Bill Few Associates, Inc.

A D V B R O C H U R E 2100 Georgetown Drive Suite 600 Sewickley, PA 15143 Telephone: 412-630-6000 Email: jjones@billfew.com www.billfew.com March 31, 2026 This brochure provides information about the qualifications and business practices of Bill Few Associates, Inc. If you have any questions about the contents of this brochure, please contact John Jones at 412-630-6000 or jjones@billfew.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. Bill Few Associates, Inc. is a registered investment advisor. Registration does not imply a certain level of skill or training. Additional information about Bill Few Associates, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The CRD for Bill Few Associates, Inc. is 133561. Part 2A of Form ADV and other important information relating to accounts with Bill Few Associates, Inc. can be found at www.billfew.com/bfa-disclosures.  ITEM 2: MATERIAL CHANGES The last annual update of the Form ADV Part 2A was March 31, 2025 No material changes since last Form ADV update. Additional minor updates and clarifications occur throughout this document and we encourage you to read the entire Brochure. We may, at any time, update this Brochure. We will send you a copy or offer you a copy (either by electronic means or in hard copy form), as required by regulations. 2  TABLE OF CONTENTS 1 2 3 4 7 9 9 10 12 12 13 13 15 16 16 16 16 ITEM 1: COVER PAGE ITEM 2: MATERIAL CHANGES ITEM 3: TABLE OF CONTENTS ITEM 4: ADVISORY BUSINESS ITEM 5: FEES AND COMPENSATION ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ITEM 7: TYPES OF CLIENTS ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ITEM 9: DISCIPLINARY INFORMATION ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ITEM 11: CODE OF ETHICS ITEM 12: BROKERAGE PRACTICES ITEM 13: REVIEW OF ACCOUNTS ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION ITEM 15: CUSTODY ITEM 16: INVESTMENT DISCRETION ITEM 17: VOTING CLIENT SECURITIES ITEM 18: FINANCIAL INFORMATION 17 SCHEDULE A 3  ITEM 4: ADVISORY BUSINESS Bill Few Associates, Inc. is a SEC-registered investment adviser with its principal place of business located in Pittsburgh, Pennsylvania. Bill Few Associates, Inc. began conducting business in 1987. Bill Few Associates, Inc. is a wholly owned subsidiary of Bill Few Financial Group, Inc. (BFFG), which is owned by the Bill Few Associates, Inc. Employee Stock Ownership Trust. Bill Few Associates, Inc. offers the following advisory services to our clients: INDIVIDUAL PORTFOLIO MANAGEMENT Our firm provides continuous advice to clients regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives, based on a client's particular circumstances are established, we help develop a client's personal investment strategy and create and manage a portfolio based on those findings. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following types of securities: Common Stock Commercial Paper Certificates of Deposit Corporate Bonds Government Bonds Municipal Bonds Mutual Funds/ETF's Options Preferred Stock Variable Annuities Because some types of investments involve certain additional degrees of risk, they will only be implemented or recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. MUTUAL FUND MODEL PORTFOLIOS Our firm provides portfolio management services to clients through our Managed Mutual Fund Account program. We manage these accounts on a discretionary or non-discretionary basis. Each model portfolio is designed to meet a particular investment goal. Through personal discussions with the client in which the client’s goals and objectives are established, a client’s base allocation is determined (i.e., equities/fixed income/cash). Account supervision is guided by the client’s stated objectives as well as tax considerations, where appropriate. In the program, our base asset allocation is determined through ongoing fundamental and technical research. The allocation is also discussed at our firm’s Investment Policy Committee meetings. Through this research and discussions, it is determined how much we allocate to each investment category (ex. large-cap, small-cap, international, short-term bond, high-yield bond, etc.). At this point, we match our firm’s base allocation with the client’s investment needs to form a model created specifically to meet a particular client’s investment goals. The accounts are managed to that individual model, although our firm may change the allocation as market conditions change. The accounts are rebalanced periodically as performance moves them away from the appropriate percentages. Mutual funds are the primary investment vehicle, although our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the same security types identified earlier in this section under Individual Portfolio Management. 4  Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. To ensure that our initial determination of an appropriate portfolio remains suitable and that the account continues to be managed in a manner consistent with the client's financial circumstances, we will periodically send reminders to clients requesting them to review their account information and to provide us with any updated information regarding changes in their financial situation and investment objectives. We also conduct periodic meetings with clients to review their accounts and to update their objectives and risk tolerance as well as their suitability profile. AMERICAN FUNDS F-2 DIRECT PROGRAM The American Funds F-2 Direct Program is a non-discretionary, fee-based program that facilitates investments into American Funds F-2 share class offerings directly held at the American Funds. Monies invested in this program are limited to the American Funds family, unlike our other fee-based programs which have an extensive list of available securities. Generally, the F-2 share class offerings have a higher cost than the F-3 that are available in the BFA Wrap Fee program when held at Pershing Advisory Solutions. Other differences of this program include account related fees, billing, and account minimums. The minimum fund investment is $250 per fund ($1,000 for money market or tax-exempt funds) as specified in the funds’ prospectus. Currently American Funds charges a one-time $10 set up fee and a $10 per annum custodial fee for IRAs and Coverdell ESA accounts. Through personal discussions with the client in which the client’s goals and objectives are established, a client’s base allocation is determined (i.e., equities/fixed income/cash). Account supervision is guided by the client’s stated objectives as well as tax considerations, where appropriate. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. To ensure that our initial determination of an appropriate portfolio remains suitable and that the account continues to be managed in a manner consistent with the client's financial circumstances, we will periodically send reminders to clients requesting them to review their account information and to provide us with any updated information regarding changes in their financial situation and investment objectives. We also conduct periodic meetings with clients to review their accounts and to update their objectives and risk tolerance as well as their suitability profile. FINANCIAL PLANNING We provide financial planning services, which entails a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service receive a written report which provides the client with a detailed financial plan designed to assist the client to achieve his or her financial goals and objectives. In general, the financial plan can address any or all of the following areas: Personal Financial Planning: We review family records, budgeting, personal liability, estate information and financial goals. Tax & Cash Flow Analysis: We analyze the client’s income tax, spending and planning for past, current and future years; then illustrate the impact of various investments on the client’s current income tax and future tax liability. Investment Planning: We analyze investment alternatives and their effect on the client's portfolio. Insurance Needs Analysis: We review existing policies to ensure proper coverage for life, health, disability, and long-term care. 5  Retirement Planning: We analyze current strategies and investment plans to help the client achieve his or her retirement goals. Death & Disability Needs Analysis: We review the client’s cash needs at death, income needs of surviving dependents, estate planning and disability income. Estate Planning: We assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid and elder law. As part of the planning process, we gather required information through in-depth personal interviews. Information gathered may include the client's current financial status, tax status, future goals, performance objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or investment professional. Implementation of financial plan recommendations is entirely at the client's discretion. We also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. Typically, the financial plan is presented to the client within three months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. Please note, we are not a law firm, attorney, accounting or tax adviser. Our financial planning services should not be interpreted as legal or tax advice. CONSULTING SERVICES Clients can also receive investment advice on a more focused basis. This may include advice on only an isolated area(s) of concern such as estate planning, retirement planning, or any other specific topic. We also provide specific consultation and administrative services regarding investment and financial concerns of the client. As some individuals of Bill Few Associates, Inc. are licensed as insurance agents of various insurance companies, insurance recommendations are limited to only those products offered through these companies. RETIREMENT ACCOUNTS Clients, and prospective clients, considering a rollover from a qualified employer sponsored retirement plan (“Employer Retirement Plan”) to an Individual Retirement Account (“IRA”) are encouraged to consider the advantages and disadvantages of an IRA rollover from their existing Employer Retirement Plan. A plan participant leaving an employer typically has four options (and may engage in a combination of these options): 1) Leave the money in the former Employer Retirement Plan, if permitted; 2) Transfer the assets to the new employer’s plan, if one is available and if rollovers are permitted; 3) Rollover the assets to an IRA; 4) Cash out (or distribute) the assets and pay the taxes due. Investors may face increased fees when they transfer retirement savings from their current Employer Retirement Plan to an IRA. Investors are advised that even if there are no costs associated with the IRA rollover itself, there will be costs associated for account administration, investment management or both. In addition to the fees charged by Bill Few Associates, Inc., the underlying investments (mutual fund, ETF, annuity, or other investment) typically also charge management fees. Custodial fees may also apply. Investing in an IRA managed by Bill Few Associates, Inc. is typically more expensive than the current Employer Retirement Plan. Investors should inquire with their retirement plan sponsor about the costs and other fees associated with their current plan in order to compare their options. While individuals of Bill Few Associates endeavor at all times to put the interests of the clients first as part of our fiduciary duty, clients should be aware that the additional compensation paid to Bill Few Associates and their financial professional when the choice is made to distribute and rollover the proceeds of an Employer Retirement Plan account to an IRA with our firm is a conflict of interest. Conflicts of interest are mitigated through discussions between the investor and the financial professional. 