ADV PART 2A

Item 1: Cover Page 124 Simsbury Rd. Bldg 1 Ste 202, Avon, CT 06001 Secondary Office 25 Kent Ave. Suite 401, Brooklyn, NY 11249 (646) 907-9424 Form ADV Part 2A – Firm Brochure Dated: October 8, 2026 This Brochure provides information about the qualifications and business practices of Telos Partners LLC. If you have any questions about the contents of this Brochure, please contact us at (646)907-9424. 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. Telos Partners LLC is a registered investment adviser. Registration does not imply a certain level of skill or training. information about Telos Partners LLC also is available on the SEC’s website at Additional www.adviserinfo.sec.gov, which can be found using the firm’s identification number, 340922. 1  Item 2: Material Changes Since becoming registered on April 29, 2026, the following changes have occurred: ● Item 5 has been updated to reflect the firm’s assets under management as of June 23, 2026. ● Item 5: EI has amended the fee structure for its Investment Management services. ● Interactive Brokers has been added as a custodian in Item 12. ● Fidelity has been added as a custodian in Item 12. ● Peter Hughes and Christopher Stevenson have revised outside business activities; Item 10 has been amended. In the future, any material changes made during the year will be reported here. 2  Item 3: Table of Contents 1 Item 1: Cover Page 2 Item 2: Material Changes 3 Item 3: Table of Contents 4 Item 4: Advisory Business 10 Item 5: Fees and Compensation 14 Item 6: Performance-Based Fees and Side-By-Side Management 14 Item 7: Types of Clients 14 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss 19 Item 9: Disciplinary Information Item 10: Other Financial Industry Activities and Affiliations 20 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 20 22 Item 12: Brokerage Practices 25 Item 13: Review of Accounts 25 Item 14: Client Referrals and Other Compensation 25 Item 15: Custody 26 Item 16: Investment Discretion 27 Item 17: Voting Client Securities 27 Item 18: Financial Information 3  Item 4: Advisory Business Description of Advisory Firm Telos Partners LLC, a limited liability company domiciled in the State of Connecticut, became registered as an investment adviser in 2026 and is directly owned by Forrest Financial Partners LLC and Evolve Investing LLC. Peter Hughes, principal and Chief Compliance Officer (“CCO”), is the sole owner of Evolve Investing LLC. Christopher Stevenson, principal, is the sole owner of Forrest Financial Partners LLC. As used in this brochure, the words “Telos”, "we", "our firm", “Advisor” and "us" refer to Telos Partners LLC and the words "you", "your" and "Client" refer to you as either a client or prospective client of our firm. Types of Advisory Services Description of Services Telos provides ongoing and continuous supervision of clients’ investments through our portfolio management services; however, we do not sponsor or serve as portfolio manager involving wrapped (“bundled”) fee investment programs. Our firm provides financial planning, offering advice to our clients on key topics such as charitable giving strategies, cash flow and budgeting, funding a college education, retirement, among others. Our services are described in this Advisory Business section (Item 4), and our fee schedule can be found in Item 5. An initial interview with the prospective client is conducted to discuss their current situation, long-term goals, and the scope of services that may be provided by our firm. Prior to or during this first meeting the client will be provided with this Form ADV Part 2 firm brochure as well as a statement involving the firm’s privacy policy, as well as a brochure supplement about the client’s representative. Any material conflicts of interest will be disclosed involving the firm and its associates that could be reasonably expected to impair the rendering of unbiased and objective advice, such as information found in Items 10 through 12 of this firm brochure. If the prospective client wishes to engage our firm for its services, we must first enter into a written agreement. Thereafter, further discussion and analysis will be conducted to determine financial needs, goals, holdings, etc. Depending on the scope of the engagement, the client may be asked to provide copies of the following documents early in the process: ● wills, codicils, and trusts ● insurance policies, including information about riders, loans, and amendments ● mortgage information ● tax returns ● student loans ● divorce decree or separation agreement ● current financial specifics including W-2s, 1099s, K-1 statements, etc. ● information on current retirement plans and other benefits provided by an employer ● statements reflecting current investments in retirement and non-retirement accounts ● employment or other business agreements, and ● completed risk profile questionnaires or other forms provided by our firm. 4  It is important that we are provided with an adequate level of information and supporting documentation throughout the term of the engagement including but not limited to source of funds, income levels, and an account holder or attorney-in-fact’s authority to act on behalf of the account, among other information that may be necessary for our services. The information and/or financial statements provided to us need to be accurate. Our firm may, but is not obligated to, verify the information that has been provided to us which will then be used in the advisory process. Investment Management Services Telos offers multiple proprietary investment strategies. During the onboarding process, we use questionnaires to learn about our Client’s personal values and unique financial situation. From there, we create investment strategies and policies that will be executed by Telos on behalf of the Client. Telos takes into account each client’s goals and preferences with respect to capital appreciation, risk tolerance, income needs, tax considerations, and time horizon. These factors serve as inputs for Telos to develop asset allocation targets and guidelines for each Client. Our investment strategies are best characterized as long-term, growth-oriented strategies. We select individual stocks, bonds, and in some cases mutual funds or ETFs. For each client, we determine the appropriate strategy or blend of strategies based on individual values, needs and objectives. For each client, we design, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Portfolios are typically constructed on a household basis and in some cases include multiple accounts. Each Client has the right to place restrictions on individual stocks, subject to acceptance by Telos. Additional information around client-imposed restrictions is disclosed later in this item, below. Although our strategies are long-term in nature, we may engage in short-term trading to harvest capital gains or losses, or if necessary, rebalance the portfolio based upon the client’s individual needs, stated goals and objectives. In some cases, Telos may retain certain legacy investments based on portfolio fit and/or tax considerations. For certain clients, we offer value-aligned, impact, and environmental, social, & governance (ESG) investing. Across our strategies, Telos seeks to integrate thematic impact opportunities -- to invest in solutions that combat climate change, create more equitable outcomes, and improve the health of all beings, among other impact-oriented causes, and where those investments fit with each Client’s financial goals and risk tolerance. Telos uses ESG screening tools that take into account both quantitative and qualitative factors, and our impact portfolios may seek to limit or restrict investments into certain companies or industries, including: ● Manufacturers of tobacco, alcohol and gambling products ● Producers of guns and/or major weapons systems (conventional or nuclear) ● The fossil fuel industry: oil, gas and coal producers and/or fossil-fuel powered utilities ● Producers of nuclear power ● Private prisons/correctional institutions ● Entities with poor track records on treatment of the environment, e.g., heavy pollution to air/water/land, toxic emissions, outsized carbon footprint ● Entities with poor track records on treatment of women, minorities, workers, communities and/or human rights 5  When we provide investment management services, Clients grant us limited authority to buy and sell securities on a discretionary basis. More information on our trading authority is explained in Item 16 of this Brochure. Clients may impose reasonable restrictions in writing on investing in certain securities, types of securities, or industry sectors. When appropriate, we utilize the services of one or more independent investment managers or independent investment management programs (“Outside Managers”) to assist with the management of Client accounts. The Outside Managers we recommend may engage our firm directly to provide sub-advisory services to client account(s) and/or may be accessible to our firm through an investment platform offered through your Custodian. We will continue to serve as Client’s primary advisor for the ongoing monitoring of the account(s) and the determination of the suitability of the Outside Manager’s overall