rising interest rate environments or fail to keep pace with inflation over time. Risk of Loss All investment types or approaches or strategies have different risks that challenge investors. Investors contend with the following major investment risks depending on the security type (list is not all inclusive of every type of investment risk): • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Market Risk: The price of a security (e.g., stock, bond, or the net asset value of a mutual fund) may decline in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent • Inflation Risk: When any of a security’s underlying fundamentals. For example, political, geopolitical, economic and social conditions may trigger market events. Type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. • Currency Risk: Some international (non-US) investments are subject to fluctuations in the value of the dollar against the currency of the - 8 - Beacon Financial Advisors, Ltd.  investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities (e.g., bonds). • Business Risk: These risks are associated with an industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. Technological developments can render once profitable products less profitable or even obsolete, as another example. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Item 9 - Disciplinary Information Legal and Disciplinary Beacon and its employees have not been involved in legal or disciplinary events related to clients, past or present. Item 10 - Other Financial Industry Activities and Affiliations Financial Industry Activities BEACON is not registered as a securities broker-dealer, or a futures commission merchant, commodity pool operator or commodity trading advisor. Affiliations BEACON has no relationship or arrangements that are material to our advisory business or you with a related person who is an investment company, other investment advisor, financial planning firm, commodity pool operator, commodity trading adviser or futures commission merchant, banking or thrift institution, - 9 - Beacon Financial Advisors, Ltd.  accounting firm, law firm, insurance company or agency, pension consultant, real estate broker or dealer, or an entity that creates or packages limited partnerships. BEACON describes later in Brokerage Practices the arrangement we have with Schwab Advisor Services™ (formerly called Schwab Institutional®), a division of Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer, member SIPC, as the qualified custodian. Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The employees of BEACON have committed to a Code of Ethics that is available for review by you and prospective clients upon request. Clients and prospective clients may request a copy of our Code of Ethics by contacting us at the telephone number listed on the cover page of this brochure. Our Code of Ethics includes the following core principles: Integrity and Honesty • Objectivity • Full Disclosure • • Competence • Confidentiality • Professionalism • Regulatory Compliance Participation or Interest in Client Transactions Neither BEACON nor its employees act as a principal, broker, or agent regarding securities you buy or sell. We have no financial interest in any securities you buy or sell. As noted earlier in Methods of Analysis, Investment Strategies and Risk of Loss our recommendations to you exclusively include no-load mutual funds. BEACON does not have, nor expects to have, any mutual fund shares like those we recommend to you (e.g., stocks, bonds, etc.). As noted earlier in Advisory Business/Principal Owners, BEACON is a limited liability company (LLC) taxed like a partnership. Practically that means all net income flows to the LLC members. It is likely BEACON will have a bank account and/or a brokerage account with funds held in sweep and/or purchased money market funds for normal operating expenses. BEACON'S employees may buy or sell securities that are also held by clients. - 10 - Beacon Financial Advisors, Ltd.  Personal Trading BEACON'S employees may buy or sell securities that are also held by clients. This presents a potential conflict of interest, as they may have the opportunity to trade ahead of you and obtain more favorable pricing. To address this conflict, our policy strictly prohibits our firm and its employees from receiving trade execution priority over your account in the purchase or sale of securities. The Chief Compliance Officer of BEACON is Joshua J. Hebert. He reviews all employee trades each quarter. Item 12 - Brokerage Practices Selecting Brokerage Firms Brokerage Firm(s) BEACON recommends/requires - BEACON does not maintain custody of your assets that we manage on which we advise (i.e., we don't have possession of your money). We may be "deemed" [by government regulations] to have custody of your assets if you give us authority to withdraw assets from your account such as remitting our fees from your accounts (see section on Custody). Your assets must be maintained in an account at a "qualified custodian," generally a broker- dealer or bank. BEACON recommends (and in some cases requires) that you use Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer, member SIPC, as the qualified custodian. Schwab will hold your assets in a brokerage account and buy and sell securities when BEACON instructs them to. However, you will decide whether to open the account(s) with Schwab. BEACON does not open accounts for you. Rather, BEACON assists you in opening Schwab account(s), and in doing so you enter into an account agreement directly with Schwab. Some of your accounts that BEACON manages may be required to be held in custody at custodians other than Schwab. For instance, your employer's retirement account (e.g., 401k, 403b, 401a, 457b, etc.) is offered exclusively through an approved broker (e.g., Fidelity, TIAA-CREF, Vanguard, etc.) and you haven't the option to use Schwab. BEACON is independently owned and operated and is not affiliated with Schwab and has no compensatory arrangement with Schwab. BEACON does not receive fees or commissions from any of these arrangements with Schwab or any custodian/broker. How We Select Brokers/Custodians - BEACON seeks to use a custodian/broker that will hold your assets and execute transactions on terms that are, overall, most advantageous when compared to other available providers and their services. We consider a wide range of factors, including: • Combination of transaction execution services and asset custody services (generally without a separate fee for custody) - 11 - Beacon Financial Advisors, Ltd.  • Capability to execute, clear, and settle trades (buy and sell securities for your account). • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, etc.), especially a large platform of no-load and institutional share class mutual funds. • Quality of services, especially a dedicated group of professionals assigned to work exclusively with BEACON and you. • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices. • Reputation, financial strength, security and stability. • Prior service to BEACON and you. Products and Services Available to Us from Schwab: Schwab Advisor Services™ is Schwab's division serving independent investment advisory firms like BEACON. Schwab provides us and you with access to its institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients' accounts. Schwab's support services generally are available on an unsolicited basis (we don't have to request them) and at no charge to us. Following is a more detailed description of Schwab's support services. ▪ Services That Benefit You - Schwab's Institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we/you might not otherwise have access to or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. ▪ Services that May Not Directly Benefit You - Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in include managing and administering our clients' accounts. They investment research, both Schwab's own and that of third parties. We may use this research to service all or a substantial number of our clients' accounts. (Of note, while BEACON has access to this research via Schwab we do not rely only on this source. We may pay license fees directly to independent research to aid in our overall research effort). In addition to investment research, Schwab also makes available software and other technology that: - 12 - Beacon Financial Advisors, Ltd.  • Provide access to client account data (such as duplicate trade confirmations and account statements). • Facilitate trade execution. • Provide pricing and other market data. • Facilitate payment of our fees from our clients' accounts (as described in Fees and Compensation, Fee Billing). • Assist with back-office functions, recordkeeping, and client reporting. ▪ Services That Generally Benefit Only Us - Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events. • Consulting on technology, compliance, legal, and business needs. • Publications and conferences on practice management and business succession. Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services. Schwab may also discount or waive its fees for some of these services or pay all or part of a third party's fees. Generally, the services described in this paragraph are provided on a company-wide basis by Schwab and are not designed for BEACON’S exclusive use. BEACON does not accept offers that are exclusively for BEACON, such as occasional business entertainment Schwab may offer our personnel and those of other RIA firms. ▪ Our Perspective on Schwab's Services - The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don't have to pay for Schwab's services. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. This may give us an incentive to recommend/require that you maintain your account with Schwab, based on our interest in receiving Schwab's services that benefit our business rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken in aggregate our selection of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab's services (as described previously in How We Select Brokers/Custodians) and not Schwab's services that benefit only us. - 13 - Beacon Financial Advisors, Ltd.  Periodically BEACON negotiates with Schwab the terms of our Pricing Schedule as part of our Pricing Agreement with Schwab. While our Pricing Schedule includes terms for equities, mutual funds, options contracts, fixed income, etc., of interest to BEACON and our clients are the pricing terms for transaction-fee mutual funds. As BEACON seeks to use mostly institutional share class mutual funds, the Schwab transaction-fees are most applicable. Schwab has been responsive in extending to BEACON a Pricing Schedule that we consider competitive and beneficial to you (see Best Execution next page). Best Execution BEACON reviews the execution of trades at Schwab each morning after trades are placed. Normally if a problem arises Schwab will contact us before executing the trade. Trading fees charged by Schwab are also reviewed on this schedule. BEACON does not receive any portion of the trading fees. Your Brokerage and Custody Costs - For our clients' accounts that Schwab maintains, Schwab does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. We negotiated Schwab's commission rates applicable to your client accounts. This negotiation benefits you because the overall commission rates you pay are lower than they would be otherwise. Normally your accounts will consist entirely of mutual fund shares, and BEACON exclusively uses only "no-load" mutual funds. In some instances, with small dollar trades, the mutual funds we buy are part of Schwab's One Source platform and there is no commission (or transaction fee) paid to Schwab by your account. In other instances, the mutual funds we buy are subject to nominal transactions fees paid by your account to Schwab. Presently regardless of the $ size of the purchase or sale we make in your account in our selected institutional share-class mutual funds your Schwab transaction fee will not exceed $18/trade. Soft Dollars Presently BEACON does not have any soft dollar arrangements with any third parties, including Schwab, other than those services described in Selecting Brokerage Firms. Order Aggregation As previously noted, BEACON exclusively uses no-load mutual funds in your accounts that we direct (discretionary). Since all these trades are mutual funds trade aggregation is not applicable to you. - 14 - Beacon Financial Advisors, Ltd.  Item 13 - Review of Accounts Periodic Reviews Account reviews are performed by principal Joshua J. Hebert. Our review/monitoring process benchmarks your current portfolio versus your target portfolio as identified in your Investment Policy Statement (IPS). Our review process includes a daily review of all transactions affecting each account. On a daily basis your accounts are reconciled on a value and cost basis method by electronic means between our portfolio accounting/management system and the broker records of our primary brokerage Schwab Advisor Services. Account reviews are performed annually, and more frequently when market conditions dictate. Review Triggers Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in your own situation. Regular Reports Our method of client reporting is providing you your own online, secure Client Portal and Document Vault (see illustration below). This is in addition to the normal brokerage statements you will receive from the custodian (e.g., Schwab) for your accounts typically on a monthly basis. Your online Client Portal includes numerous reports including performance, capital flows, holdings, realized gains & losses, transactions and projected income for your total portfolio as well as each account that makes up your total portfolio. Item 14 - Client Referrals and Other