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Firm Brochure
(Part 2A of Form ADV)
964 State Route 28
Milford, OH 45150
PHONE: 513-575-9654
FAX: 513-575-9656
WEBSITE: www.brownfinancialadvisors.com
EMAIL: team@brownfinancialadvisors.com
This brochure provides information about the qualifications and business practices of
Brown Financial Advisors, LLC. Being registered as a registered investment adviser
does not imply a certain level of skill or training. If you have any questions about the
contents of this brochure, please contact us at 513-575-9654 or by email at
team@brownfinancialadvisors.com. The information in this brochure has not been
approved or verified by the United States Securities and Exchange Commission, or by
any state securities authority.
Additional information about Brown Financial Advisors, LLC (IARD #147056) is
available on the SEC’s website at www.adviserinfo.sec.gov
April 2, 2025
Brown Financial Advisors, LLC
Item 2: Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure.
Material Changes since the Last Update
This update is in accordance with the annual filing requirements for Registered Investment
Advisors. Since the last filing of this brochure on February 29, 2024, the following has been
changed:
•
Item 4 has been updated to reflect the current assets under management.
Full Brochure Available
Whenever you would like to receive a complete copy of our Firm Brochure, please contact us
by telephone at: 513-575-9654 or by email at: team@brownfinancialadvisors.com.
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Brown Financial Advisors, LLC
Item 3: Table of Contents
Form ADV – Part 2A – Firm Brochure
Item 1: Cover Page
Item 2: Material Changes ...................................................................................................................... i
Annual Update .................................................................................................................................................. i
Material Changes since the Last Update ................................................................................................ i
Full Brochure Available ................................................................................................................................ i
Item 3: Table of Contents .................................................................................................................... ii
Item 4: Advisory Business .................................................................................................................. 1
Firm Description ............................................................................................................................................ 1
Types of Advisory Services ........................................................................................................................ 1
Client Tailored Services and Client Imposed Restrictions ............................................................. 1
Wrap Fee Programs ...................................................................................................................................... 2
Client Assets Under Management ............................................................................................................ 2
Item 5: Fees and Compensation ....................................................................................................... 2
Method of Compensation and Fee Schedule........................................................................................ 2
Third-Party Client Payment of Fees ........................................................................................................ 4
Additional Client Fees Charged ................................................................................................................ 4
Prepayment of Client Fees .......................................................................................................................... 4
External Compensation for the Sale of Securities to Clients ......................................................... 4
Item 6: Performance-Based Fees ..................................................................................................... 4
Sharing of Capital Gains ............................................................................................................................... 4
Item 7: Types of Clients ....................................................................................................................... 5
Description ....................................................................................................................................................... 5
Account Minimums ....................................................................................................................................... 5
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 5
Methods of Analysis ...................................................................................................................................... 5
Investment Strategy ...................................................................................................................................... 5
Security Specific Material Risks ............................................................................................................... 5
Item 9: Disciplinary Information ..................................................................................................... 6
Criminal or Civil Actions ............................................................................................................................. 6
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Brown Financial Advisors, LLC
Administrative Enforcement Proceedings ........................................................................................... 6
Self-Regulatory Organization Enforcement Proceedings ............................................................... 6
Item 10: Other Financial Industry Activities and Affiliations ............................................... 6
Broker-Dealer or Representative Registration .................................................................................. 6
Futures or Commodity Registration ....................................................................................................... 6
Material Relationships Maintained by this Advisory Business and Conflicts of Interest .. 6
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest 6
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading ..................................................................................................................................................... 7
Code of Ethics Description ......................................................................................................................... 7
Investment Recommendations Involving a Material Financial Interest and Conflict of
Interest ............................................................................................................................................................... 7
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest ............................................................................................................................................................... 7
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Transactions and Conflicts of Interest ................................................................................................... 8