investment program and/or strategies. We will recommend adjustments to your account(s) when we believe such changes are in your best interests. Our review process and analysis of Outside Managers is further discussed in Item 8 of this Brochure. Financial Planning Services Financial planning involves an 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. The key defining aspect of financial planning is that through the financial planning process, all questions, information, and analysis will be considered as they affect and are affected by the entire financial and life situation of the Client. Clients purchasing this service will receive a written report, providing the Client with a detailed financial plan designed to help achieve the Client’s stated financial goals and objectives. In general, the financial plan will address some or all of the following areas of concern. The Client and Telos will work together to select specific areas to cover. These areas may include, but are not limited to, the following: ● Business Planning: We provide consulting services for clients who currently operate their own business, are considering starting a business, or are planning for an exit from their current business. Under this type of engagement, we work with you to assess your current situation, identify your objectives, and develop a plan aimed at achieving your goals. We are available to assist businesses in a variety of ways including financial planning & analysis, strategic consulting, budgeting, forecasting, employee retention and retirement strategies, as well as coordination with financial institutions, corporate attorneys, or an accounting firm. We serve as a limited plan fiduciary per §3(21) of the Employee Retirement Income Security Act of 1974 (ERISA), but we do not act as the plan adviser or investment manager as defined in ERISA §3(38), nor do we serve as ERISA §3(16) plan third-party administrator. ● Cash Flow and Debt Management: We will conduct a review of your income and expenses to determine your current surplus or deficit along with advice on prioritizing how any surplus should be used or how to reduce expenses if they exceed your income. Advice may also be provided on which debts to pay off first based on factors such as the interest rate of the debt and any income tax ramifications. We may also recommend what we believe to be an appropriate cash reserve that should be considered for emergencies and other financial goals, along with a review of accounts (such as to save desired amounts. money market funds) for such reserves, plus strategies 6  ● Education Planning: Advice may include projecting the amount that will be needed to achieve post- secondary education funding goals, along with savings strategies and the “pros-and-cons” of various college savings vehicles that are available. We are also available to review a client’s financial picture as it relates to eligibility for financial aid or the best way to contribute to other family members. ● Investment Analysis: This may involve developing an asset allocation strategy to meet Clients’ financial goals and risk tolerance, providing information on investment vehicles and strategies, reviewing employee stock options, as well as assisting you in establishing your own investment account at a selected broker/dealer or custodian. The strategies and types of investments we may recommend are further discussed in Item 8 of this brochure. ● Retirement Planning: Our retirement planning services typically include projections of your likelihood of achieving your financial goals, typically focusing on financial independence as the primary objective. For situations where projections show less than the desired results, we may make recommendations, including those that may impact the original projections by adjusting certain variables (e.g., working longer, saving more, spending less, taking more risk with investments). If you are near retirement or already retired, advice may be given on appropriate distribution strategies to minimize the likelihood of running out of money or having to adversely alter spending years. during your retirement ● Risk Management: A risk management review includes an analysis of your exposure to major risks that could have a significant adverse impact on your financial picture, such as premature death, disability, property and casualty losses, or the need for long-term care planning. Advice may be provided on ways to minimize such risks and about weighing the costs of purchasing insurance versus the benefits of doing so and, likewise, the potential cost of not purchasing insurance (“self-insuring”). ● Tax Planning Strategies: Advice may include ways to minimize current and future income taxes as a part of your overall financial planning picture. For example, we may make recommendations on which type of account(s) or specific investments should be owned based in part on their “tax efficiency,” with the consideration that there is always a possibility of future changes to federal, state or local tax laws and rates that may impact your situation. We recommend that you consult with a qualified tax professional before initiating any tax planning strategy, and we may provide you with contact information for accountants or attorneys who specialize in this area if you wish to hire someone for such purposes. We will participate in meetings or phone calls between you and your tax professional with your approval. Financial Planning Services are offered on a Project-Based and/or via an Ongoing engagement. Ongoing Comprehensive Financial Planning Upon engaging Telos for this service, the financial plan development process will begin with helping the Client to establish their goals and values around money in addition to gathering important information that will contribute to the areas of focus within the plan. The Client will need to provide current and accurate information to help complete the following areas of analysis that may be 7  adjusted based on their needs and objectives: net worth, cash flow, credit scores/reports, employee benefit, retirement planning, investments, college planning, and estate planning. Once the Client's information is reviewed, their plan will be built and analyzed, and then the findings, analysis and potential changes to their current situation will be reviewed with the Client. Clients engaging in this service will receive a personalized report, providing the Client with a detailed financial plan designed to guide the client in achieving his or her stated financial goals and objectives. Once the plan has been delivered, an annual service calendar will be established that sets expectations for support around the implementation of key components of the plan. This calendar will establish time frames for periodic meetings, follow-ups, and check-ins for Telos to assist the Client with the implementation of the plan. The calendar will be a guiding document that can be adjusted as the client’s needs and priorities evolve but will detail out the key tasks to be addressed by the client and/ or Telos during the year such as asset allocation reviews, rebalancing, tax loss harvesting and other investment related tax strategy reviews, budgeting and cash flow reviews, retirement planning projections and reviews, student loan analysis and reviews, as well any other key meetings, projects, or tasks that Telos and the Client determine are necessary. In addition to those periodic events, the full plan will be reviewed semi-annually with the client and adjusted as needed based on changes in their financial situation and objectives. Each year, typically during every other semi-annual review, the Client and Telos will re-evaluate and agree to the services and fees laid out for the next calendar year. A new agreement or an addendum to the original agreement will be signed acknowledging the services to be provided and the fees to be charged for the next year. Project-Based Financial Planning We provide project-based financial planning engagements on various individual topics such as retirement planning, risk management, college savings, cash flow, debt management, work benefits, and estate and incapacity planning. This service is available for Clients who have very specific financial planning needs who are looking to work with a financial planner on a limited-scope project rather than through an ongoing comprehensive financial planning arrangement. These engagements can vary in length but generally conclude upon the delivery of the Client’s financial plan or after an agreed upon number of meetings of hours. Clients engaging in this service will receive a personalized financial plan that is specific to the topics or areas of focus that the Client is requesting support on. In general, the financial plan will address any or all of the following areas of concern based on the needs and objectives of the Client. At the start of the engagement, the Client and Telos will work together to determine the specific areas to cover. Family Office Consulting For certain clients we offer family office consulting. This bespoke service goes deeper than our Ongoing Comprehensive Financial Planning and Investment Management with Telos functioning as your family’s Chief 8  Financial Officer, ensuring