FPN ADV PART 2A APPENDIX 1 - WRAP FEE PROGRAM BROCHURE

ITEM 1: COVER PAGE Financial Planning Navigators Corp. ADV Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure 7365 Kirkwood Court North Suite 330 Maple Grove MN 55369 (763) 265-4450 fpnavigators.com January 27, 2026 This wrap fee program brochure provides information about the qualifications and business practices of Financial Planning Navigators Corp. (hereinafter “FPN” or “Adviser” or “We”). If you have any questions about the contents of this brochure, please contact us at (763) 265-4450. 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. Registration does not imply a certain level of skill or training. Additional information about Financial Planning Navigators Corp. also is available on the SEC’s website at www.adviserinfo.sec.gov. 1  ITEM 2: MATERIAL CHANGES The following material change has been made to this Brochure since its last filing on February 10, 2025. • FPN has updated its fee schedule. See Item 4 for more information. This Brochure will be delivered to Clients of the Wrap Fee Program before or at the time a client enters into the Wrap Fee Program contact. Either this complete Brochure or a Summary of Material Changes shall be provided to each Client annually and if a material change occurs in the business practices of FPN. 2  ITEM 3: TABLE OF CONTENTS ITEM 1: COVER PAGE ................................................................................................................. 1 ITEM 2: MATERIAL CHANGES ................................................................................................. 2 ITEM 3: TABLE OF CONTENTS ................................................................................................. 3 ITEM 4: SERVICES, FEES AND COMPENSATION ................................................................. 4 ITEM 5: ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ........................................ 5 ITEM 6: PORTFOLIO MANAGER SELECTION AND EVALUATION ................................... 5 ITEM 8: CLIENT CONTACT WITH PORTFOLIO MANAGERS .............................................. 8 ITEM 9: ADDITIONAL INFORMATION .................................................................................... 8 3  ITEM 4: SERVICES, FEES AND COMPENSATION A. FPN manages individually allocated portfolios, providing ongoing advice to the client based on the individual needs, client profile and risk tolerance of the client. When suitable for the client, we recommend the use of Third-Party Managers, Outside Managers, or Sub-Advisors (TAMPs) for portfolio management services. When FPN recommends a Sub-Advisor, the Client shall authorize and direct the Custodian (as defined) to pay to Sub-Advisor the Management Fee out of the Account upon the Custodian's receipt of a statement from the Sub-Advisor. Please note, the Sub-Advisor’s fee will be charged separately and in addition to FPN’s fee. Client will sign a separate contract with each Sub-Advisor, stipulating the frequency and amount of payments, as well as the calculation used to assess the advisory fee. Fees are negotiable. Families may use combined AUM totals for billing purposes. The WRAP fee charged for the program are according to the following fee schedule: Account Value $0 - $500,000 $500,000 - $1,000,000 $1,000,001 - $2,000,000 $2,000,001 - $4,000,000 $4,000,001 - $6,000,000 $6,000,001 - $8,000,000 $8,000,001 - $10,000,000 $10,000,001 - $15,000,000 $15,000,001 - $20,000,000 $20,000,001 - $40,000,000 $40,000,001 - $75,000,000 $75,000,001 - $150,000,000 $150,000,000+ Annual Advisory Fee 1.50% 1.25% 1.05% 0.95% 0.85% 0.75% 0.70% 0.65% 0.55% 0.50% 0.45% 0.43% 0.40% B. The wrap program may cost the client more or less than purchasing such services separately, based on factors such as trading activity in the client’s account. C. The client may pay certain fees in addition to the wrap fee, such as custodial fees, charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. These fees are not included in the wrap fee that is charged by our firm. When managing a client's account on a wrap fee basis, we receive as compensation for our investment advisory services, the balance of the total wrap [or program] fee you pay after custodial, trading and other management costs (including execution and transaction fees) have been deducted. Accordingly, we have a conflict of interest because we have a financial incentive to 4  maximize our compensation by seeking to reduce or minimize the total costs incurred in your account(s) subject to a wrap fee. D. FPN does not compensate any person other than firm personnel as a result of the client’s participation in the wrap program. ITEM 5: ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS We do not have a minimum account size requirement. We provide investment advice to individuals, high net-worth individuals, pension and profit- sharing plans, charitable organizations, and corporations or other businesses. ITEM 6: PORTFOLIO MANAGER SELECTION AND EVALUATION A. Portfolio managers are selected based on investment management strategies and models that are deemed suitability for clients. Portfolio managers must be appropriately registered and properly positioned to provide quality execution of client transactions. 1. FPN uses industry standards to calculate portfolio manager performance. 2. FPN reviews performance information to determine or verify its accuracy and its compliance with presentation standards. 