Item 12: Brokerage Practices ........................................................................................................... 8
Factors Used to Select Broker-Dealers for Client Transactions ................................................... 8
Aggregating Securities Transactions for Client Accounts .............................................................. 8
Item 13: Review of Accounts ............................................................................................................. 8
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved ............................................................................................................................................ 8
Review of Client Accounts on Non-Periodic Basis ............................................................................ 8
Content of Client Provided Reports and Frequency ......................................................................... 8
Item 14: Client Referrals and Other Compensation .................................................................. 9
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts
of Interest .......................................................................................................................................................... 9
Advisory Firm Payments for Client Referrals ..................................................................................... 9
Item 15: Custody .................................................................................................................................... 9
Account Statements ...................................................................................................................................... 9
Item 16: Investment Discretion ....................................................................................................... 9
Discretionary Authority for Trading ...................................................................................................... 9
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Brown Financial Advisors, LLC
Item 17: Voting Client Securities ................................................................................................... 10
Proxy Votes ....................................................................................................................................................10
Item 18: Financial Information ...................................................................................................... 10
Balance Sheet .................................................................................................................................................10
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
Commitments to Clients ............................................................................................................................10
Bankruptcy Petitions during the Past Ten Years .............................................................................10
Supervised Person Brochure .......................................................................................................... 11
Gregory Brown ..............................................................................................................................................11
Principal Executive Officers and Management Persons - Gregory Brown ............................12
Education and Business Standards .......................................................................................................12
Disciplinary Information ...........................................................................................................................12
Other Business Activities ..........................................................................................................................12
Additional Compensation .........................................................................................................................12
Supervision .....................................................................................................................................................13
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Brown Financial Advisors, LLC
Item 4: Advisory Business
Firm Description
Brown Financial Advisors, LLC, (“BFA”) was founded in 2008. Gregory Allen Brown is 100%
owner.
BFA is a fee-based financial planning firm. The firm does not sell annuities, insurance, stocks,
bonds, funds, limited partnerships, or other commissioned products and the firm’s Managing
Member is affiliated with an entity that sells financial insurance products, known as Brown
Insurance & Tax Advisors.
An evaluation of each client's initial situation is provided to the client, often in the form of a
holdings summary and risk analysis. Periodic reviews are also communicated to provide
reminders of the specific courses of action that need to be taken.
Other professionals (e.g., Lawyers, Accountants, Insurance Agents, etc.) are engaged directly
by the client on an as-needed basis. Conflicts of interest will be disclosed to the client in the
unlikely event they should occur.
Types of Advisory Services
Asset Management Services
BFA has also entered into a Co-Advisor relationship with Gradient Investments, LLC (GI).
BFA will provide information to each client regarding the services offered by GI as the
portfolio manager. BFA will assist the Client to determine the appropriate model selection
based on the Client’s investment objectives and risk tolerance. BFA will have full discretion
on an ongoing basis to select suitable models to maintain client’s risk tolerance. BFA will
share in the management fees charged by GI as described in Item 5 of this brochure.
Financial Planning and Consulting
If financial planning services are applicable, the client may choose to compensate BFA on a
negotiable fixed fee basis or hourly basis described in detail under “Fees and Compensation”
section of this brochure. Services include but are not limited to a thorough review of all
applicable topics including Wills, Estate Plan/Trusts, Investments, Taxes, and Insurance, and
such services may not constitute, treated or billed as financial plan. A conflict of interest
exists between the interests of the investment advisor and the interests of the client. The
client is under no obligation to act upon the investment advisor’s recommendation. If the
client elects to act on any of the recommendations, the client is under no obligation to effect
the transaction through BFA. Any ffinancial plans, if applicable, will be completed and
delivered inside of ninety (90) days. Clients may terminate advisory services with thirty (30)
days written notice.
Solicitor Arrangements
BFA has legacy clients where BFA acted as a solicitor for Gradient Investments, LLC. Any new
clients placed with Gradient Investments, LLC will be through the Co-Advisor relationship
described above.
Client Tailored Services and Client Imposed Restrictions
The goals and objectives for each client are documented in our client files. Investment
strategies are created that reflect the stated goals and objective. Clients may impose
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restrictions on investing in certain securities or types of securities. Agreements may not be
assigned without client consent.
Wrap Fee Programs
BFA does not sponsor or manage a wrap fee programs.