that your finances are structured to align with your values and provide the foundation for a life well-lived. As your Family Office Consultant, Telos will serve as your main point of contact for nearly every facet of your financial life. We coordinate directly on your behalf with your suite of professionals, including estate attorneys, trust administrators, accountants, business managers, insurance advisors, and specialized asset managers, among others. This service includes analysis of potential and existing investments in early-stage companies; venture or private equity funds; private credit funds; and other alternative investments. We provide due diligence of investments into individual companies including calls with company managers and analysis of financial projections. For private funds, we review the fund's investment strategy and background, analyze its portfolio, and evaluate the investment thesis. We also serve as the point of contact for any fund investments, manage liquidity for capital calls, and provide back-office support for direct investments. Each engagement is structured in collaboration with the client family to ensure that it addresses their unique needs. Additional services include: ● Concentrated holdings strategy ● Family governance and education ● Non-profit Board guidance ● Professional services coordination ● Financial planning support for heirs ● Alternative investment analysis ● Comprehensive risk management ● Tangible asset advisory Hourly Consulting Service We provide hourly consulting services for businesses, individuals, and family offices. Our services include: Financial Planning Services. This one-time or ad-hoc service is designed for clients requiring supplemental assistance, incidental advice, or an abbreviated review. Topics addressed are chosen by the client and may include any of the areas listed above. Early-stage Investments. Analysis of individual securities, angel or private equity investments for individuals or business entities including family offices. We also offer analysis of potential and existing investments in early-stage or other venture or private equity funds. Services offered include due diligence, reviewing the fund's investment strategy and background, and analyzing its portfolio. Telos will also serve as the point of contact for any fund investments. Business Valuation. For business owners interested in selling their business, buying a business, or succession planning, we help our clients understand what their business is worth. Our work includes analysis of the business and historical trends, forward-looking projections, industry and economic research, and a conclusion of value in various scenarios. Preparation and Review of Pitch Materials and Coaching. For businesses that are fundraising, we can help review marketing materials and provide feedback on how the founders tell their story, and how that story aligns with key performance indicators. 9  Educational Seminars / Speaking Engagements We may provide seminars for groups seeking general advice on investments and other areas of personal finance. These seminars are purely educational in nature and do not involve the sale of any investment products. Information presented will not be based on any individual’s need, nor does Telos provide individualized investment advice to attendees during these seminars. Topics covered during educational seminars will be determined by the Client and Telos. Client Tailored Services and Client Imposed Restrictions We tailor the delivery of our services to meet the individual needs of our Clients. We consult with Clients initially and on an ongoing basis, through the duration of their engagement with us, to determine risk tolerance, time horizon and other factors that may impact the Clients’ investment and/or planning needs. Clients are able to specify, within reason, any restrictions they would like to place as it pertains to individual securities and/or sectors that will be traded in their account. All such requests must be provided to Telos in writing. Telos will notify Clients if they are unable to accommodate any requests. Wrap Fee Programs We do not participate in wrap fee programs. Assets Under Management As of June 23, 2026, Telos has $139,462,878.60 in discretionary and $0 in non-discretionary assets under management. Item 5: Fees and Compensation Please note, unless a Client has received this brochure at least 48 hours prior to signing an Advisory Contract, the Advisory Contract may be terminated by the Client within five (5) business days of signing the Advisory Contract without penalty or incurring any fees. At no time do we require prepayment of $1,200 or more six months or more in advance of rendering the services. How we are paid depends on the type of advisory services we perform. Below is a brief description of our fees, however, you should review your executed Advisory Contract for more detailed information regarding the exact fees you will be paying. Fees are negotiable and some fees may vary by Client for similar services. No increase to the agreed-upon advisory fees outlined in the Advisory Contract shall occur without prior Client consent. Our standard advisory fee schedule applies to new clients. Advisory fees are negotiable and may vary from the standard fee schedule based on factors including account size, complexity, services provided, relationship history, legacy arrangements, and other circumstances. Certain legacy clients, including clients who became clients of the firm through a merger, acquisition, or other business combination, may continue to pay advisory fees under prior fee schedules or other negotiated arrangements. As a result, similarly situated clients may 10  pay different advisory fees. The specific advisory fee applicable to each client is set forth in the client’s investment advisory agreement. Legacy fee schedules may be higher or lower than the firm’s current standard fee schedule. Investment Management Services The fee is based on a percentage of assets under management and is negotiable. The annualized fees for investment management services are based on the following fee schedule: Assets Under Management Annual Advisory Fee $0 - $1,000,000 1.25% $1,000,001 - $10,000,000 1.00% $10,000,001- $15,000,000 0.75% $15,000,001- $25,000,000 0.65% $25,000,001 - $50,000,000 0.55% $50,000,001 - $100,000,000 0.48% $100,000,001 and Above 0.40% The annual advisory fee is paid quarterly in arrears based on the value of Client’s account(s) as of the last day of the previous billing period. The advisory fee is a straight tiered fee and is calculated by assessing the percentage rates using the predefined levels of assets as shown in the above chart. For example, for assets under management of $3,000,000, a Client would pay an effective fee of 1.00% with the annual fee of $30,000. The formula for the quarterly fee is determined by the following calculation: (($3,000,000 x 1.00%) ÷ 4 = $7,500. In determining the advisory fee, we may allow accounts of members of the same household to be aggregated. Telos relies on the valuation as provided by Client’s custodian in determining assets under management. Our advisory fee is prorated for any partial billing periods occurring during the engagement, including the initial and terminating billing periods. If Telos utilizes an Outside Manager, the above fee schedule does not include the Outside Manager’s fee. The Outside Manager’s advisory fees, billing schedule, and payment procedures are set forth in their separate written disclosure documents, advisory agreements, and/or the account opening documents of your account Custodian. At no point will the combined advisory fee charged to the Client exceed 2% of assets under management. Ongoing Comprehensive Financial Planning Telos collects an initial fee, no greater than $12,500. The initial fee covers the initial construction of the comprehensive financial plan. This work will commence immediately after the fee is paid, and the length of time required to complete and deliver the plan is dependent on several factors including the needs of the Client, the Client’s ability to provide any necessary information and documentation, as well as the complexity of their financial situation. Advisor may reduce or waive the initial fee at the Advisor’s discretion. 