6  When we provide investment advice to you regarding your retirement accounts, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates certain conflicts with your interests, so we operate under PTE 2020- 02, where applicable, a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under PTE 2020-02, when providing individualized investment advice to retirement investors, we must also: • Meet a professional standard of care (give prudent advice); • Not put our financial interests ahead of yours (give loyal advice); • Avoid misleading statements about our conflicts of interest, fees and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about our conflicts of interest. AMOUNT OF MANAGED ASSETS As of December 31, 2025, we were actively managing assets of $2,136,754,998 on a discretionary basis and an additional $586,420,466 of assets on a non-discretionary basis for a total of $2,723,175,464. ITEM 5: FEES AND COMPENSATION The advisory fee will be disclosed prior to services being provided and agreed upon in a written investment advisory agreement. Our advisory fees for portfolio management are based upon a percentage of assets under management and generally range from .25% to 1.25%. Our Standard Fee Schedule is a tiered schedule and is billed as follows: Tier First Next Next Above Asset Level $ 500,000 500,000 500,000 1,500,000 Annual Rate 1.25% 1.00% .75% .50% Generally, advisory fees are billed quarterly in advance and calculated based on the account’s market value (including cash and cash equivalents) on the last business day of the prior quarter. Fees for new accounts, and for new deposits into existing accounts, will be pro-rated based on the remaining number of days left in the quarter. Accounts within the same household, and set to the same tiered fee schedule, can be combined for breakpoint purposes. Fees are debited directly from the client’s Pershing account unless the client requests to pay by invoice in which an invoice will be sent to the client detailing the advisory fees for the upcoming quarter. For advisory accounts in which the management fee is directly deducted from their account, the client's custodian is advised by Bill Few Associates, Inc. of the fee amount that is to be deducted. On at least a quarterly basis, the custodian is required to send to the client a statement showing all transactions within the account during the reporting period, including the fee amount. Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review their account statements to verify the accuracy of the calculation, among other things. Clients should contact us directly if they believe that there may be an error in their statement. Generally, a minimum of $250,000 of assets under management is required for portfolios comprised mainly of individual equities or individual bonds. The minimum account size for portfolios predominantly comprised of mutual funds is $50,000. The account size may be negotiable under certain circumstances. Bill Few Associates, Inc. may group certain related client accounts for the purposes of achieving the minimum account size and determining the annualized fee. Although Bill Few Associates, Inc. has established the aforementioned fee schedule, we retain the discretion to negotiate alternative fees on a client-by-client basis which represents a conflict of interest. Client facts, circumstances and needs are 7  considered in determining the fee schedule. These include the complexity of the client assets to be placed under management; anticipated future additional assets; related accounts; portfolio style, account composition, reports, among other factors. The specific annual fee schedule is identified in the contract between the financial professional and each client. Discounts, not generally available to our advisory clients, may be offered to family members and friends of associated persons of our firm. AMERICAN FUNDS F-2 DIRECT PROGRAM American Funds F-2 Direct Program fees are calculated and debited by American Funds quarterly in arrears in the second month of each calendar quarter and is based upon the accounts average daily balance. The program’s advisory fee is a flat fee that ranges between .25% - 1.25%. Billing is handled by American Funds and fees are deducted from the client account. Assets are held directly with American Funds in the F-2 share class, which have no 12b-1 fees but have a higher cost than their F-3 share class equivalent. There is a $10 set up fee charged by the American Funds and an annual $10 custodial fee for IRAs and Coverdell ESAs. We do not receive any compensation from the setup and custodial fees. The client must acknowledge and agree to allow American Funds to liquidate shares of the funds held in order to cover any applicable advisory or account service fees. Although Bill Few Associates, Inc. has established the aforementioned fee schedule, we retain the discretion to negotiate alternative fees on a client-by-client basis which represents a conflict of interest. FINANCIAL PLANNING FEES Bill Few Associates, Inc.'s Financial Planning fee is determined based on the nature of the services being provided and the complexity of each client’s circumstances. All fees are agreed upon prior to entering into a contract with any client. Our Financial Planning fees are calculated and charged on a fixed fee basis, typically ranging from $500 to $5,000, depending on the specific arrangement reached with the client. We may request a retainer upon completion of our initial fact-finding session with the client; however, advance payment will never exceed $500 for work that will not be completed within six months. The balance is due upon completion of the plan. CONSULTING SERVICES FEES Bill Few Associates, Inc.'s Consulting Services fee is determined based on the nature of the services being provided and the complexity of each client’s circumstances. All fees are agreed upon prior to entering into a contract with any client. Our Consulting Services fees are calculated and charged on an hourly basis, ranging from $200 to $300 per hour. An estimate for the total hours is determined at the start of the advisory relationship. OTHER REVENUE Bill Few Associates Inc. is licensed to sell insurance products in addition to its advisory business. Certain investment personnel of our firm are agents for various insurance companies. As such, these individuals are able to receive separate, yet customary commission compensation resulting from implementing product transactions on behalf of advisory clients. Clients, however, are not under any obligation to engage these individuals when considering the implementation of advisory recommendations. The implementation of any or all recommendations is solely at the discretion of the client. Bill Few Associates, Inc. permits third party payments/reimbursements for advisor education, seminars and entertainment. While these individuals endeavor at all times to put the interest of the clients first as part of Bill Few Associates, Inc.'s fiduciary duty, clients should be aware that the receipt of additional compensation itself creates a conflict of interest and may affect the judgment of these individuals when making recommendations. GENERAL INFORMATION Termination of the Advisory Relationship: A client agreement may be canceled at any time, by either party, for any reason upon receipt of written notice. As disclosed above, certain fees are paid in advance of services provided. Upon termination of 8  any account, any prepaid, unearned fees will be promptly refunded. In calculating a client’s reimbursement of fees, we will pro-rate the reimbursement according to the number of days remaining in the billing period after the effective date of the termination. Mutual Fund Fees: All fees paid to Bill Few Associates, Inc. for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and/or ETFs to their shareholders. These fees and expenses are described in each fund's prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. A client could invest in a mutual fund directly, without our services. In that case, the client would not receive the services provided by our firm which are designed, among other things, to assist the client in determining which mutual fund or funds are most appropriate to each client's financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and our fees to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Mutual Fund Share Classes: Many mutual fund companies currently offer multiple share classes of their funds, each with a different expense structure. Often, financial institutions, such as investment advisers, are eligible to buy for their advisory clients lower cost shares than are available to retail customers. Bill Few Associates annually performs a review of the mutual funds held (and/or recommended) in its advisory accounts to ensure that its advisory clients are holding the lowest cost shares available to them. If during the annual review, a lower cost share class mutual fund is identified, Bill Few Associates, Inc. will convert the shares to the lowest cost share class for the client. As Bill Few Associates, Inc. uses the services of Pershing Advisory Solutions, LLC, not all securities or share classes are available on their platform. Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees and expenses charged by custodians and imposed by broker-dealers (see Schedule A), including, but not limited to, margin interest, statement, delivery, transfer and other fees. For investors that participate in the Bill Few Associates Wrap Fee Program, transactions costs for clearing and execution of trades are paid by Bill Few Associates, Inc. Additional information can be found in the BFA Wrap Fee Program Brochure. Please refer to the "Brokerage Practices" section under Item 12 of this brochure for additional information. ERISA Accounts: Bill Few Associates, Inc. is deemed to be a fiduciary to advisory clients that are employee benefit plans pursuant to the Employee Retirement Income and Securities Act ("ERISA"), and regulations under the Internal Revenue Code of 1986 (the "Code"), respectively. As such, our firm is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include among other things, restrictions concerning certain forms of compensation. Advisory Fees in General: Clients should note that similar advisory services may or may not be available from other registered or unregistered investment advisers for similar or lower fees. In addition, fee-based accounts are typically more expensive over time versus commission-based accounts due to a higher level of service and ongoing management delivered. Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees in excess of $1,200 more than six months in advance of services rendered. ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Bill Few Associates, Inc. does not charge performance-based fees. ITEM 7: TYPES OF CLIENTS Bill Few Associates, Inc. provides advisory services to the following types of clients: Individuals Charitable organizations High net worth individuals Corporations or other businesses Pension and profit sharing plans As previously disclosed in Item 5, our firm has established certain initial minimum account requirements, based on the nature of the services being provided. For a more detailed understanding of those requirements, please review the disclosures provided in Item 5. 