Client Assets Under Management
BFA has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts:
$298,778,630
$0
Date Calculated:
December 31, 2024
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
Co-Adviser Fees
Gradient Investments, LLC (“GI”) SEC number 801-70812
BFA has entered into a Co-Advisor Agreement with Gradient Investments, LLC (“GI”). GI is a
Registered Investment Advisor registered with the Securities and Exchange Commission that
provides investment portfolio advice and supervisory services.
GI offers an actively managed program of mutual fund and stock portfolios. The fee will be
disclosed to the Client in the Investment Advisory Agreement and are negotiable. The Clients
fee for these services will be based on a percentage of assets under management as follows:
STRATEGIC & TACTICAL, ALLOCATION & DEFINED OUTCOME PORTFOLIOS
All Assets
Annual Fee
1.40%
GI
0.40%
BFA
1.00%
Traditionally, GI’s Tactical Portfolio was billed with a max annual fee of 2.00%. Since GI is the
sub-advisor to the Tactical Portfolio and will receive an annual fee of 0.20% from the ETF, GI
has reduced its annual fee of the Tactical Portfolio so as not to double dip.
For example, a Client investing $100,000 in the GI Tactical portfolio prior to November 2022
would pay an annual fee to GI of $2,000 or $100,000 x 2.00% = $2,000. After November
2022 the same client would pay GI an annual fee of $1,400 or $100,000 x 1.40% = $1,400 and
pay the internal fees of $200 or $100,000 x 0.20% = $200. For a total of $1,400 + $200 =
$1,600.
PRESERVATION PORTFOLIOS
All Assets
Annual Fee
1.00%
GI
0.40%
BFA
0.60%
CLIENT DIRECTED ACCOUNTS
All Assets
Annual Fee
$300
GI
$300
BFA
$0
For Client Directed Accounts (CDA), GI will assist in the opening, closing and transferring of
accounts. GI will not have discretion at any time on these accounts. Client is solely
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responsible for the assets held within the accounts and their values which could increase or
decrease (potential loss of principal). GI will not execute trades in CDA accounts. GI
exceptions will be made for withdrawals to client or assets transferred into a GI managed
portfolio. GI will also provide performance reporting on these accounts and can furnish
3rd party analysis reports per the client’s request. Similar services may be available through
other sources for a lower fee.
These are flat fee schedules, the entire portfolio is charged the same asset management fee.
Example:
Calculation
Quarterly Fee
($750,000*1.40%) * (91/365) $2,617.81
Portfolio
Strategic, Tactical, Allocation & Defined
Outcome Portfolios
Preservation Portfolio
($750,000*1.0%) * (91/365) $1,869.86
Fee Calculation: (Quarter End Value x Annual Fee %) x (Days in Quarter/Days in Year) + $15
Quarterly Service Fee*
* The $15 Quarterly Service Fee is the technology fee charged per account or investment strategy
for performance and other reporting. This fee is disclosed in our ADV Part 2A (Item 5: Fees and
Compensation) and in our Investment Proposal and Contract (Schedule D: Schedule of Fees).
The above fees are negotiable. Fees are assessed quarterly in arrears based on the amount of the
assets managed as of the end of the previous quarter. All management fees are withdrawn from
the Client’s account unless otherwise noted. GI will receive written authorization from the Client
to deduct advisory fees from their account held by a qualified custodian. GI will pay BFA their
share of the fees. BFA does not have access to deduct Client fees. Clients may terminate their
account within five (5) business days of signing the investment advisory agreement without
penalty or obligation. For terminations after the initial five business days, GI will be entitled to a
pro-rata fee for the days service was provided in the final quarter. GI will pay BFA their portion of
the final fee.
Incentive Program - GI
In addition to the regular advisory fee, GI has instituted a long-term incentive arrangement
by BFA can share in GI’s portion of the management fee. This does not change the cost to the
client; it is a sharing arrangement paid from GI’s portion of the advisory fee. The incentive
arrangement will be paid annually according to the following table:
BFA quarterly AUM with GI
$10,000,000
$25,000,000
$50,000,000
$75,000,000
Participation rate in GI’s fee
3.00%
10.00%
12.50%
15.00%
Once BFA reaches and maintains the thresholds listed above, the participation rate applies to
all of the AUM for the quarter.