11  Upon delivery of the comprehensive financial plan, we charge a recurring fixed fee for Ongoing Comprehensive Financial Planning. Fees are paid monthly or quarterly in arrears, ranging from $3,600 to $18,000 annually. The fee range is dependent upon variables including the specific needs of the Client, complexity, estimated time, research, and resources required to provide services to you, among other factors we deem relevant. Fees are negotiable and the final agreed upon fee will be outlined in your Advisory Contract. For clients with at least $1,000,000 in assets under management, Telos may waive the Ongoing Comprehensive Financial Planning fees. Project-Based Financial Planning We charge a fixed fee for Project-Based Financial Planning. Fixed fee rates range from $8,000 to $20,000. The fee range is dependent upon variables including the specific needs of the Client, complexity, estimated time, research, and resources required to provide services to you, among other factors we deem relevant. Fees are negotiable and the final agreed upon fee will be outlined in your Advisory Contract. Telos collects a portion of the fee to be collected in advance with the remainder due upon completion of the services. Family Office Consulting Clients may engage this combined service for a fee based on a percentage of assets under management, fixed fees, or any combination as outlined in the client agreement. Family Office Consulting consists of an ongoing fee that is paid monthly or quarterly, in arrears, that can range from $140,000 to $240,000 annually for the work involved in supporting the Client with the implementation, maintenance, and future iterations of the plan. The fee is determined based on the expected amount of work and the level of complexity (tax planning issues, employee stock options, estate related issues, legacy investments and new portfolio strategies) involved in the planning arrangement with the client. The fee arrangement will be reviewed and agreed to by Telos and the Client at the start of the engagement. Hourly Consulting Service Hourly Consulting Service will be offered at the rate of $500 per hour. The fee is negotiable at the firm’s discretion based on the expected work involved at various points in the engagement or based on other factors such the client being an employee of the firm or a family member. Monthly ongoing consulting services are available at our hourly rate. Fees are paid in arrears on a monthly basis, following the receipt of a monthly invoice for hours worked during each period. Educational Seminars / Speaking Engagements Seminars and Speaking Engagements are offered to organizations and the public on a variety of financial topics. Fees range from $300 to $30,000 per seminar or $100 to $2,000 per participant. The fee range is based on the content, amount of research conducted, the number of hours of preparation needed, and the number of attendees. Fees are due in advance of the seminar or speaking engagement. Advisor offers its services in a virtual or in-person setting. Should the event require travel arrangements, both parties must agree to the terms of travel (i.e. cost, distance, hotel arrangements) at the start of the engagement. These engagements 12  may be canceled or terminated by the client at any time up to the date of the event or engagement. Any prepaid but unearned fees will be refunded within 30 days of the receipt of notice of termination. Fee Payment Fees for Investment Management services are deducted from one or more account(s) held at an unaffiliated third-party custodian, as directed by the Client. Please refer to Item 15 of this Brochure regarding our policy on direct fee deduction. Fees for all other services may be paid by electronic funds transfer, debit card, credit card or check. We use an independent third-party payment processor in which the Client can securely input their payment information to pay their fee. We do not have access to the Client’s banking or credit information at any time. The Client will be provided with their own secure portal in order to make payments. Other Types of Fees and Expenses Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which may be incurred by the Client. Clients may incur certain charges imposed by custodians, brokers, and other third parties such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer, and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual fund and exchange-traded funds also charge internal management fees, which are disclosed in a fund's prospectus. Such charges, fees, and commissions are exclusive of and in addition to our fee, and we shall not receive any portion of these commissions, fees, and costs. Item 12 further describes the factors that we consider in selecting or recommending custodians for Client’s transactions and determining the reasonableness of their compensation (e.g., commissions). Clients may incur fees from third-party professionals such as accountants and attorneys that Telos may recommend, upon Client request. Such fees are separate and distinct from Telos’s advisory fees. Terminations and Refunds For Investment Management Services, the Advisory Contract may be terminated with written notice 30 calendar days in advance. Since fees are paid in arrears, no refund will be needed upon termination of the Advisory Contract. Clients will be responsible for payment of fees up to the date of termination. For Ongoing Comprehensive Financial Planning services, the Advisory Contract may be terminated with written notice 30 calendar days in advance. In the event of early termination prior to the initial plan being delivered, fees will be prorated based upon the percentage of the work done up to the date of termination and any unearned fees will be refunded to the Client. Since ongoing fees are paid in arrears, no refund will be needed upon termination of the Advisory Contract. Clients will be responsible for payment of fees up to the date of termination. For Project-Based Financial Planning & Hourly Consulting Services, these services are not an ongoing engagement, thus upon receipt of the final fees, the Advisory Contract will automatically be terminated. Clients may terminate at any time provided written notice. If fees are paid in advance, a prorated refund will 13  be given, if applicable, upon termination of the Advisory Contract for any unearned fee. For fees paid in arrears, Client shall be charged a pro-rata fee based upon the percentage of the work done up to the date of termination. For Family Office Consulting engagements, an annual fee commitment, payable in monthly or quarterly installments, is required. If a Client terminates the engagement before the annual fee has been paid, the remainder of the annual fee is due. This commitment is compensation for Client onboarding, data gathering, and setting the basis for the financial plan. This work will commence immediately after the engagement begins, and will be completed within the first 30 days of the date the first quarter or month fee is paid. Therefore, any payment of the remaining commitment is for work already completed. Upon completion of the initial annual commitment, the engagement may be terminated in writing 30 days in advance. Clients will be responsible for payment of fees up to the date of termination. For Educational Seminars and Speaking Engagements, Advisor or Clients may cancel the event with 30 days’ advance written notice. Should the Client cancel the event within 30 days of the event (with the exception of weather or similar unforeseen causes), the Client will be responsible for reimbursement of any non- refundable travel expenses already incurred and a prorated fee for any work conducted in preparation of the event, based on the percentage of work done and the flat fee agreed upon by both parties. Should any fees collected in advance exceed the amount of work conducted, Advisor will provide a prorated refund within 30 days from the notice of termination. Sale of Securities or Other Investment Products Advisor and its supervised persons do not accept compensation for the sale of securities or other investment products including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management We do not offer performance-based fees and do not engage in side-by-side management Item 7: Types of Clients We provide financial planning and investment management services to individuals, high net-worth individuals, charitable organizations and corporations or other businesses. We do not have a minimum account size requirement to open or maintain an account. Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Methods of Analysis Fundamental analysis involves analyzing individual companies and their industry groups, such as a company’s financial statements, details regarding the company’s product line, the experience, and expertise of the company’s management, and the outlook for the company’s industry. The resulting data is used to measure the true value of the company’s stock compared to the current market value. The risk of fundamental 14  analysis is that the information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock’s value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Technical analysis involves using chart patterns, momentum, volume, and relative strength in an effort to pick sectors that may outperform market indices. However, there is no assurance of accurate forecasts or that trends will develop in the markets we follow. In the past, there have been periods without discernible trends and similar periods will presumably occur in the future. Even where major trends develop, outside factors like government intervention could potentially shorten them. Furthermore, one limitation of technical analysis is that it requires price movement data, which can translate into price trends sufficient to dictate a market entry or exit decision. In a trendless or erratic market, a technical method may fail to identify trends requiring action. In addition, technical methods may overreact to minor price movements, establishing positions contrary to overall price trends, which may result in losses. Finally, a technical trading method may underperform other trading methods when fundamental factors dominate price moves within a given market. 