3. Performance information is calculated on a uniform and consistent basis. B. FPN and its advisers sponsor and act as portfolio managers for the wrap fee program described in this wrap fee program brochure. This may create a conflict of interest in that other investment advisory firms may charge the same or lower fees than our firm for similar services. Our related person portfolio managers are not subject to the same selection and review as outside portfolio managers that participate in the wrap fee program. C. Advisory Business FPN and its Investment Adviser Representatives act as a portfolio manager(s) for FPN’s wrap fee program. See Item 4 of this wrap fee program brochure for more information about our wrap fee advisory programs. Tailored Advice and Client Imposed Restrictions FPN tailors’ investment management and financial planning services to the individual needs of clients, by collecting client profile and suitability data at the commencement of the engagement, to assess the client’s risk tolerance and investment objectives. For Financial Planning clients, Adviser collects relevant data to the client’s financial planning. Needs to provide specifically tailored advice. When suitable for the client, we recommend the use of Third-Party Managers, 5  Outside Managers, or Sub-Advisors (TAMPs) for portfolio management services. Clients may impose restrictions on investing in certain securities or types of securities. Methods of Analysis, Investment Strategies and Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. The methods of analysis and investment strategies Adviser uses in formulating investment advice or managing assets are as follows: A. Modern Portfolio Theory (MPT) is a practical method for selecting investments to maximize their overall returns within an acceptable level of risk. A key component of the MPT theory is diversification. Most investments are either high risk and high return or low risk and low return. The underlying principles of MPT include the theory that the only acceptable risk is that which is adequately compensated by an expected return. Risk and investment return are related and an increase in risk requires an increased expected return. Additionally, MPT suggests that markets are efficient. The same market information is available to all investors at the same time, so the market prices every security fairly based upon this equal availability of information. The design of the portfolio is more important than the selection of any particular security. The appropriate allocation of capital among asset classes will have far more influence on long-term portfolio performance than the selection of individual securities. Increasing diversification of the portfolio with lower correlated asset class positions can decrease portfolio risk. Correlation is the statistical term for the extent to which two asset classes move in tandem or opposition to one another. B. 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 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. C. Technical Analysis involves using chart patterns, momentum, volume, and relative strength 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. D. Cyclical Analysis is a type of technical analysis that involves evaluating recurring price patterns and trends based upon business cycles. Economic/business cycles may not be 6  predictable and may have many fluctuations between long-term expansions and contractions. The lengths of economic cycles may be difficult to predict with accuracy and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and consequently the changing value of securities that would be affected by these changing trends. E. Charting Analysis involves the gathering and processing of price and volume information for a particular security. This price and volume information is analyzed using mathematical equations. The resulting data is then applied to graphing charts, which is used to predict future price movements based on price patterns and trends. Charts may not accurately predict future price movements. Current prices of securities may not reflect all information about the security and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. F. Use of Sub-Advisers: Adviser may refer Clients to third-party investment advisers ("outside managers"). Our analysis of outside managers involves the examination of the experience, expertise, investment philosophies, and past performance of the outside managers to determine if that manager has demonstrated an ability to invest over a period and in different economic conditions. We monitor the manager's underlying holdings, strategies, concentrations, and leverage as part of our overall periodic risk assessment. Additionally, as part of our due diligence process, we survey the manager's compliance and business enterprise risks. A risk of investing with an outside manager who has been successful in the past is that he or she may not be able to replicate that success in the future. In addition, as Adviser does not control the underlying investments in an outside manager's portfolio. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our Clients. Moreover, as we do not control the manager's daily business and compliance operations, we may be unaware of the lack of internal controls necessary to prevent business, regulatory or reputational deficiencies. Voting Client Securities Adviser does not vote client proxies. Clients will receive their proxies and other solicitations directly from their custodian. Clients can contact us at the phone number/email address on the cover page of this brochure with questions about a particular solicitation. ITEM 7: CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS We are required to describe the information about you that we communicate to your portfolio manager(s), and how often or under what circumstances we provide updated information. Our firm communicates with your portfolio manager(s) on a regular basis as needed (daily, weekly, monthly, etc.) to ensure the most current investment goals and objectives are understood