Compensation Incoming Referrals BEACON has received many client referrals over the years. The referrals are from current clients, estate planning attorneys, accountants, employees, personal friends of employees and other similar sources. The firm does not compensate referring parties for these referrals. Referrals Out BEACON does not accept referral fees or any form of remuneration from other professionals when a BEACON prospect or client is referred to them. From time to time, BEACON may refer clients to other professionals, such as insurance agents. BEACON do not receive any attorneys, accountants, or compensation, referral fees, commissions, or other economic benefits as a result of - 15 - Beacon Financial Advisors, Ltd.  these referrals. Any such professionals are engaged directly by the client, and clients are under no obligation to use any professional BEACON may recommend. Other Compensation BEACON does not receive any other monetary compensation from any third party aside from your fees for our services. We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. You do not pay more for assets maintained at Schwab as a result of these arrangements, yet we benefit from the referral arrangement, so this is a conflict of interest. These products and services, how they benefit us, and the related conflicts of interest are described above in Brokerage Practices. The availability to us of Schwab's products and services is not based on us giving particular investment advice to you, such as buying securities for you. Item 15 - Custody Account Statements All your investments are held at qualified custodians like Schwab, which means the custodians provide account statements directly to you at your email or postal address of record at least quarterly and in most instances monthly. You should carefully review those statements promptly when you receive them. Custodians like Schwab maintain actual custody of your assets. As noted above your custodian will send account statements to you. As noted below, you are urged to compare your account statements received directly from your custodian to the Client Portal reports we provide to you. You may have authorized our quarterly advisory fees be debited (e.g., withdrawn) from your investment account--*government regulations deem us to have custody in this instance. We provide you with a quarterly Fee-For-Service Schedule in your Client Portal Document Vault that details the fee calculation. We are not required to provide your Fee-For-Service Schedule to Schwab, and Schwab does not verify the accuracy of our advisory fee calculation. Performance Reports You are urged to compare your account statements received directly from the custodians (e.g., Schwab) to your Client Portal provided by BEACON. Previously in Review of Accounts/Regular Reports, we described the reports we customarily provide in your online, secure Client Portal. As a footnote on your Client Portal, we place the following legend as a reminder to you to compare/contrast: - 16 - Beacon Financial Advisors, Ltd.  "Clients are urged to compare the custodians (Schwab et al) account statements with your Client Portal monthly ending values". Net Worth Statements We periodically provide many clients with net worth statements and net worth graphs that are generated from our CRM system (client relationship management). Net worth statements contain approximations of bank account balances and/or held- away accounts provided by you, as well as the value of land and hard-to-price real estate. The net worth statements are used for long-term financial planning where the exact values of assets are not material to the financial planning tasks. Item 16 - Investment Discretion Discretionary Authority for Trading As discussed previously in Advisory Business/Asset Management, you normally will place your assets in a brokerage account designated as a discretionary account. BEACON accepts discretionary authority to manage securities accounts on your behalf. BEACON has the authority to determine, without obtaining your specific consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. At any time, you may contact us if there are any changes in your financial situation or investment objectives, or if you wish to impose, add, or modify any reasonable restrictions to our investment management services. You approve the custodian to be used when you open your brokerage account(s). BEACON does not receive any portion of the transaction fees or commissions paid by you to the custodian on executed trades. Discretionary trading authority facilitates placing trades in your accounts on your behalf so that we may promptly implement the investment policy that you have approved in writing. As discussed previously in Advisory Business/Asset Management, there are instances when you could have a brokerage account designation as non-discretionary. In that case we do not have authority to buy or sell securities. Limited Power of Attorney A limited power of attorney is a trading authorization for the purpose of authorizing us to have investment discretion. You sign a limited power of attorney so that we may execute the trades that you have approved. The limited power of attorney is part of the brokerage account application you open with the custodian. - 17 - Beacon Financial Advisors, Ltd.  Item 17 - Voting Client Securities Proxy Votes A proxy is a designated person acting for you. Whether you own common stock (shares) of a company or shares in a mutual fund, there are times when you have the right to vote on matters put before shareholders. The matters can range from financial issues to social issues, or can be as straightforward as voting to ratify or not the board of directors, or the outside accounting firm or legal counsel, etc. If you so designate on your brokerage application, BEACON votes proxies for mutual fund securities over which it maintains discretionary authority consistent with our proxy voting policy. The brokerage application addresses proxy voting with language like "Issuer Communications and Related Actions." If you do not designate for us to vote your proxy, that remains your duty. In this case the custodian will provide you with the proxy materials. A free copy of the BEACON proxy voting policy is available upon request. Item 18 - Financial Information Financial Condition BEACON does not have any financial impairment that will preclude us from meeting engagement commitments to you. Regulations require we provide you with our balance sheet in certain circumstances. In our case, a balance sheet is not required to be provided because BEACON does not serve as a custodian for your funds or securities and does not require prepayment of fees of more than $1,200 per client six months or more in advance. Neither BEACON nor any of our principals or employees has ever been the subject of a bankruptcy petition. - 18 - Beacon Financial Advisors, Ltd.