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 funds in the Client’s portfolio. In addition, we 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 fund or ETF less suitable for the Client’s portfolio. Alternative Investments. Though it is not Telos's primary investment strategy, Telos and its representative may from time to time recommend less traditional assets (sometimes called “alternative investments”) in combination with more traditional assets like stocks and bonds, when suitable. Alternative investments can include: commodities, currency hedging, direct lending, hedge funds, precious metals, private equity, venture capital, among others. Alternative investments may be accessed in multiple ways, including, but not limited to, Direct Investment, Pooled Investment Vehicles, and Private Investment Funds. Telos shall not have discretionary authority to directly invest Client funds into alternative investments. Telos is limited to recommending or advising on alternative investments based on Client’s goals and risk tolerance. Clients should be aware of the risk should Client implement Telos’s recommendations. Alternative investments generally involve various risk factors, including, but not limited to the following. A more in-depth discussion of risks that must be considered is set forth in each investment’s offering documents or similar disclosure document, which will be provided to each Client for review and consideration prior to investing. ● Potential for complete loss of principal, meaning that you may lose your entire investment ● Liquidity constraints 15  ● Lack of transparency ● Difficulty obtaining price evaluation ● Limited or no secondary market ● Long term investment commitment ● Volatility of returns ● High internal and operating costs ● Restrictions on withdrawals ● Complex tax structures and delays in tax reporting ● Less regulation Use of Outside Managers: We may refer clients to independent investment managers or independent investment management programs (“Outside Managers”) offered by various sub-advisors to manage portions of a client’s portfolio. The decision to use an Outside Manager is based on our assessment of the client’s needs and objectives, and whether these solutions may be more appropriate than mutual funds or ETFs for certain portfolio allocations. Our due diligence and ongoing monitoring of Outside Managers involves evaluating their experience, expertise, investment philosophies, and historical performance to assess their ability to manage investments over various market cycles. We also review and monitor their underlying holdings, strategies, concentrations, and leverage as part of our periodic risk assessments. As part of our diligence process, we assess compliance infrastructure and enterprise-level business risks to help identify any operational concerns. Clients should be aware that past success by an Outside Manager or sub-advisor does not guarantee future performance. There is also a risk that these managers may deviate from their stated investment mandates, potentially making the strategy less suitable for our clients. Furthermore, because we do not oversee the daily business or compliance operations of these third parties, we may be unaware of deficiencies in internal controls that could lead to business, regulatory, or reputational risks. Investment Strategies Asset Allocation In implementing our Clients’ investment strategy, we begin by attempting to identify an appropriate ratio of equities, fixed income, and cash (i.e. “asset allocation”) 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 equities, 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. We attempt to closely monitor our asset allocation models and make changes periodically to keep in line with the target risk tolerance model. Passive and Active Investment Management We may choose investment vehicles that are considered passive, active, or a combination of both styles. Passive investing involves building portfolios that are composed of various distinct asset classes. The asset classes are weighted in a manner to achieve a desired relationship between correlation, risk and return. Funds that passively capture the returns of the desired asset classes are placed in the portfolio. Active investing involves a single manager or managers who employ some method, strategy or technique to construct a portfolio that is intended to generate returns that are greater than the broader market or a 16  designated benchmark. Actively managed funds are also designed to reduce volatility and risk. We may engage in both passive and active investing in the Client's portfolio. However, we strive to construct portfolios of funds and individual securities that we believe will have the greatest probability for achieving our Clients’ personal financial goals with the least amount of volatility and risk rather than attempt to outperform an arbitrary index or benchmark. Specific investment selections are based on a number of factors that we evaluate in order to select, what we believe to be, the highest quality funds or individual securities for our Clients. These factors include but are not limited to underlying holdings of funds, percentage weighting of holdings within funds, liquidity, tax efficiency, bid/ask spreads, and other smart/strategic beta factors. These factors may or may not result in the lowest cost ETFs and mutual funds available when utilizing funds in a Client’s portfolio, but we strive to keep internal fund expenses as low as possible. Socially Responsible Investing We may utilize various socially conscious investment approaches if a Client desires. Telos may construct portfolios that utilize mutual funds, ETFs, or individual securities with the purpose of incorporating socially conscious principles into a Client’s portfolio. These portfolios may sometimes also be customized to reflect the personal values of each individual, family, or organization. This allows our Clients to invest in a way that aligns with their values. Telos may rely on mutual funds and ETFs that incorporate Environmental, Social and Governance (“ESG”) research as well as positive and negative screens related to specific business practices to determine the quality of an investment on values-based merits. Additionally, Telos may construct portfolios of individual securities in order to provide Clients with a greater degree of control over the socially conscious strategies they are utilizing. Telos relies on third-party research when constructing portfolios of individual securities with socially conscious considerations. If you request your portfolio to be invested according to socially conscious principles, you should note that returns on investments of this type may be limited and because of this limitation you may not be able to be as well diversified among various asset classes. The number of publicly traded companies that meet socially conscious investment parameters is also limited, and due to this limitation, there is a probability of similarity or overlap of holdings, especially among socially conscious mutual funds or ETFs. Therefore, there could be a more pronounced positive or negative impact on a socially conscious portfolio, which could be more volatile than a fully diversified portfolio. Material Risks Involved All investing strategies we offer involve risk and may result in a loss of your original investment which you should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities, and any other investment or security. Material risks associated with our investment strategies are listed below. Market Risk: Market risk involves the possibility that an investment’s current market value will fall because of a general market decline, reducing the value of the investment regardless of the operational success of the issuer’s operations or its financial condition. Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended. Small and Medium Cap Company Risk: Securities of companies with small and medium market capitalizations are often more volatile and less liquid than investments in larger companies. Small and 17  medium cap companies may face a greater risk of business failure, which could increase the volatility of the Client’s portfolio. Turnover Risk: Actively managed mutual funds tend to have a higher turnover rate than passive funds. A high portfolio turnover would result in higher transaction costs and in higher taxes when shares are held in a taxable account. These factors may negatively affect the account’s performance. Limited markets: Certain securities may be less liquid (harder to sell or buy) and their prices may at times be more volatile than at other times. Under certain market conditions, we may be unable to sell or liquidate investments at prices we consider reasonable or favorable or find buyers at any price. Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall below par value or the principal investment. The opposite is also generally true: bond prices generally rise when interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these price changes. Most other investments are also sensitive to the level and direction of interest rates. Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or the securities’ claim on the issuer’s assets and finances. Inflation: Inflation may erode the buying power of your investment portfolio, even if the dollar value of your investments remains the same. Risks Associated with Securities Apart from the general risks outlined above which apply to all types of investments, specific securities may have other risks. Commercial Paper is, in most cases, an unsecured promissory note that is issued with a maturity of 270 days or less. Being unsecured the risk to the investor is that the issuer may default. Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s bankruptcy or restructuring could lose all value. A slower-growth or recessionary economic environment could have an adverse effect on the price of all stocks. Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest and repay the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero coupon bonds, which do not pay current interest, but rather are priced at a discount from their face values and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on factors such as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond’s maturity, the greater its interest rate risk. Exchange Traded Funds prices may vary significantly from the Net Asset Value due to market conditions. Certain Exchange Traded Funds may not track underlying benchmarks as expected. ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above (premium) or below (discount) their net asset value and an ETF purchased at a premium may ultimately be sold at a discount; (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are delisted from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large 18  decreases in stock prices) halts stock trading generally. The Adviser has no control over the risks taken by the underlying funds in which the Clients invest. Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes, including the construction of public facilities. Municipal bonds pay a lower rate of return than most other types of bonds. However, because of a municipal bond’s tax-favored status, investors should compare the relative after-tax return to the after-tax return of other bonds, depending on the investor’s tax bracket. Investing in municipal bonds carries the same general risks as investing in bonds in general. Those risks include interest rate risk, reinvestment risk, inflation risk, market risk, call or redemption risk, credit risk, and liquidity and valuation risk. Mutual Funds When a Client invests in open-end mutual funds or ETFs, the Client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will incur higher expenses, many of which may be duplicative. In addition, the Client's overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). Options and other derivatives carry many unique risks, including time-sensitivity, and can result in the complete loss of principal. While covered call writing does provide a partial hedge to the stock against which the call is written, the hedge is limited to the amount of cash flow received when writing the option. When selling covered calls, there is a risk the underlying position may be called away at a price lower than the current market price. Item 9: Disciplinary Information Criminal or Civil Actions Telos and its management persons have not been involved in any criminal or civil action. Administrative Enforcement Proceedings Telos and its management persons have not been involved in any administrative enforcement proceedings. Self-Regulatory Organization Enforcement Proceedings Telos and its management persons have not been involved in any self-regulatory organization (SRO) proceedings. Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer Affiliation Neither Telos or its management persons is registered, or have an application pending to register, as a broker- dealer or a registered representative of a broker-dealer. Other Affiliations Neither Telos or its management persons is registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of the foregoing entities. 19  Related Persons Nicholas Stecklein is an Investment Advisor Representative of Telos Partners LLC and is also the owner of Advantage Tax and Planning. While Telos provides investment advisory and financial planning services, we may independently contract with Advantage Tax and Planning to provide specialized tax consulting or preparation services for certain client engagements. Telos will collect the fees from clients for these services when applicable and remit payment to Advantage Tax and Planning. This arrangement allows Telos to integrate professional tax insights into our broader financial planning process; however, Advantage Tax and Planning operates as a separate and distinct legal entity from Telos Partners LLC. Mr. Stecklein devotes 25 hours per week during market trading hours to this activity. At times, Telos may refer clients to Advantage Tax and Planning for tax-related needs, and conversely, Mr. Stecklein may refer his tax clients to Telos for investment management. Telos does not receive any compensation or referral fees in exchange for these introductions. However, a conflict of interest exists because Nicholas Stecklein has a financial incentive to recommend Advantage Tax and Planning for tax services. We mitigate this conflict by requiring that all such recommendations are made in the client's best interest and by ensuring clients understand they are never obligated, as a client of Telos, to use the services of Advantage Tax and Planning. Peter Hughes and Christopher Stevenson provide consulting services through Forrest Financial Partners LLC (“FFP”), which holds an ownership interest in Telos Partners LLC. These consulting activities are separate from the investment advisory services they provide through Telos. Mr. Hughes and Mr. Stevenson may, in the course of their consulting work with FFP, introduce individuals to Telos where Telos’s services may be appropriate. Neither Mr. Hughes nor Mr. Stevenson receives referral fees, bonuses, revenue-sharing payments, or other compensation based on whether an individual introduced through FFP becomes a Telos client. These outside business activities may occur during normal business hours but are not expected to materially interfere with Mr. Hughes’s or Mr. Stevenson’s responsibilities to Telos or its clients. Recommendations or Selections of Other Investment Advisers Telos recommends Clients to Outside Managers to manage their accounts. In the event that we recommend an Outside Manager, we do not share in their advisory fee. Our fee is separate and in addition to their compensation (as noted in Item 5 of this brochure). Clients will receive a copy of the Outside Manager’s Form ADV 2A, Firm Brochure, which also describes the Outside Manager’s fee. You are not obligated, contractually or otherwise, to use the services of any Outside Manager we recommend. Moreover, Telos will only recommend an Outside Manager who is properly licensed or registered as an investment adviser. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading As a fiduciary, our firm has a duty of utmost good faith to act solely in the best interests of each Client. Our Clients entrust us with their funds and personal information, which in turn places a high standard on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the expected 20  basis of all of our dealings. The firm also adheres to the Code of Ethics and Professional Responsibility adopted by the CFP® Board of Standards Inc., and accepts the obligation not only to comply with the mandates and requirements of all applicable laws and regulations but also to take responsibility to act in an ethical and professionally responsible manner in all professional services and activities. Additionally, Telos requires adherence to its Insider Trading Policy, and the CFA Institute's Asset Manager Code of Professional Conduct and Code of Ethics and Standards of Professional Conduct. Code of Ethics Description This Code of Ethics does not attempt to identify all possible conflicts of interest, and compliance with each of its specific provisions will not shield our firm or its access persons from liability for misconduct that violates a fiduciary duty to our Clients. A summary of the Code of Ethics' Principles is outlined below. ● Integrity - Access persons shall offer and provide professional services with integrity. ● Objectivity - Access persons shall be objective in providing professional services to Clients. ● Competence - Access persons shall provide services to Clients competently and maintain the necessary knowledge and skill to continue to do so in those areas in which they are engaged. ● Fairness - Access persons shall perform professional services in a manner that is fair and reasonable to Clients, principals, partners, and employers, and shall disclose conflict(s) of interest in providing such services. ● Confidentiality - Access persons shall not disclose confidential Client information without the specific consent of the Client unless in response to proper legal process, or as required by law. ● Professionalism - Access persons conduct in all matters shall reflect the credit of the profession. ● Diligence - Access persons shall act diligently in providing professional services. We periodically review and amend our Code of Ethics to ensure that it remains current, and we require all firm access persons to attest to their understanding of and adherence to the Code of Ethics at least annually. Our firm will provide a copy of its Code of Ethics to any Client or prospective Client upon request. Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest Neither our firm, its access persons, or any related person is authorized to recommend to a Client or effect a transaction for a Client, involving any security in which our firm or a related person has a material financial interest, such as in the capacity as an underwriter, adviser to the issuer, principal transaction, among others. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest Our firm, its access persons, and its related persons may buy or sell securities similar to, or different from, those we recommend to Clients. In an effort to reduce or eliminate certain conflicts of interest, our Code of Ethics may require that we restrict or prohibit access persons’ transactions in specific reportable securities. Any exceptions or trading pre-clearance must be approved by Telos’s Chief Compliance Officer in advance of the transaction in an account. Telos maintains a copy of access persons’ personal securities transactions as required. Trading Securities At/Around the Same Time as Client’s Securities From time to time our firm, its access persons, or its related persons may buy or sell securities for themselves at or around the same time as they buy or sell securities for Clients’ account(s). To address this conflict, it is 21  our policy that neither our firm or access persons shall have priority over Clients’ accounts in the purchase or sale of securities. Item 12: Brokerage Practices Factors Used to Select Custodians In recommending custodians, we have an obligation to seek the “best execution” of transactions in Client accounts. The determinative factor in the analysis of best execution is not the lowest possible commission cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of the custodian’s services. The factors we consider when evaluating a custodian for best execution include, without limitation, the custodian’s: ● Combination of transaction execution services and asset custody services (generally without a separate fee for custody); ● Capability to execute, clear, and settle trades (buy and sell securities for your account); ● Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.); ● Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.); ● Availability of investment research and tools that assist us in making investment decisions; ● Quality of services; ● Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices; ● Reputation, financial strength, security and stability; ● Prior service to us and our clients. With this in consideration, our firm recommends Charles Schwab & Co., Inc. (“Schwab”) and Interactive Brokers, as independent and unaffiliated SEC registered broker-dealer firms and members of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). Research and Other Soft-Dollar Benefits We do not have any soft-dollar arrangements with custodians whereby soft-dollar credits, used to purchase products and services, are earned directly in proportion to the amount of commissions paid by a Client. However, as a result of being on their institutional platform, Schwab and Interactive Brokers may provide us with certain services that may benefit us. Schwab Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like us. They provide our Clients and us with access to their institutional brokerage services (trading, custody, reporting and related services), many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our Clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available on an 22  unsolicited basis (we don’t have to request them) and at no charge to us. The benefits received by Advisor or its personnel do not depend on the number of brokerage transactions directed to Schwab. As part of its fiduciary duties to Clients, Advisor at all times must put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits by Advisor or its related persons in and of itself creates a potential conflict of interest and may indirectly influence the Advisor’s choice of Schwab for custody and brokerage services. This conflict of interest is mitigated as Advisor regularly reviews the factors used to select custodians to ensure our recommendation is appropriate. Following is a more detailed description of Schwab’s support services: 1. Services that benefit you. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our Clients. Schwab’s services described in this paragraph generally benefit you and your account. 2. Services that may not directly benefit you. Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our Clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or a substantial number of our Clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: ● provide access to Client account data (such as duplicate trade confirmations and account statements) facilitate trade execution and allocate aggregated trade orders for multiple Client accounts facilitate payment of our fees from our Clients’ accounts ● ● provide pricing and other market data ● ● assist with back-office functions, recordkeeping, and Client reporting 3. Services that generally benefit only us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: ● Educational conferences and events ● Consulting on technology, compliance, legal, and business needs ● Publications and conferences on practice management and business succession 4. Your brokerage and custody costs. For our Clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, many mutual funds and ETFs) may not incur Schwab commissions or transaction fees. Interactive Brokers Interactive Brokers offers products or services other than execution that assist our firm in managing and administering client accounts. These may include software and other technology that provides access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), facilitate payment of our fees from clients’ accounts, and assist with back-office functions, record keeping and client reporting. These services may be used to 23  service all or a substantial number of client accounts, including accounts not maintained at Interactive Brokers. Telos may also receive services from Interactive Brokers that are intended to help our firm manage and further develop our business. These services may include website design and technology support. Interactive Brokers also has arrangements with various product vendors, which enable our firm to purchase their products at a discount. These products may include such items as: client reporting and consolidated statement software; client communication software; client relationship management software; compliance assistance; and investment research. While the benefits we receive from Interactive Brokers does not depend on the amount of brokerage transactions directed to Interactive Brokers, as a fiduciary we are required to disclose that there is an inherent conflict of interest when our firm recommends that clients maintain their assets at Interactive Brokers. These recommendations may be based in part on the benefits we receive from Interactive Brokers, such as the availability of the above-mentioned products and services, and not solely on our clients’ interest in receiving the most favorable execution. Fidelity Telos maintains a custodial relationship with the Institutional Wealth Services division of Fidelity Investments (“Fidelity”). Fidelity is a qualified third-party custodian. In connection with the Fidelity relationship Telos may receive the following benefits through Fidelity Institutional Wealth Services: custodian/adviser interface software, certain practice management software and resources, duplicate trade confirmations and bundled duplicate statements; access to a trading desk that exclusively services its Institutional Wealth Services participants; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; and access to an electronic communication network for client order entry and account information. Clients may benefit from Telos’s custodial relationship with Fidelity in that Telos employees may help facilitate account openings and closings, cashiering functions such as wire transfers and journaling funds between accounts, providing intraday account balances, and communicating with Fidelity on their behalf. These services accrue to the benefit of 13 all Telos Clients that custody at Fidelity, although Clients may not benefit equally from these products and services. Products and services received by Telos from Fidelity are standard to all advisers utilizing Fidelity. While Telos does suggest that Clients custody their accounts at Fidelity, Telos does not require use of Fidelity. Ultimately the choice of custodian is up to the Client. Clients who choose to use a custodian other than Fidelity may not realize the benefits that come about as a result of Telos’s custodial relationship with Fidelity Brokerage for Client Referrals We receive no referrals from a custodian, broker-dealer or third party in exchange for using that custodian, broker-dealer or third party. Clients Directing Which Broker/Dealer/Custodian