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To receive the incentive award, BFA needs to meet two qualifications. First, the quarter end
billable AUM must be above the threshold amounts specified. Second, Advisor must be an
advisor “in good standing” with GI at the time the annual checks are issued. “In good
standing” means the advisor is proactively placing assets with GI.
Financial Planning and Consulting
Prior to the planning process the client will be provided an estimated plan fee. Services
include but are not limited to a thorough review of all applicable topics including Wills,
Estate Plan/Trusts, Investments, Taxes, Insurance, and Mortgages. Client will pay nothing to
start with the balance payable after ninety (90) days. Client may cancel at any time during
the ninety (90) days with no cost or obligation. Services are completed and delivered inside
of ninety (90) days.
Hourly Fees
Financial Planning Services may be offered based on an hourly fee of $200 per hour.
Fixed Fees
Financial Planning Services may be offered based on a negotiable fixed fee with a
maximum fee of $2,500 based on complexity and unique client needs.
Third-Party Client Payment of Fees
Asset Management fees are billed monthly in arrears. Fees for financial plans are billed upon
delivery of the financial plan.
Additional Client Fees Charged
Custodians may charge transaction fees on purchases or sales of certain funds, bonds,
equities and exchange-traded funds. These charges may include fund transactions fees,
postage and handling and miscellaneous fees (fees levied to recover costs associated with
fees assessed by self-regulatory organizations). These transaction charges are usually small
and incidental to the purchase or sale of a security. The selection of the security is more
important than the nominal fee that the custodian charges to buy or sell the security.
Prepayment of Client Fees
BFA does not charge client fees in advance.
External Compensation for the Sale of Securities to Clients
BFA does not receive any external compensation for the sale of securities to clients, nor do
any of the Investment Advisor Representatives of BFA.
Item 6: Performance-Based Fees
Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of managed
securities.
BFA does not use a performance-based fee structure because of the conflict of interest.
Performance-based compensation may create an incentive for the adviser to recommend an
investment that may carry a higher degree of risk to the client.
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Item 7: Types of Clients
Description
BFA generally provides investment advice to individuals, trusts and high net worth
individuals. Client relationships vary in scope and length of service.
Account Minimums
BFA does not require a minimum to open an account.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Third-Party Money Managers (“TPM”) utilized by BFA may use various methods of analysis
to determine the proper strategy for the client referred and these will be disclosed in the
TPM’s Form ADV Part 2. Investing in securities involves risk of loss that clients should be
prepared to bear.
When creating a financial plan, BFA utilizes fundamental analysis to provide review of
insurance policies for economic value and income replacement. Technical analysis is used to
review mutual funds and individual stocks. The main sources of information include
Morningstar, client documents such as tax returns and insurance policies.
In developing a financial review for a client, BFA’s analysis may include cash flow analysis,
investment planning, risk management, tax planning and estate planning. Based on the
information gathered, a detailed strategy is tailored to the client’s specific situation.
Investment Strategy
The investment strategy for a specific client is based upon the objectives stated by the client
during consultations. The client may change these objectives at any time. Each client
executes an Investment Policy Statement or Risk Tolerance that documents their objectives
and their desired investment strategy.
Other strategies may include long-term purchases, short-term purchases, trading, and option
writing (including covered options, uncovered options or spreading strategies).
Security Specific Material Risks
All investment programs have certain risks that are borne by the investor. The specific risks
associated with financial planning include:
• Risk of Loss
o Client fails to follow the recommendations of BFA resulting in market loss
o Client has changes
in
financial status or
lifestyle and
therefore plan
recommendations are no longer valid
The risks associated with utilizing TPMs include:
• Manager Risk
o TPM fails to execute the stated investment strategy
• Business Risk
o TPM has financial or regulatory problems
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The specific risks associated with the portfolios of the TPM’s which is disclosed in the TPM’s
Form ADV Part 2.
Item 9: Disciplinary Information
Criminal or Civil Actions
BFA and its management have not been involved in any criminal or civil action.