9  ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS METHODS OF ANALYSIS We use the following methods of analysis in formulating our investment advice and/or managing client assets: Fundamental Analysis: We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Qualitative Analysis: We subjectively evaluate non-quantifiable factors such as quality of management, labor relations, and strength of research and development factors not readily subject to measurement and predict changes to share price based on that data. A risk in using qualitative analysis is that our subjective judgment may prove to be incorrect. Asset Allocation: Rather than focusing primarily on securities selection, we attempt to identify an appropriate ratio of equities, fixed income, and cash suitable to the client’s investment goals and risk tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the ratio of securities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the client’s goals. Mutual Fund and/or ETF Analysis: We look at the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap in the underlying investments held in another fund(s) in the client’s portfolio. We also monitor the funds or ETFs in an attempt to determine if they are continuing to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the client’s portfolio. Risks for all forms of analysis: Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. INVESTMENT STRATEGIES We use the following strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: Long-term purchases: We purchase securities with the intention of holding them in the client's account for a year or longer. Typically, we employ this strategy when we believe the securities to be currently undervalued, and/or we want exposure to a particular asset class over time, regardless of the current projection for this class. A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantage of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. 10  Short-term purchases: When utilizing this strategy, we purchase securities with the intention of selling them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities we purchase. A short-term purchase strategy poses risks should the anticipated price swing not materialize; we are then left with the option of having a long-term investment in a security that was designed to be a short-term purchase, or potentially taking a loss. In addition, this strategy involves more frequent trading than does a longer-term strategy and will result in less favorable tax treatment of short-term capital gains. Margin transactions: We will purchase stocks for your portfolio with money borrowed from your brokerage account. This allows you to purchase more stock than you would be able to with your available cash and allows us to purchase stock without selling other holdings. Managing accounts on Margin is only done with prior client consent and authorization and represents a limited number of accounts under active management. Option writing: We may use options as an investment strategy. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a specific price on or before a certain date. An option, just like a stock or bond, is a security. An option is also a derivative, because it derives its value from an underlying asset. The use of Option writing is only done with prior client consent and authorization and represents a limited number of accounts under active management. The two types of options are calls and puts: A call gives us the right to buy an asset at a certain price within a specific period of time. We will buy a call if we anticipate the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. We will buy a put if we anticipate the price of the stock will fall before the option expires. We will use options to speculate on the possibility of a sharp price swing. We will also use options to "hedge" a purchase of the underlying security; in other words, we will use an option purchase to limit the potential upside and downside of a security we have purchased for your portfolio. We use "covered calls", in which we sell an option on a security you own. In this strategy, you receive a fee for making the option available, and the person purchasing the option has the right to buy the security from you at an agreed-upon price. We use a "spreading strategy", in which we purchase two or more option contracts (for example, a call option that you buy and a call option that you sell) for the same underlying security. This effectively puts you on both sides of the market, but with the ability to vary price, time and other factors. Risk of Loss: Securities investments are not guaranteed, and you may lose money on your investments. Clients should understand that investing in any securities, including mutual funds, involves a risk of loss of both income and principal. We ask that you work with us to help us understand your tolerance for risk. Leveraged and Inverse Funds/ETF Risks: Bill Few Associates, Inc. does not recommend Leveraged and Inverse Funds/ETFs. However, clients may direct us to purchase or hold these investments in their accounts. While Leveraged and Inverse ETFs offer potential for amplified returns, they also carry significant risks. There is the possibility of significant losses in short periods of time including the risk that you could lose most or all of your investment, especially in volatile markets. These funds generally have a daily investment objective and are not designed to track their benchmark for longer periods of time. The effects of volatility and compounding could cause their returns to diverge materially from the benchmark when held longer than a single trading day. Investors should review the investment prospectus and principal risks described therein prior to investing. Penny Stock Risks: Penny stocks are low-priced shares of small companies. Bill Few Associates, Inc. does not recommend investing in Penny stocks. However, clients may direct us to purchase or hold these investments in their accounts. Penny stocks may trade infrequently, which means that it may be difficult to sell penny stock shares. Because it may be difficult to find quotations for penny stocks, they may be impossible to accurately price. Penny stocks generally have lower liquidity, 11  are subject to volatile price fluctuations and often have large bid/ask spreads. Penny stocks are considered speculative investments and investors may lose some or all of their investment. Market Disruptions and other Impacts of Force Majeure Events: Financial markets may be impacted by the outbreak of a contagious disease, a terrorist act or threat, acts of war or severe weather incidents. An outbreak of a contagious disease with the potential to become a pandemic, or the measure taken by the governments of affected countries against such potential outbreaks, could seriously disrupt financial markets, which could have an adverse effect on investment performance. The spread of such disease can quickly and negatively impact business operations, supply chains, business and leisure travel, stores, restaurants, sports events and other venues. These sudden changes in business and consumer behaviors can cause instability in the world financial markets and may generate localized or even global economic instability. The outbreak of a contagious disease, a terrorist act or threat, acts of war or severe weather incidents can lead to increased volatility in investments securities. ITEM 9: DISCIPLINARY INFORMATION Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that may be material to your evaluation of a firm or the integrity of its management. In 2018, Bill Few Associates, Inc. elected to participate in the Securities and Exchange Commission’s Mutual Fund Share Class Selection Disclosure Initiative (“SCSD Initiative”). The SCSD Initiative provided investment advisers with the opportunity to voluntarily self-report to the SEC’s Division of Enforcement possible inadequacies with their disclosures concerning mutual fund share class selection and the fees pursuant to Rule 12b-1 under the Investment Company Act of 1940. As part of the SCSD Initiative, BFA reviewed their disclosures and activities related to mutual fund share class selection. At the conclusion of the SCSD Initiative, BFA consented to a settlement agreement to reimburse accounts the amount of 12b-1 fees received ($2,201,454.07) along with prejudgment interest ($191,850.74). The SEC did not impose a fine or civil monetary penalty in recognition of the fact that BFA self-reported. ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Certain investment personnel of our firm are agents for various insurance companies. As such, these individuals are able to receive separate, yet customary commission compensation resulting from implementing product transactions on behalf of advisory clients. Clients, however, are not under any obligation to engage these individuals when considering implementation of advisory recommendations. The implementation of any or all recommendations is solely at the discretion of the client. While Bill Few Associates, Inc. and these individuals endeavor at all times to put the interest of the clients first as part of our fiduciary duty, clients should be aware that the receipt of additional compensation itself creates a conflict of interest and may affect the judgment of these individuals when making recommendations. The following procedures are employed to address this conflict: • We disclose to clients the existence of all material conflicts of interest, including the potential for our firm and our employees to earn compensation from advisory clients in addition to our firm's advisory fees; • We disclose to clients that they are not obligated to purchase recommended investment products from our employees or affiliated companies; • We collect, maintain and document accurate, complete and relevant client background information, including the client’s financial goals, objectives and risk tolerance; • Our firm's management conducts regular reviews of each client account to verify that all recommendations made to a client are suitable to the client’s needs and circumstances; • We require that our employees seek prior approval of any outside employment activity so that we may ensure that any conflicts of interests in such activities are properly addressed; • We periodically monitor these outside employment activities to verify that any conflicts of interest continue to be properly addressed by our firm; and • We educate our employees regarding the responsibilities of a fiduciary, including the need for having a reasonable and independent basis for the investment advice provided to clients. 12  ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that we require of our employees, including compliance with applicable federal securities laws. Bill Few Associates, Inc. and our personnel owe a duty of loyalty, fairness and good faith towards our clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code. Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions reports as well as initial and annual securities holdings reports that must be submitted by the firm’s access persons. Among other things, our Code of Ethics also requires the prior approval of any acquisition of securities in a limited offering (e.g., private placement) or an initial public offering. Our code also provides for oversight, enforcement and recordkeeping provisions. Bill Few Associates, Inc.'s Code of Ethics further includes the firm's policy prohibiting the use of material non-public information. While we do not believe that we have any particular access to non-public information, all employees are reminded that such information may not be used in a personal or professional capacity. A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by email sent to jjones@billfew.com or by calling us at 412-630-6000. Bill Few Associates, Inc. and individuals associated with our firm are prohibited from engaging in principal transactions. Our Code of Ethics is designed to assure that the personal securities transactions, outside business activities and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Our firm and/or individuals associated with our firm buy or sell for their personal accounts securities identical to or different from those recommended to our clients. Such transactions occur at or about the same time as client transactions. In addition, any related person may have an interest or position in a certain securities which may also be recommended to a client. ITEM 12: BROKERAGE PRACTICES Broker Selection: As an investment advisory client, it is your choice to select a broker-dealer to execute your trades and to custody the assets that will be held in your account. As a means of streamlining the overall administration and management of your investment accounts, we recommend clients choose the brokerage services of Pershing Advisory Solutions, LLC (PAS). PAS is registered with the U.S. Securities and Exchange Commission (“SEC”) and the Financial Industry Regulatory Authority (“FINRA”). By working with PAS, your trades will be executed, cleared and custodied at Pershing LLC, a broker- dealer and clearing firm that is registered with the SEC and FINRA. Soft Dollar Arrangements: Soft dollars is a term used when payments for research services by an investment adviser to a brokerage firm is made through commission revenue, as opposed to normal direct payments of cash. Bill Few Associates, Inc. does not have any soft dollar arrangements and does not receive any soft dollar benefits. The majority of our research is generated by our team of experienced research analysts utilizing generally available research reports and subscriptions that are paid for directly by Bill Few Associates, Inc. Directed Brokerage: If a client directs us to use a broker-dealer other than Pershing Advisory Solutions, LLC (PAS) to execute some or all account transactions, the client must understand that it is his or her responsibility to negotiate the terms and conditions of such services. Under these circumstances, Bill Few Associates, Inc. has no authority to negotiate prices and commissions or obtain volume discounts on behalf of the client. This “directed brokerage” arrangement may impair our ability to obtain the best qualitative trade execution for you. In fact, in some cases you may pay higher transaction prices and commissions than those paid by clients who use the brokerage services of PAS. Brokerage for Client Referrals: We do not recommend broker-dealers to clients based on our interest in receiving client referrals from the broker-dealer. 13  Block Trading: We will place block trades where possible and when advantageous to clients. Block trading is typically done for equities in which the total quantity of shares to be bought or sold is a significant amount. This blocking of trades permits the trading of aggregate blocks of securities composed of assets from multiple client accounts, so long as transaction costs are shared equally between all accounts included in any such block. Block trading may allow us to execute equity trades in a timelier, more equitable manner, at an average share price. Bill Few Associates, Inc. will typically aggregate trades among clients whose accounts can be traded at a given broker. Bill Few Associates, Inc.'s block trading policy and procedures are as follows: Transactions for any client account may not be aggregated for execution if the practice is prohibited by or inconsistent with the client's advisory agreement with Bill Few Associates, Inc., or our firm's order allocation policy. The trading desk or trader, in concert with the portfolio manager, must determine that the purchase or sale of the particular security involved is appropriate for the client and consistent with the client's investment objectives and with any investment guidelines or restrictions applicable to the client's account. The portfolio manager must reasonably believe that the order aggregation will benefit, and will enable Bill Few Associates, Inc. to seek best execution for each client participating in the aggregated order. This requires a good faith judgment at the time the order is placed for the execution. It does not mean that the determination made in advance of the transaction must always prove to have been correct in the light of a "20-20 hindsight" perspective. Best execution includes the duty to seek the best quality of execution, as well as the best net price. Prior to entry of an aggregated order, a written order ticket must be completed which identifies each client account participating in the order and the proposed allocation of the order, upon completion, to those clients. If the order 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 pro rata among the participating client accounts in accordance with the initial order ticket or other written statement of allocation. However, adjustments to this pro rata allocation may be made to participating client accounts in accordance with the initial order ticket or other written statement of allocation. Furthermore, adjustments to this pro rata allocation may be made to avoid having odd amounts of shares held in any client account, or to avoid excessive ticket charges in smaller accounts. Generally, each client that participates in the aggregated order must do so at the average price for all separate transactions made to fill the order and must share in the commissions/execution charge on a pro rata basis in proportion to the client's participation. Under the client’s agreement with the custodian/broker, transaction costs may be based on the number of shares traded for each client. If the order will be allocated in a manner other than stated in the initial statement of allocation, a written explanation of the change must be provided to and approved by the Chief Compliance Officer no later than the morning following the execution of the aggregate trade. Bill Few Associates, Inc.'s client account records separately reflect, for each account in which the aggregated transaction occurred, the securities which are held by, and bought and sold for, that account. Funds and securities for aggregated orders are clearly identified on Bill Few Associates, Inc.'s records and to the broker- dealers or other intermediaries handling the transactions, by the appropriate account numbers for each participating client. No client or account will be favored over another. Trading Errors: It is Bill Few Associates policy to identify and correct any errors as promptly as possible without disadvantaging the client. Any losses incurred from a firm trading error is the responsibility of the firm. Any gains where it is not feasible to pass the gain to the client will be retained by the firm and used to offset losses. 14  ITEM 13: REVIEW OF ACCOUNTS INDIVIDUAL PORTFOLIO MANAGEMENT Reviews: While the underlying securities within Individual Portfolio Management Services accounts are monitored, these accounts are reviewed at least annually. Accounts are reviewed in the context of each client's stated investment objectives and guidelines. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, or market, political or economic environment. These accounts are reviewed by Bill Few Associates financial analysts and/or the financial professional for each account. Reports: In addition to the statements and confirmations of transactions that clients receive from their broker-dealer or custodian, we provide reports summarizing account performance, balances and holdings during regular review meetings with clients. These reports will also remind the client to notify us if there have been changes in the client's financial situation or investment objectives and whether the client wishes to impose investment restrictions or modify existing restrictions. MUTUAL FUND MODEL PORTFOLIO MANAGEMENT Reviews: While the underlying securities within the Mutual Fund Model Portfolio Management accounts are continually monitored, these accounts are reviewed at least annually. Accounts are reviewed in the context of the investment objectives and guidelines of each model portfolio as well as any investment restrictions provided by the client. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic environment. These accounts are reviewed by Bill Few Associates financial analysts and/or the financial professional for each account. Reports: In addition to the statements and confirmations of transactions that clients receive from their broker-dealer or custodian, we may provide reports summarizing account performance, balances and holdings during regular review meetings with clients. These reports will also remind the client to notify us if there have been changes in the client's financial situation or investment objectives and whether the client wishes to impose investment restrictions or modify existing restrictions. AMERICAN FUNDS F-2 DIRECT PROGRAM Reviews: While the underlying securities within the American Funds F-2 Direct Program are monitored, these accounts are reviewed at least annually. Accounts are reviewed in the context of the investment objectives. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic environment. These accounts are reviewed by the financial professional for each account. Reports: In addition to the statements and confirmations of transactions that clients receive from their custodian, we may provide reports summarizing account performance, balances and holdings during regular review meetings with clients. These reports will also remind the client to notify us if there have been changes in the client's financial situation or investment objectives and whether the client wishes to impose investment restrictions or modify existing restrictions. FINANCIAL PLANNING SERVICES Reviews: While reviews may occur at different stages depending on the nature and terms of the specific engagement, typically no formal reviews will be conducted for Financial Planning clients unless otherwise contracted for. Such reviews will be conducted by the financial professional. Reports: Financial Planning clients will receive a completed financial plan. Additional reports will not typically be provided unless otherwise contracted for. 15  CONSULTING SERVICES Reviews: While reviews may occur at different stages depending on the nature and terms of the specific engagement, typically no formal reviews will be conducted for Consulting Services clients unless otherwise contracted for. Such reviews will be conducted by the client's account representative. Reports: These client accounts will receive reports as contracted for at the inception of the advisory engagement. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION It is Bill Few Associates, Inc.'s policy not to accept or allow our related persons to accept any form of compensation, including cash, sales awards or other prizes, from a non-client in conjunction with the advisory services we provide to our clients. We believe these practices would create an unacceptable conflict of interest. Bill Few Associates, Inc. does not compensate any third party for client referrals. ITEM 15: CUSTODY Bill Few Associates, Inc. does not maintain physical custody of client funds or securities. However, we are deemed to have custody of client assets under certain circumstances such as allowing clients to execute standing letters of authorization for asset movement, where we have authority to obtain temporary possession of client funds for deposit into their accounts and directly debiting advisory fees from client accounts. In the instances where Bill Few Associates is deemed to have custody, we will follow the requirements of rule 206(4)-2 including any required audits. Clients will receive, at least quarterly, statements from their qualified custodian, detailing the activity, account holdings and balances of their investment account. It is extremely important for clients to carefully review their custodial statements to verify the accuracy of the fee calculations, deposits, withdrawals, and asset movements among other things. Clients should contact us directly if they believe that there may be an error in their statement. We urge clients to compare the account statements from their qualified custodian(s) with the reports they receive from Bill Few Associates, Inc. ITEM 16: INVESTMENT DISCRETION Clients may hire us to provide discretionary asset management services, in which case we place trades in a client's account without contacting the client prior to each trade to obtain the client's permission. Our discretionary authority includes the ability to determine the specific securities to buy or sell, the amount of the securities to buy or sell and the timing of when to buy or sell. Clients give us discretionary authority when they sign a discretionary agreement with our firm and may limit this authority by giving us written instructions. Clients may also change or amend such limitations by providing us with written instructions. ITEM 17: VOTING CLIENT SECURITIES As a matter of firm policy, we do not vote proxies on behalf of clients. Therefore, clients maintain exclusive responsibility for directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. Clients are responsible for instructing each custodian of the assets to forward to the client copies of all proxies and shareholder communications relating to the client’s investment assets. Upon the client’s request, we may provide clients with consulting assistance regarding proxy issues if they contact us with questions at our principal place of business. 16  ITEM 18: FINANCIAL INFORMATION Registered investment advisers that maintain discretionary authority are required to disclose any financial condition that is reasonably likely to impair their ability to meet their contractual obligations. Bill Few Associates, Inc. has no financial circumstances to report that may impair our ability to meet our contractual obligations. Under no circumstances do we require or solicit payment of fees six months or more in advance of services rendered. Therefore, we are not required to include a financial statement. Bill Few Associates, Inc. has not been the subject of a bankruptcy petition at any time during the past ten years. 17  Schedule A Client Account Fees and Expenses 18  The following lists various fees and expenses that may be applicable to your Bill Few Associates, Inc. accounts. Certain fees may not apply or may be absorbed by Bill Few Associates, Inc. Other fees are only charged when the associated services are requested or when special processing is required. Description Fees Account Fees and Expenses (as of 1/1/2024): Description Fees Inactivity Fee (Retail Accounts Only) Asset Management Accounts (Resource Checking/ProCash/Corestone) Mutual Fund Only Waived Platinum Waived Mixed Account Waived Gold N/A Dividend Reinvestment 1.00 Silver Plus N/A Bond Redemption Notification Fee 1.00 Silver N/A Margin Extension 10.00 Corporate Gold N/A Corporate Platinum Waived Asset Management Accounts Reorganization Items: Voluntary Transfers Accommodation Transfers Register and Ship Certificate 20.00 60.00 25.00 Checking Fees: Safekeeping (per position per month) 2.00 Other Checking/Debit-related Fees Direct Registration (Transfer In) Waived Initial Personal Check Order Waived Direct Registration (Transfer Out) 10.00 Check Reorder 7.50 Legal, GNMA and Restricted Transfers 60.00 Initial Personal Check Order (Carbon Copy) 15.00 Check Reorder (Carbon Copy) 25.00 Business Checks 50.00 Business Style Reorder 40.00 Limited Partnership/Alternative Investments Subscription Fee Redemption Fee Reregistration Fee Annual Administration Fee (registered positions) Annual Administration (unregistered positions) 50.00 50.00 50.00 35.00 125.00 Business Style Check Binder 20.00 Overnight Check Reorder 20.00 Annual Retirement Plan Maintenance Fees Returned Checks or ACH Debits 25.00 Stop Payment Waived Waived Waived View Copy of Paid Check Online Waived Retrieve Copy of aid Checks 2.50 Waived Letter with Checking Account Information Waived Waived Debit Card Fees: ATM Withdrawal Fee (In-network and Out-of-network) Waived IRA, Roth IRA, SEP, Education Savings (Mutual Fund Only) IRA, Roth IRA, SEP, Education Savings (Mixed) Qualified Retirement Plan–SIMPLE, 403(b) (Mutual Fund Only) Qualified Retirement Plan – SIMPLE, 403(b) (Mixed) Individual and Simplified 401(k), Profit Sharing and Money Purchase Plan Flex 401(k), Profit Sharing/Money Purchase Plan Waived Waived ATM Surcharge Fee (charged by an ATM) Various ($10 maximum reimbursement per month) Cash Advance Fee (non-ATM) 0.25% of principal ($2.50 minimum) 2.50 Retrieve Copy of Paid Debit Card Draft Foreign Transaction Fee 1% of the transaction Paper Delivery Fee (if not enrolled in e-delivery) 2.00/month Trade Processing Ticket Charges and Commissions Stocks and ETFs ticket charges 1,2 Options ticket charges Bond ticket charges Mutual Fund ticket charges Commissions up to 2%; non-fee paying accts NTF Early Redemption Fee Waived Waived Waived Waived N/A 50.00 Paper Delivery Fee-Tax Documents (Fee is waived if these 10.00/year are sent via e-delivery or if you subscribe to Paper Delivery Fee) Interest Expenses on Margin Debits (Charge over Prime Base Lending Rate) 3 Varies Account Transfer 25.00 Interest Expense on Non Purpose Loans (Charge over Fed Fund Target Rate) 3 Varies Retirement and Education Account Termination Fee 75.00 Asset Movement Charges Certified Check Delivery 12.00 Returned Checks for Insufficient Funds (Deposits) 25.00 1The common stock and ETF ticket charges do not apply for foreign securities transactions. Instead, Pershing foreign execution, clearance and settlement service fees, which may also include a currency conversion spread and, in some cases, a foreign tax, are charged for all foreign stock transactions. Fees and expenses will vary depending on which country (market) the stock is being traded in. Returned Checks for Insufficient Funds (Checks Written) 25.00 2A transaction charge by the market exchanges will be assessed. Profit Sharing Loan Processing 50.00 Stop Payment 10.00 Overnight Check Delivery 12.00 Overnight Check Delivery (Overseas) 25.00 3The Pershing Base Lending and the Prime Lending rates are set with reference to recognized interest rates, industry conditions related to the extension of credit, and general credit market conditions. All interest over these rates is credited to Bill Few Associates, Inc. Overnight Check Delivery (Saturday) 18.00 Wire Fee 20.00 ACH Returns 20.00 19 

W R A P F E E P R O G R A M B R O C H U R E 2100 Georgetown Drive Suite 600 Sewickley, PA 15143 Telephone: 412-630-6000 Email: jjones@billfew.com www.billfew.com March 31, 2026 This wrap fee program brochure provides information about the qualifications and business practices of Bill Few Associates, Inc. If you have any questions about the contents of this brochure, please contact John Jones at 412-630-6000 or jjones@billfew.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. Bill Few Associates, Inc. is a registered investment advisor. Registration does not imply a certain level of skill or training. Additional information about Bill Few Associates, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The CRD for Bill Few Associates, Inc. is 133561. This BFA Wrap Fee Program Brochure and other important information relating to accounts with Bill Few Associates, Inc. can be found at www.billfew.com/bfa-disclosures.  ITEM 2: MATERIAL CHANGES The last annual update of the Form ADV Wrap Fee Program brochure was March 31, 2025. No material changes since last Form ADV update. Additional minor updates and clarifications occur throughout this document and we encourage you to read the entire Brochure. We may, at any time, update this Brochure. We will send you a copy or offer you a copy (either by electronic means or in hard copy form), as required by regulations. 2  TABLE OF CONTENTS 1 2 3 4 6 7 11 11 ITEM 1: COVER PAGE ITEM 2: MATERIAL CHANGES ITEM 3: TABLE OF CONTENTS ITEM 4: SERVICES, FEES AND COMPENSATION ITEM 5: ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ITEM 6: PORTFOLIO MANAGER SELECTION AND EVALUATION ITEM 7: CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ITEM 8: CLIENT CONTACT WITH PORTFOLIO MANAGERS ITEM 9: ADDITIONAL INFORMATION 11 3  ITEM 4: SERVICES, FEES AND COMPENSATION Services Bill Few Associates, Inc. (“BFA”) offers asset management services based on the individual needs of the client. This Brochure provides a description of the advisory services offered under the Bill Few Associates, Inc. Wrap Fee Program (“Program”). For more information about BFA’s other investment advisory services, please contact your advisor for a copy of a similar brochure that describes such services or go to www.adviserinfo.sec.gov. We offer portfolio management services through a wrap-fee program ("Program") as described in this wrap fee program brochure to prospective and existing clients. We are the sponsor and investment adviser for the Program. A wrap-fee program is a type of investment program that provides clients with asset management and brokerage services for one all-inclusive fee. If you participate in our wrap fee program, you will pay our firm a single fee, which includes investment management fees, certain transaction costs, custodial and administrative costs. You are not charged separate fees for the respective components of the total services. We receive the fee for our services and pay a portion of the fee to Pershing Advisor Solutions. The overall cost you will incur if you participate in our wrap fee program may be higher or lower than you might incur by separately purchasing the types of services available in the Program. Prior to becoming a client under the Program, you will be required to enter into a separate written agreement with us that sets forth the terms and conditions of the engagement and describes the scope of the services to be provided, and the fees to be paid. Through the BFA Wrap Fee Program, BFA provides ongoing investment advice and management on assets in the client’s account. BFA provides advice on the purchase and sale of various types of investments, such as mutual funds, exchange-traded funds (“ETFs”), equities, and fixed income securities. BFA provides advice that is tailored to the individual needs of the client based on the investment objective chosen by the client. Clients may impose restrictions on investing in certain securities or groups of securities by indicating in the written advisory agreement with BFA. We will use the information we gather to develop a strategy that enables our firm to customize an investment portfolio for you in accordance with your risk tolerance and investment objectives. Once