to Use Our firm recommends Clients establish account(s) at Schwab and Interactive Brokers to execute transactions through. We will assist with establishing your account(s) at Schwab and Interactive Brokers, however, we will 24  not have the authority to open accounts on the Client's behalf. Not all investment advisers require their Clients to use their recommended custodian. By recommending that Clients use Schwab and Interactive Brokers, we may be unable to achieve most favorable execution of Client transactions, and this practice may cost Clients more money. We base our recommendations on the factors disclosed in Item 12 herein and will only recommend custodians if we believe it's in the best interest of the Client. If Clients do not wish to utilize our recommended custodian, we permit Clients to direct brokerage. We will be added to your account through a limited trading authority. However, due to restraints from not having access to an institutional platform, we are unable to achieve most favorable execution of Client transactions. Clients directing brokerage may cost Clients more money. For example, in a directed brokerage account, the Client may pay higher brokerage commissions because we may not be able to aggregate orders to reduce transaction costs, or the Client may receive a higher transaction price at their selected custodian versus our recommended custodian. Aggregating (Block) Trading for Multiple Client Accounts Generally, we combine multiple orders for shares of the same securities purchased for advisory accounts we manage (this practice is commonly referred to as “block trading”). We will then distribute a portion of the shares to participating accounts in a fair and equitable manner. The distribution of the shares purchased is typically proportionate to the size of the account, but it is not based on account performance or the amount or structure of management fees. Subject to our discretion, regarding particular circumstances and market conditions, when we combine orders, each participating account pays an average price per share for all transactions and pays a proportionate share of all transaction costs. Accounts owned by our firm or access persons may participate in block trading with your accounts; however, they will not be given preferential treatment. Outside Managers used by Telos may block Client trades at their discretion. Their specific practices are further discussed in their ADV Part 2A, Item 12 Item 13: Review of Accounts Periodic Reviews An associated person of Telos will work with Clients to obtain current information regarding their assets and investment holdings and will review this information as part of our financial planning services. Telos does not provide specific reports to Clients, other than financial plans. Clients who engage us for investment management services will have their account(s) reviewed regularly on a quarterly basis by the respective adviser. All investment adviser representatives are supervised by Peter Hughes, Managing Partner and CCO. The account(s) are reviewed with regards to the Client’s investment objectives and risk tolerance levels. Triggers of Reviews Events that may trigger a special review would be unusual performance, addition or deletions of Client- imposed restrictions, excessive draw-down, volatility in performance, or buy and sell decisions from the firm or per Client's needs. Review Reports 25  Clients will receive trade confirmations from the custodian(s) for each transaction in their accounts as well as monthly or quarterly statements and annual tax reporting statements from their custodian showing all activity in the accounts, such as receipt of dividends and interest. Telos will provide written performance and/or holdings reports to Investment Management Clients on a quarterly basis. We urge Clients to compare these reports against the account statements they receive from their custodian. Item 14: Client Referrals and Other Compensation Compensation Received by Telos Partners LLC Telos is a fee-only firm that is compensated solely by its Clients. Telos does not receive commissions or other sales-related compensation. Except as mentioned in Item 12 above, we do not receive any economic benefit, directly or indirectly, from any third party for advice rendered to our Clients. Client Referrals from Solicitors Telos does not, directly or indirectly, compensate any person who is not advisory personnel for Client referrals. Item 15: Custody Telos does not hold, directly or indirectly, Client funds or securities, or have any authority to obtain possession of them. All Client assets are held at a qualified custodian. If Telos deducts its advisory fee from Client’s account(s), the following safeguards will be applied: i. ii. The Client will provide written authorization to Telos, permitting us to be paid directly from Client’s accounts held by the custodian. The custodian will send at least quarterly statements to the Client showing all disbursements from the accounts, including the amount of the advisory fee. We urge you to carefully review custodial statements and compare them to the account invoices or reports that we may provide to you and notify us of any discrepancies. Clients are responsible for verifying the accuracy of these fees as listed on the custodian’s brokerage statement as the custodian does not assume this responsibility. Our invoices or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Telos can establish a Standing Letter of Authorization or other similar asset transfer authorization arrangements (“SLOA”) with qualified custodians in order for us to disburse funds to accounts as specifically designated by the Client. With a SLOA a Client can typically authorize first-party and/or third-party transfers. If transfers are third-party, Telos complies with each of the requirements and conditions enumerated below: 1. The Client provides an instruction to the qualified custodian, in writing, that includes the Client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. 26  2. The Client authorizes Telos, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. 3. The Client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the Client’s authorization, and provides a transfer of funds notice to the Client promptly after each transfer. 4. The Client has the ability to terminate or change the instruction to the Client’s qualified custodian. 5. Telos has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the Client’s instruction. 6. Telos maintains records showing that the third party is not a related party of Telos or located at the same address as Telos. 7. The Client’s qualified custodian sends the Client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Item 16: Investment Discretion For those Client accounts where we provide Investment Management Services, Telos has discretionary authority and limited power of attorney to determine the securities and the amount of securities to be bought or sold for a Client’s account without having to obtain prior Client approval for each transaction. Investment discretion is explained to Clients in detail when an advisory relationship has commenced. At the start of the advisory relationship, the Client will execute a Limited Power of Attorney, which will grant our firm discretion over the account(s). Additionally, the discretionary relationship will be outlined in the Advisory Contract and signed by the Client. Clients may limit our discretion by requesting certain restrictions on investments. However, approval of such requests are at the firm’s sole discretion. If Telos has engaged an Outside Manager to assist with the management of Client’s portfolio, Telos has the discretion to direct the Outside Manager to buy or sell securities for Client’s portfolio without obtaining prior Client approval for each transaction. Item 17: Voting Client Securities Telos will typically take on the responsibility to vote proxies for client securities. We have adopted Proxy Voting Policies and Procedures that outline our voting processes. Our Proxy policies and procedures are designed to ensure that we address any known potential or actual conflicts of interest and that we vote in our clients’ best interest. We utilize a third-party proxy voting administration service to assist in monitoring and voting client proxies, and maintaining the required records pertaining to each proxy vote made. We have also contracted with a third-party proxy voting solution to provide us with an electronic proxy voting platform. The solution maintains written proxy voting guidelines that can be configured by our firm to enable us to review, report, and vote on proxies efficiently while ensuring that votes are made consistent with the interests of our clients. Telos performs a periodic review of the guidelines to form a reasonable belief that the recommendations are consistent with furthering the interests of our clients. 27  Item 18: Financial Information We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to our Clients, nor have we been the subject of any bankruptcy proceeding. We do not have custody of Client funds or securities, except as disclosed in Item 15 above, or require or solicit prepayment of more than $1,200 in fees six months or more in advance. 28