Administrative Enforcement Proceedings
BFA and its management have not been involved in administrative enforcement proceedings.
Self-Regulatory Organization Enforcement Proceedings
The firm and its management have not been involved in legal or disciplinary events related
to past or present investment clients.
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer or Representative Registration
Neither BFA nor any of its employees are registered representatives of a broker-dealer.
Futures or Commodity Registration
Neither BFA nor its employees are registered or has an application pending to register as a
futures commission merchant, commodity pool operator, or a commodity trading advisor.
Material Relationships Maintained by this Advisory Business and Conflicts of Interest
Managing Member Gregory Brown has a financial affiliated business involving Insurance, Tax
Advisory and Tax Preparation, known as Brown Insurance & Tax Advisors, LLC. From time
to time, he will offer clients products, services and advice from those activities.
These practices represent conflicts of interest because it may give an incentive to
recommend products based on the commission and/or fee amount received. However, this
conflict is mitigated by disclosures, procedures, and the firm’s Fiduciary obligation to place
the best interest of the client first and the clients are not required to purchase any products
or services. Clients have the option to purchase these products, services, or advice through
another Insurance Agent or Tax Preparer of their choosing.
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest
BFA utilizes the services of Third-Party Money Managers to manage client accounts. In such
circumstances, BFA receives Co-Advisor fees from the Third-Party Manager. This situation
creates a conflict of interest. However, when referring clients to a Third-Party Money
Manager, the client’s best interest will be the main determining factor of BFA. These fees do
not include brokerage fees that may be assessed by the custodian. Fees for these services are
based on a percentage of Assets Under Management not to exceed any limit imposed by any
regulatory agency. The final fee schedule is disclosed in the Client agreement.
This Co-Advisor relationship is disclosed to the client in each contract between BFA and
Third-Party Money Manager. BFA does not charge additional management fees for Third-
Party Managed Account Services. Client's signature is required to confirm consent for
services within Third-Party Investment Agreement. Client initials BFA 's Investment
Advisory Agreement to acknowledge receipt of Third-Party Fee Schedule and required
documents including Form ADV Part 2 disclosures.
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Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
Code of Ethics Description
The employees of BFA have committed to a Code of Ethics (“Code”). The purpose of our Code
is to set forth standards of conduct expected of BFA employees and addresses conflicts that
may arise. The Code defines acceptable behavior for employees of BFA. The Code reflects
BFA and its supervised persons’ responsibility to act in the best interest of their client.
One area which the Code addresses is when employees buy or sell securities for their
personal accounts and how to mitigate any conflict of interest with its clients. We do not
allow any employees to use non-public material information for their personal profit or to
use internal research for their personal benefit in conflict with the benefit to its clients.
BFA’s policy prohibits any person from acting upon or otherwise misusing non-public or
inside information. No advisory representative or other employee, officer or director of BFA
may recommend any transaction in a security or its derivative to advisory clients or engage
in personal securities transactions for a security or its derivatives if the advisory
representative possesses material, non-public information regarding the security.
BFA’s Code is based on the guiding principle that the interests of the client is its top priority.
BFA’s officers, directors, advisors, and other employees have a fiduciary duty to its clients
and must diligently perform that duty to maintain the complete trust and confidence of its
clients. When a conflict arises, it is BFA's obligation to put the client’s interests over the
interests of either employees or the company.
The Code applies to “Access” persons. “Access” persons are employees who have access to
non-public information regarding any clients' purchase or sale of securities, or non-public
information regarding the portfolio holdings of any reportable fund, who are involved in
making securities recommendations to clients, or who have access to such recommendations
that are non-public.
BFA will provide a copy of the Code of Ethics to any client or prospective client upon request.
Investment Recommendations Involving a Material Financial Interest and Conflict of
Interest
BFA and its employees do not recommend to clients securities in which we have a material
financial interest.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest
BFA and its employees may buy or sell securities that are also held by clients. In order to
mitigate conflicts of interest such as trading ahead, employees are required to disclose all
reportable securities transactions as well as provide the firm with copies of their brokerage
statements.