by your portfolio manager(s). In most cases, we will communicate such information as part of our regular investment management duties. Nevertheless, we will also communicate information to your 7  portfolio manager(s) when you ask us to, when market or economic conditions make it prudent to do so. ITEM 8: CLIENT CONTACT WITH PORTFOLIO MANAGERS Our clients may directly contact their portfolio manager(s) with questions or concerns by calling the phone number on this Brochure. ITEM 9: ADDITIONAL INFORMATION Disciplinary Information The Adviser and its management personnel have not been the subject of any legal, regulatory, or disciplinary events that are material to a client’s or prospective client’s evaluation of the Adviser or the integrity of the Adviser’s management. Accordingly, there are no disciplinary events to disclose under this Item. Other Financial Industry Activities and Affiliations Neither the Adviser nor its management persons are registered, or have applications pending to register, as a broker-dealer or as a registered representative of a broker-dealer. In addition, neither the Adviser nor its management persons are registered, or have applications pending to register, as a futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of any such entities. Certain related persons of the Adviser, including Julie Hetland and Molly Murphy, may be licensed insurance agents and may receive compensation from unaffiliated insurance brokers, including Ash Brokerage and Highland Capital, in connection with the recommendation or sale of insurance products. This compensation creates a conflict of interest because it provides an incentive to recommend insurance products or insurance brokers based on compensation received rather than solely on a client’s needs. The Adviser addresses this conflict by requiring that recommendations be made in the client’s best interest, and clients are under no obligation to purchase insurance products or to engage any recommended insurance broker. The Adviser may also recommend the services of unaffiliated investment advisers or managers. The Adviser does not maintain any other business relationship with such advisers that would create a material conflict of interest. Any advisory fees charged by the Adviser are separate from, and in addition to, the fees charged by such advisers and are disclosed to clients prior to engagement. Clients are not required, contractually or otherwise, to engage the services of any outside investment adviser recommended by the Adviser. Code of Ethics, Participation or Interest in Client Transaction and Personal Trading The Adviser has adopted a written Code of Ethics that applies to all advisory activities, including Retirement Plan engagements and rollover-related advice. The Code of Ethics addresses, among other things, standards of conduct, professional duties to clients, conflicts of interest, personal securities transactions, reporting requirements for access persons, gifts and entertainment, 8  political contributions (“pay-to-play”), reporting of violations, and disciplinary actions. A copy of the Adviser’s Code of Ethics is available to any client or prospective client upon request at no cost. The Adviser does not recommend that clients purchase or sell any security in which the Adviser or a related person has a material financial interest. The Adviser and its related persons may invest in the same securities, or in related securities (such as warrants, options, or futures), that are recommended to clients. This practice creates a potential conflict of interest because the Adviser or its related persons could benefit from market activity resulting from client transactions or have influence over the timing or pricing of trades. The Adviser addresses this conflict through the policies and procedures contained in its Code of Ethics, including prohibitions on “front-running” and other improper trading practices, and by requiring access persons and related persons to adhere to applicable personal trading restrictions and reporting requirements. The Adviser or its related persons may also recommend securities to clients, or execute transactions for client accounts, at or about the same time that the Adviser or related persons buy or sell the same securities for their own accounts. The Adviser mitigates the conflicts associated with such concurrent trading by enforcing its Code of Ethics and supervisory procedures designed to promote fair and equitable treatment of clients. Review of Accounts The CCO will ensure Adviser periodically reviews client accounts and financial plans, on no less than an annual basis. Additional reviews of client accounts and financial plans may be triggered by volatile market conditions, changes to client profile information and investment objectives, and any communication by the client of imposed investment restrictions. Adviser will provide written reports to Investment Advisory clients on no less than an annual basis. We urge Clients to compare these reports against the account statements they receive from their custodian. Client Referrals and Other Compensation Adviser does not receive any economic benefit, directly or indirectly, from anyone who is not a client for advice rendered to our clients. Nor does Adviser, directly or indirectly, compensate any person who is not advisory personnel for client referrals. Adviser and its related persons do not directly or indirectly compensate any person who is not our supervised person for client referrals. Financial Information 9  The Adviser does not have any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. In addition, the Adviser does not require or solicit prepayment of advisory fees in excess of $1,200 per client, six months or more in advance. 10