we construct an investment portfolio for you, or select a model portfolio, we will monitor your portfolio's performance and re-balance your investments as required by changes in market conditions and in your financial circumstances. For more information regarding our investment advisory services, including individual portfolio management and mutual fund model portfolios, please review our Part 2A of Form ADV. BFA provides investment management services on both a discretionary and non-discretionary basis. Non- discretionary services require clients to initiate or pre-approve investment transactions in their accounts before they can occur, whereas “discretionary” services authorize BFA to buy, sell or hold investment positions without obtaining pre-approval from clients for each transaction. Clients choose if they want BFA to provide investment management services on a discretionary or non-discretionary basis. When clients choose discretionary management, BFA receives limited discretionary authority from the client to select the identity, timing and amount of securities to be bought or sold. Clients must provide written authorization to allow BFA discretionary authority. In all cases, this discretion is exercised in a manner consistent with the stated investment objectives for the particular client account. Assets for program accounts are held at Pershing LLC (“Pershing”), a broker-dealer and clearing firm that is registered with the U.S. Securities and Exchange Commission (“SEC”) and a member of the Financial Industry Regulatory Authority, Inc. (FINRA”). Pershing Advisor Solutions LLC (“PAS”) is the introducing broker-dealer. PAS is registered with the SEC and a member of FINRA. PAS provides brokerage services for program accounts and provides other administrative services as described throughout this Brochure. By selecting PAS as the broker-dealer, clients may be unable to achieve the most favorable execution of their transactions. Therefore, this practice may cost clients more money. Clients will be subject to separate fees and expenses charged by PAS. BFA receives support services from PAS, many of which assist BFA to better monitor and service program accounts maintained at PAS; however, some of the services and products benefit BFA and not client accounts. If you choose PAS as the broker-dealer, you cannot request that your orders be executed through a different broker-dealer. Clients should understand that not all advisors require their clients to select a certain broker-dealer. 4  Fees In the BFA Wrap Fee Program, clients pay BFA a single advisory fee for advisory services and execution of transactions. Clients do not pay brokerage commissions, mark-ups or transaction charges for execution of transactions in addition to the advisory fee. The amount of the advisory fee will be disclosed prior to services being provided and agreed upon in the appropriate written investment advisory agreement. Our advisory fees are a percentage based on the value of all assets in the account, including cash holdings, and generally range from .25% to 1.25%. Our Standard Fee Schedule is a tiered schedule and is billed as follows: Tier First Next Next Above Asset Level $ 500,000 500,000 500,000 1,500,000 Annual Rate 1.25% 1.00% .75% .50% The advisory fee is negotiable between the client and BFA as outlined in the advisory agreement. The advisory fee may be higher than the fee charged by other investment advisors for similar services. The advisory fee is paid to BFA. BFA does not accept performance-based fees for program accounts. Generally, advisory fees are billed quarterly in advance and calculated based on the account’s market value on the last business day of the prior quarter. Fees for new accounts, and for new deposits into existing accounts, will be pro- rated based on the remaining number of days left in the quarter. Fees are debited from the client’s account unless the client requests to be billed directly. For clients requesting to be billed directly, an invoice will be sent to the client detailing the advisory fees for the upcoming quarter. Accounts within the same household, and set to the same tiered fee schedule, can be combined for breakpoint purposes. For advisory accounts in which the management fee is deducted from the account, BFA calculates the advisory fee and provides PAS with instructions for the fee amount that is to be deducted. On at least a quarterly basis, the custodian is required to send to the client a statement showing all transactions within the account during the reporting period, including the fee amount. If the advisory agreement is terminated before the end of the period, client is entitled to a pro-rated refund of any pre-paid advisory fee based on the number of days remaining in the billing period after the termination date. Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review their custodial or account statements to verify the accuracy of the calculation, among other things. Clients should contact us directly if they believe that there may be an error in their statement. Wrap Fee Program Transaction Charges Disclosure BFA has agreed to pay an asset-based fee to PAS for certain brokerage services including clearing, execution and other fees. The monthly asset-based fee is tiered and decreases as client assets increase. Therefore, BFA is incentivized to increase client assets. Other Types of Fees and Charges Program accounts will incur additional fees and charges from parties other than BFA as noted below. These fees and charges are in addition to the advisory fee paid to BFA. BFA does not share in any portion of these third-party fees. PAS, as the introducing broker-dealer providing brokerage services to program accounts, will impose certain fees and charges that are not part of the bundled platform fee. BFA notifies clients of these charges at account opening. PAS will deduct these fees and charges, as applicable, directly from the client’s program account. There are other fees and charges that are imposed by other third parties that apply to investments in program accounts. Some of these fees and charges are described below. 5  • If a client’s assets are invested in mutual funds or other pooled investment products, clients should be aware that there will be two layers of advisory fees and expenses for those assets. Client will pay an advisory fee to the fund manager and other expenses as a shareholder of the fund. Client will also pay BFA the advisory fee with respect to those assets. Most of the mutual funds available in the program may be purchased directly. Therefore, clients could generally avoid the second layer of fees by not using the management services of BFA and by making their own investment decisions. • Certain mutual funds impose fees and charges such as contingent deferred sales charges, early redemption fees and charges for frequent trading. These charges may apply if a client transfers into or purchases such a fund with the applicable charges in a program account. • Although BFA requires that no-load and load-waived mutual funds be purchased in a program account when available, client should understand that some mutual funds pay asset-based sales charges or service fees (e.g., 12b-1 fees) to the custodian with respect to account holdings. BFA does not receive 12b-1 fees or commissions. Further information regarding fees assessed by mutual funds and other securities is available in the appropriate prospectus, which is available upon request from BFA or from the product sponsor directly. Other Important Considerations • The advisory fee is an ongoing wrap fee for investment advisory services, the execution of transactions and other administrative and custodial services. The advisory fee may cost the client more or less than purchasing similar services separately, for example, paying an advisory fee plus commissions for each transaction in the account. BFA does not offer these services separately. Factors that bear upon the cost of the account in relation to the cost of the same services purchased separately include the type and size of the account, historical and or expected size or number of trades for the account, and number and range of supplementary advisory and client-related services provided to the client. • The advisory fee also may cost the client more than if assets were held in a traditional brokerage account. In a brokerage account, a client is charged a commission for each transaction, and the representative has no duty to provide ongoing advice with respect to the account. If the client plans to follow a buy and hold strategy for the account or does not wish to purchase ongoing investment advice or management services, the client should consider opening a brokerage account rather than a program account. • The Advisor recommending the program to the client receives compensation as a result of the client’s participation in the program. This compensation includes a portion of the advisory fee and also may include other compensation, such as salary, bonuses, awards or other things of value offered by BFA to its associated persons. • The investment products available to be purchased in the program can be purchased by clients outside of a program account, through broker-dealers or other investment firms not affiliated with BFA. ITEM 5: ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS There are no minimum account values for Advisor Directed accounts within the BFA Wrap Fee Program, however certain investment styles do have account minimums. Generally, a minimum of $250,000 of assets under management is required for portfolios comprised mainly of individual equities or individual bonds. The minimum account size for portfolios predominantly comprised of mutual funds is $50,000. The account size may be negotiable under certain circumstances. Bill Few Associates, Inc. may group certain related client accounts for the purposes of achieving the minimum account size and determining the annualized fee. The program is available for individuals, IRAs, banks and thrift institutions, pension and profit-sharing plans, trusts, estates, charitable organizations, state and municipal government entities, corporations and other business entities. 6  ITEM 6: PORTFOLIO MANAGER SELECTION AND EVALUATION In the BFA Wrap Fee Program, BFA is the wrap program portfolio manager. BFA, through its associated persons, is responsible for the investment advice and management offered to clients. BFA requires that individuals involved in determining or giving investment advice have sufficient training and experience to provide such advice, including the successful completion of industry exams and certifications. For more information about the associated person of BFA managing the account, clients should refer to the Brochure Supplement for the associated person, which clients should have received along with this Brochure at the time the account was opened. Methods of Analysis and Investment Strategies We use the following methods of analysis in formulating our investment advice and/or managing client assets: Fundamental Analysis: We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Qualitative Analysis: We subjectively evaluate non-quantifiable factors such as quality of management, labor relations, and strength of research and development factors not readily subject to measurement and predict changes to share price based on that data. A risk in using qualitative analysis is that our subjective judgment may prove to be incorrect. Asset Allocation: Rather than focusing primarily on securities selection, we attempt to identify an appropriate ratio of equities, fixed income, and cash suitable to the client’s investment goals and risk tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the ratio of securities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the client’s goals. Mutual Fund and/or ETF Analysis: We look at the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap in the underlying investments held in other fund(s) in the client’s portfolio. We also monitor the funds or ETFs in an attempt to determine if they are continuing to follow their stated investment strategy. We review and monitor the performance of managers we select. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the client’s portfolio. Risks for all forms of analysis: Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. INVESTMENT STRATEGIES We use the following strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: 7  Long-term purchases: We purchase securities with the intention of holding them in the client's account for a year or longer. Typically, we employ this strategy when we believe the securities to be currently undervalued, and/or we want exposure to a particular asset class over time, regardless of the current projection for this class. A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantage of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Short-term purchases: When utilizing this strategy, we purchase securities with the intention of selling them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities we purchase. A short-term purchase strategy poses risks should the anticipated price swing not materialize; we are then left with the option of having a long-term investment in a security that was designed to be a short-term purchase, or potentially taking a loss. In addition, this strategy involves more frequent trading than does a longer-term strategy, and will result in less favorable tax treatment of short-term capital gains. Margin transactions: With prior client consent, we will purchase stocks for your portfolio with money borrowed from your brokerage account. This allows you to purchase more stock than you would be able to with your available cash and allows us to purchase stock without selling other holdings. Managing accounts on Margin is only done with prior client consent and authorization and represents a limited number of accounts under active management. Option writing: With prior client consent, we may use options as an investment strategy. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a specific price on or before a certain date. An option, just like a stock or bond, is a security. An option is also a derivative because it derives its value from an underlying asset. The use of Option writing is only done with prior client consent and authorization and represents a limited number of accounts under active management. The two types of options are calls and puts: A call gives us the right to buy an asset at a certain price within a specific period of time. We will buy a call if we anticipate the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. We will buy a put if we anticipate the price of the stock will fall before the option expires. We will use options to speculate on the possibility of a sharp price swing. We will also use options to "hedge" a purchase of the underlying security; in other words, we will use an option purchase to limit the potential upside and downside of a security we have purchased for your portfolio. We use "covered calls", in which we sell an option on a security you own. In this strategy, you receive a fee for making the option available, and the person purchasing the option has the right to buy the security from you at an agreed-upon price. We use a "spreading strategy", in which we purchase two or more option contracts (for example, a call option that you buy and a call option that you sell) for the same underlying security. This effectively puts you on both sides of the market, but with the ability to vary price, time and other factors. Risk of Loss: Securities investments are not guaranteed, and you may lose money on your investments. Clients should understand that investing in any securities, including mutual funds, involves a risk of loss of both income and principal. We ask that you work with us to help us understand your tolerance for risk. Types of Investments and Risks Depending on the type of service being provided, BFA can recommend different types of securities, including mutual funds, closed end funds, ETFs, equities, fixed income securities, options. Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some risks associated with investing and with some types of investments that BFA can recommend depending on the service provided. 8  Market Risk. This is the risk that the value of securities owned by an investor may go up or down, sometimes rapidly or unpredictably, due to factors affecting securities markets generally or particular industries. Interest Rate Risk. This is the risk that fixed income securities will decline in value because of an increase in interest rates; a bond or a fixed income fund with a longer duration will be more sensitive to changes in interest rates than a bond or bond fund with a shorter duration. Credit Risk. This is the risk that an investor could lose money if the issuer or guarantor of a fixed income security is unable or unwilling to meet its financial obligations. Issuer‐Specific Risk. This is the risk that the value of an individual security or particular type of security can be more volatile than the market as a whole and can perform differently from the value of the market as a whole. Investment Company Risk. To the extent a client account invests in ETFs or other investment companies, its performance will be affected by the performance of the investment managers and the underlying portfolio holdings. Investments in ETFs and other investment companies are subject to the risks of the investment companies’ investments, as well as to the investment companies’ expenses. If a client account invests in other investment companies, the client account may receive distributions of taxable gains from portfolio transactions by that investment company and may recognize taxable gains from transactions in shares of that investment company, which would be taxable when distributed. Equity Investment Risk. Our judgments about the attractiveness, value and potential appreciation of a particular individual security may be incorrect and there is no guarantee that individual securities will perform as anticipated. Sharp downward market moves may adversely impact long positions. Losses may also be incurred on individual positions as a result of issuer-specific matters such as unexpectedly disappointing earnings, lawsuits, analyst action or other matters. Equity returns are volatile and may fluctuate substantially over time. Bond Risk. Rising interest rates will generally cause the prices of bonds and other debt securities to fall. In addition, falling interest rates may cause an issuer to redeem, call or refinance a security before its stated maturity, which may result in the fund having to reinvest the proceeds in lower yielding securities. Longer maturity debt securities may be subject to greater price fluctuations than shorter maturity debt securities. Bonds and other debt securities are subject to credit risk, which is the possibility that the credit strength of an issuer will weaken and/or an issuer of a debt security will fail to make timely payments of principal or interest and the security will go into default. Lower quality debt securities generally have higher rates of interest and may be subject to greater price fluctuations than higher quality debt securities. Concentration Risk. To the extent a client account concentrates its investments by investing a significant portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if they did not concentrate their investments to such an extent. Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub‐sectors of the market, its performance will be especially sensitive to developments that significantly affect those sectors, industries, or sub‐sectors. An individual sector, industry, or sub‐sector of the market may be more volatile, and may perform differently, than the broader market. The several industries that constitute a sector may all react in the same way to economic, political or regulatory events. A client account’s performance could be affected if the sectors, industries, or sub‐sectors do not perform as expected. Alternatively, the lack of exposure to one or more sectors or industries may adversely affect performance. Alternative Strategy Mutual Funds. Certain mutual funds invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be suitable for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes and potential illiquidity. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real 9  estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. These types of funds tend to have higher expense ratios than more traditional mutual funds. They also tend to be newer and have less of a track record or performance history. Closed-End/Interval Funds. Clients should be aware that closed-end funds available within the program may not give investors the right to redeem their shares, and a secondary market may not exist. Therefore, clients may be unable to liquidate all or a portion of their shares in these types of funds. While the fund may from time to time offer to repurchase shares, it is not obligated to do so (unless it has been structured as an "interval fund"). In the case of interval funds, the fund will provide limited liquidity to shareholders by offering to repurchase a limited amount of shares on a periodic basis, but there is no guarantee that clients will be able to sell all of the shares in any particular repurchase offer. The repurchase offer program may be suspended under certain circumstances. Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally classified as open- end mutual funds or UITs. However, they differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as an investment company under the Investment Company Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities, are not registered as an investment company. ETFs may be closed and liquidated at the discretion of the issuing company. Leveraged and Inverse Funds/ETF Risks: Bill Few Associates, Inc. does not recommend Leveraged and Inverse Funds/ETFs. However, clients may direct us to purchase or hold these investments in their accounts. While Leveraged and Inverse ETFs offer potential for amplified returns, they also carry significant risks. There is the possibility of significant losses in short periods of time including the risk that you could lose most or all of your investment, especially in volatile markets. These funds generally have a daily investment objective and are not designed to track their benchmark for longer periods of time. The effects of volatility and compounding could cause their returns to diverge materially from the benchmark when held longer than a single trading day. Investors should review the investment prospectus and principal risks described therein prior to investing. Penny Stock Risks: Penny stocks are low-priced shares of small companies. Bill Few Associates, Inc. does not recommend investing in Penny stocks. However, clients may direct us to purchase or hold these investments in their accounts. Penny stocks may trade infrequently, which means that it may be difficult to sell penny stock shares. Because it may be difficult to find quotations for penny stocks, they may be impossible to accurately price. Penny stocks generally have lower liquidity, are subject to volatile price fluctuations and often have large bid/ask spreads. Penny stocks are considered speculative investments and investors may lose some or all of their investment. Market Disruptions and other Impacts of Force Majeure Events: Financial markets may be impacted by the outbreak of a contagious disease, a terrorist act or threat, acts of war or severe weather incidents. An outbreak of a contagious disease with the potential to become a pandemic, or the measure taken by the governments of affected countries against such potential outbreaks, could seriously disrupt financial markets, which could have an adverse effect on investment performance. The spread of such disease can quickly and negatively impact business operations, supply chains, business and leisure travel, stores, restaurants, sports events and other venues. These sudden changes in business and consumer behaviors can cause instability in the world financial markets and may generate localized or even global economic instability. The outbreak of a contagious disease, a terrorist act or threat, acts of war or severe weather incidents can lead to increased volatility in investments securities. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. Investing in securities involves the risk of loss that clients should be prepared to bear. 10  Voting Client Securities As a matter of firm policy, we do not vote proxies on behalf of clients. Therefore, clients maintain exclusive responsibility for directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. Clients will receive proxies or other solicitations directly from Pershing or a transfer agent. Clients are responsible for instructing Pershing to forward to the client copies of all proxies and shareholder communications relating to the client’s investment assets. Upon the client’s request, we may provide clients with consulting assistance regarding proxy issues if they contact us with questions at our principal place of business. ITEM 7: CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS In the BFA Wrap Fee Program, Bill Few Associates and/or our Advisors are responsible for account management; there is no separate portfolio manager involved. The Advisor obtains the necessary financial data from the client and assists the client in setting an appropriate investment objective for the account. The Advisor obtains this information by having the client complete an advisory agreement and other documentation. Clients are encouraged to contact their Advisor if there have been any changes in the client’s financial situation or investment objectives or if they wish to impose any reasonable restrictions on the management of the account or reasonably modify existing restrictions. ITEM 8: CLIENT CONTACT WITH PORTFOLIO MANAGERS Client should contact their Advisor at any time with questions regarding program accounts. No restrictions are placed on a client’s ability to contact or consult with Bill Few Associates. ITEM 9: ADDITIONAL INFORMATION Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that may be material to your evaluation of a firm or the integrity of its management. In 2018, BFA elected to participate in the Securities and Exchange Commission’s Mutual Fund Share Class Selection Disclosure Initiative (“SCSD Initiative”). The SCSD Initiative provided investment advisers with the opportunity to voluntarily self-report to the SEC’s Division of Enforcement possible inadequacies with their disclosures concerning mutual fund share class selection and the fees pursuant to Rule 12b-1 under the Investment Company Act of 1940. As part of the SCSD Initiative, BFA reviewed their disclosures and activities related to mutual fund share class selection. At the conclusion of the SCSD Initiative, BFA consented to a settlement agreement to reimburse accounts the amount of 12b-1 fees received ($2,201,454.07) along with prejudgment interest ($191,850.74). The SEC did not impose a fine or civil monetary penalty in recognition of the fact that BFA self-reported. Other Financial Industry Activities and Affiliations Certain investment personnel of our firm are also agents for various insurance companies. As such, these individuals are able to receive separate, yet customary commission compensation resulting from implementing product transactions on behalf of advisory clients. Clients, however, are not under any obligation to engage these individuals when considering implementation of advisory recommendations. The implementation of any or all recommendations is solely at the discretion of the client. While BFA and these individuals endeavor at all times to put the interest of the clients first as part of our fiduciary duty, clients should be aware that the receipt of additional compensation itself creates a conflict of interest and may affect the judgment of these individuals when making recommendations. The following procedures are employed to address this conflict: We disclose to clients the existence of all material conflicts of interest, including the potential for our firm and our employees to earn compensation from advisory clients in addition to our firm's advisory fees. 11  We disclose to clients that they are not obligated to purchase recommended investment products from our employees or affiliated companies. We collect, maintain and document accurate, complete and relevant client background information, including the client’s financial goals, objectives and risk tolerance. Our firm's management conducts regular reviews of each client account to verify that all recommendations made to a client are suitable to the client’s needs and circumstances. We require that our employees seek prior approval of any outside employment activity so that we may ensure that any conflicts of interest in such activities are properly addressed. We periodically monitor these outside employment activities to verify that any conflicts of interest continue to be properly addressed by our firm. We educate our employees regarding the responsibilities of a fiduciary, including the need for having a reasonable and independent basis for the investment advice provided to clients. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that we require of our employees, including compliance with applicable federal securities laws. BFA and our personnel owe a duty of loyalty, fairness and good faith towards our clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code. Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions reports as well as initial and annual securities holdings reports that must be submitted by the firm’s access persons. Among other things, our Code of Ethics also requires the prior approval of any acquisition of securities in a limited offering (e.g., private placement) or an initial public offering. Our code also provides for oversight, enforcement and recordkeeping provisions. BFA 's Code of Ethics further includes the firm's policy prohibiting the use of material non-public information. While we do not believe that we have any particular access to non-public information, all employees are reminded that such information may not be used in a personal or professional capacity. A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by email sent to jjones@billfew.com or by calling us at 412-630-6000. BFA and individuals associated with our firm are prohibited from engaging in principal transactions. Our Code of Ethics is designed to assure that the personal securities transactions, outside business activities and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Our firm and/or individuals associated with our firm may buy or sell for their personal accounts securities identical to or different from those recommended to our clients. In addition, any related person may have an interest or position in a certain securities which may also be recommended to a client. Review of Accounts INDIVIDUAL PORTFOLIO MANAGEMENT Reviews: While the underlying securities within Individual Portfolio Management Services accounts are monitored, these accounts are reviewed at least annually. Accounts are reviewed in the context of each client's stated investment objectives and guidelines. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, or market, political or economic environment. These accounts are reviewed by BFA financial analysts and/or the financial professional for each account. Reports: In addition to the statements and confirmations of transactions that clients receive from Pershing, we provide reports summarizing account performance, balances and holdings during regular review meetings with clients. 12  Portfolio performance information provided to clients is calculated by third party software using industry standards. Performance information provided by the underlying manager has not been independently verified by us and we cannot guarantee its accuracy. These reports will also remind the client to notify us if there have been changes in the client's financial situation or investment objectives and whether the client wishes to impose investment restrictions or modify existing restrictions. MUTUAL FUND MODEL PORTFOLIO MANAGEMENT Reviews: While the underlying securities within the Mutual Fund Model Portfolio Management accounts are continually monitored, these accounts are reviewed at least annually. Accounts are reviewed in the context of the investment objectives and guidelines of each model portfolio as well as any investment restrictions provided by the client. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic environment. These accounts are reviewed by BFA financial analysts and/or the financial professional for each account. Reports: In addition to the statements and confirmations of transactions that clients receive from Pershing, we may provide reports summarizing account performance, balances and holdings during regular review meetings with clients. Portfolio performance information provided to clients is calculated by third party software using industry standards. Performance information provided by the underlying manager has not been independently verified by us and we cannot guarantee its accuracy. These reports will also remind the client to notify us if there have been changes in the client's financial situation or investment objectives and whether the client wishes to impose investment restrictions or modify existing restrictions. Client Referrals and Other Compensation It is BFA 's policy not to accept or allow our related persons to accept any form of compensation, including cash, sales awards or other prizes, from a non-client in conjunction with the advisory services we provide to our clients. We believe these practices would create an unacceptable conflict of interest. Bill Few Associates, Inc. does not compensate any third party for client referrals. Financial Information Registered investment advisers that maintain discretionary authority are required to disclose any financial condition that is reasonably likely to impair their ability to meet their contractual obligations. Bill Few Associates, Inc. has no financial circumstances to report that may impair our ability to meet our contractual obligations. Under no circumstances do we require or solicit payment of fees six months or more in advance of services rendered. Therefore, we are not required to include a financial statement. Bill Few Associates, Inc. has not been the subject of a bankruptcy petition at any time during the past ten years. 13