The Chief Compliance Officer of BFA is Gregory Brown. He reviews all employee trades on a
quarterly basis. The personal trading reviews ensure that the personal trading of employees
does not affect the markets and that clients of the firm receive preferential treatment over
employee transactions.
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Client Securities Recommendations or Trades and Concurrent Advisory Firm
Securities Transactions and Conflicts of Interest
BFA does not maintain a firm proprietary trading account and does not have a material
financial interest in any securities being recommended and therefore no conflicts of interest
exist.
Item 12: Brokerage Practices
Factors Used to Select Broker-Dealers for Client Transactions
BFA may recommend the use of a particular custodian or may utilize a custodian of the
client's choosing. BFA will select an appropriate custodian based on a number of factors
including but not limited to their relatively low transaction fees and reporting ability. BFA
relies on its custodian to provide its execution services at the best prices available. Lower
fees for comparable services may be available from other sources. Clients pay for any and all
custodial fees in addition to the advisory fee charged by BFA.
• Directed Brokerage
BFA utilizes Third-Party Money Managers and therefore it does not take direction from
clients as to what custodian to use.
• Best Execution
Investment advisors who manage or supervise client portfolios on a discretionary basis
have a fiduciary obligation of best execution. BFA does not exercise discretion of client
accounts.
• Soft Dollar Arrangements
BFA does not maintain any soft dollar arrangements.
Aggregating Securities Transactions for Client Accounts
BFA does not trade individual securities therefore aggregation of securities transactions is
not applicable.
Item 13: Review of Accounts
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved
Account reviews are performed quarterly by advisor Gregory Brown, Chief Compliance
Officer (CCO). Account reviews are performed more frequently when market conditions
dictate. Initial financial review work and/or financial plans (if any) are considered complete
when recommendations are delivered to the client and a review is done upon request of
client as well as other specific frequencies as may be requested and mutually agreed to.
Review of Client Accounts on Non-Periodic Basis
Other conditions that may trigger a review of clients’ accounts are changes in the tax laws,
new investment information, significant changes in market conditions, and/or changes in a
client's own as well as other specific frequencies as requested and mutually agreed to.
Content of Client Provided Reports and Frequency
Clients receive account statements no less than quarterly for managed accounts. Account
statements are issued by the Third-Party Money Manager’s custodian. Client receives
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confirmations of each transaction in an account from the Custodian and may receive an
additional statement during any month in which a transaction occurs.
Item 14: Client Referrals and Other Compensation
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts
of Interest
In addition, financial consultants may be eligible for cash and non-cash compensation
including incentives, education-focused trips and other benefits. Some of these programs
may be financed in whole or in part by unaffiliated third parties, including Third-Party
Money Managers, which may influence some representatives to favor those managers. See
the prior sections entitled “Fees and Compensation” and “Other Financial Industry Activities
and Affiliations” for more details regarding compensation and conflicts of interests.
BFA’s investment advisor representatives may receive certain benefits from Gradient
Investments, LLC (and/or its affiliated companies) based on achieving certain production
thresholds. These thresholds are not based on the sale of any specific product or specific
product type. These incentives include marketing assistance, access to technology, office
support, and business trainings and trips. While some of these benefit the client, such as
technology and training, some do not. This creates a conflict of interest because it gives an
incentive to the representative to meet this threshold. This conflict is mitigated by
disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the
Client first. Clients are not required to use Gradient Investments, LLC or any of its affiliated
companies.
Advisory Firm Payments for Client Referrals
BFA does not compensate for Client referrals.
Item 15: Custody
Account Statements
All assets are held at qualified custodians, which means the custodians provide account
statements directly to clients at their address of record at least quarterly. Clients are urged
to compare the account statements received directly from their custodians to any
performance report statements prepared by the Third-Party Money Managers.
Item 16: Investment Discretion
Discretionary Authority for Trading
BFA has discretion to select appropriate portfolios for clients when using GI portfolios, but
does not have the discretion to select specific securities within the portfolios.
BFA allows Client’s to place certain restrictions, as outlined in the Client’s Investment Policy
Statement or similar document. Such restrictions could include only allowing purchases of
socially conscious investments. These restrictions must be provided to BFA in writing.
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Item 17: Voting Client Securities
Proxy Votes
BFA does not vote proxies on securities. Clients are expected to vote their own proxies. The
client will receive their proxies directly from the custodian of their account or from a transfer
agent.
When assistance on voting proxies is requested, BFA will provide recommendations to the
Client. If a conflict of interest exists, it will be disclosed to the Client.
Item 18: Financial Information
Balance Sheet
A balance sheet is not required to be provided because BFA does not serve as a custodian for
client funds or securities and BFA does not require prepayment of fees of more than $1200
per client and six months or more in advance.
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
Commitments to Clients
BFA has no condition that it is reasonably likely to impair its ability to meet contractual
commitments to our clients.
Bankruptcy Petitions during the Past Ten Years
Neither BFA nor its management has had any bankruptcy petitions in the last ten years.
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Supervised Person Brochure
Part 2B of Form ADV
Gregory Brown
964 State Route 28
Milford, OH 45150
PHONE: 513-575-9654
FAX: 513-575-9656
WEBSITE: www.brownffinancialadvisors.com
EMAIL: team@brownfinancialadvisors.com
This brochure supplement provides information about Gregory Brown and supplements
Brown Financial Advisors, LLC’s brochure. You should have received a copy of that
brochure. Please contact Gregory Brown if you did not receive Brown Financial Advisors
LLC’s brochure or if you have any questions about the contents of this supplement.
Additional information about Gregory Brown (CRD# 5578071) is available on the SEC’s
website at www.adviserinfo.sec.gov
April 2, 2025
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Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Principal Executive Officers and Management Persons - Gregory Brown
• Year of Birth: 1965
Education and Business Standards
Educational Background:
• FINRA Series 65 - Investment Advisor Representative
• Life, Health, Accident and Annuity Insurance Lines - Licensure
• Property and Casualty Insurance Lines – Licensure
• Mortgage Broker Loan Origination Officer – Licensure
• Central State University - Finance - Studies
• University of Oklahoma - Nursing Home Administration - Licensure
• South Oklahoma City Jr. College - Finance - Studies
• Southern Nazarene University - Human Resource Management - Studies
• Southern Ohio Bible College - Biblical Studies and Pastoral Theology - Studies
Business Experience:
• Brown Financial Advisors, LLC: Managing Member/Investment Advisor Representative
From 03/2008-Present
• Brown Insurance & Tax Advisors, LLC: President/Insurance/Taxes
From 12/2004-Present
Disciplinary Information
None to report.
Other Business Activities
Gregory Brown has a financial affiliated business involving Insurance, Tax Advisory and Tax
Preparation, known as Brown Insurance & Tax Advisors, LLC. From time to time, he will
offer clients products, services and advice from those activities.
These practices represent conflicts of interest because it gives an incentive to recommend
products based on the commission and/or fee amount received. However, this conflict is
mitigated by disclosures, procedures, and the firm’s Fiduciary obligation to place the best
interest of the client first and the clients are not required to purchase any products or
services. Clients have the option to purchase these products and services through another
Insurance Agent or Tax Preparer of their choosing.
Additional Compensation
Mr. Brown receives additional compensation in his capacity as an Insurance Agent, but he
does not receive any performance-based fees.
Mr. Brown may receive certain benefits from Gradient Investments, LLC (and/or its affiliated
companies) based on achieving certain production thresholds. These thresholds are not
based on the sale of any specific product or specific product type. These incentives include
marketing assistance, access to technology, office support, and business trainings and trips.
While some of these benefit the client, such as technology and training, some do not. This
creates a conflict of interest because it gives an incentive to the representative to meet this
threshold. This conflict is mitigated by disclosures, procedures and the firm’s fiduciary
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obligation to place the best interest of the Client first. Clients are not required to use Gradient
Investments, LLC or any of its affiliated companies.
Supervision
Mr. Brown is the sole owner of Brown Financial Advisors, LLC; therefore, he is solely
responsible for all supervision and formulation and monitoring of investment advice offered
to clients. He will adhere to the required policies and procedures as described in the firm’s
Compliance Manual.
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