CURRAN FINANCIAL PARTNERS, LLC

Curran Financial Partners, LLC 115 River Landing Dr, Suite 200 Daniel Island, SC, 29492 Form ADV Part 2A – Firm Brochure (843) 300-1182 info@curranfinancialpartners.com Website: www.CurranFinancialPartners.com Dated March 21, 2025 This Brochure provides information about the qualifications and business practices of Curran Financial Partners, LLC, “CFP”. If you have any questions about the contents of this Brochure, please contact us at (843) 300-1182. 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. Curran Financial Partners, LLC is registered as a SEC registered Investment Adviser. Registration of an Investment Adviser does not imply any level of skill or training. Additional information about CFP is available on the SEC’s website at www.adviserinfo.sec.gov which can be found using the firm’s identification number 281943. 1  Since the last annual update filing of the Form ADV Part 2A for CFP, dated March 22, 2024, there have been the following material changes: Item 2: Material Changes Please note that this section only discusses changes we consider material. • Accounting services were added to the types of advisory services being offered in Item 4. • Additional information about insurance product recommendations was provided in Item 10. • A new relationship with SmartAsset, a lead generation firm, was disclosed in Item 14. 2  Contents Item 3: Table of Contents Item 1: Cover Page ............................................................................................................................................. 1 Item 2: Material Changes ................................................................................................................................... 2 Item 3: Table of Contents ................................................................................................................................... 3 Item 4: Advisory Business ................................................................................................................................... 4 Item 5: Fees and Compensation ......................................................................................................................... 6 Item 6: Performance-Based Fees and Side-By-Side Management ..................................................................... 8 Item 7: Types of Clients ...................................................................................................................................... 8 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ............................................................... 8 Item 9: Disciplinary Information .......................................................................................................................11 Item 10: Other Financial Industry Activities and Affiliations ............................................................................11 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................13 Item 12: Brokerage Practices ...........................................................................................................................14 Item 13: Review of Accounts ............................................................................................................................15 Item 14: Client Referrals and Other Compensation .........................................................................................15 Item 15: Custody ..............................................................................................................................................15 Item 16: Investment Discretion ........................................................................................................................16 Item 17: Voting Client Securities ......................................................................................................................17 Item 18: Financial Information .........................................................................................................................17 3  Description of Advisory Firm Item 4: Advisory Business Curran Financial Partners, LLC is registered as an Investment Adviser with the U.S. Securities and Exchange Commission. We were founded on July 20, 2015. Adam Curran is the principal owner of CFP. As of December 31, 2024, CFP manages $505,652,097 on a discretionary basis. To avoid the appearance of double counting assets under management, this figure does not include assets under management for The God Bless America ETF (YALL) (“the Fund”), although these assets are included as regulatory assets under management in Item 5(D)(3) of our Form ADV, Part 1A. Types of Advisory Services Investment Management Services We are in the business of managing individually tailored investment portfolios in either our Passive Management Service or Active Management Service. Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's circumstances are established, we develop a client's personal investment policy or an investment plan with an asset allocation target and create and manage a portfolio based on that policy and allocation target. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. We may also review and discuss a client’s prior investment history, as well as family composition and background. Account supervision is guided by the stated objectives of the client (e.g., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Fees pertaining to this service are outlined in Item 5 of this brochure. Financial Planning Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. The key defining aspect of financial planning is that through the financial planning process, all questions, information and analysis will be considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service will receive a written or an electronic report, providing the client with a detailed financial plan designed to achieve his or her stated financial goals and objectives. The client is under no obligation to act upon our recommendations. If the client elects to act on any of the recommendations, the client is under no obligation to execute the transaction through our firm. In general, the financial plan will address any or all of the following areas of concern. The client and advisor will work together to select the specific areas to cover. These areas may include, but are not limited to, the 4  following: • 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 money market funds) for such reserves, plus strategies to save desired amounts. • College Savings: Includes projecting the amount that will be needed to achieve college or other post- secondary education funding goals, along with advice on ways for you to save the desired amount. Recommendations as to savings strategies are included, and, if needed, we will review your financial picture as it relates to eligibility for financial aid or the best way to contribute to grandchildren (if appropriate). • Estate Planning: This usually includes an analysis of your exposure to estate taxes and your current estate plan, which may include whether you have a will, powers of attorney, trusts and other related documents. Our advice also typically includes ways for you to minimize or avoid future estate taxes by implementing appropriate estate planning strategies such as the use of applicable trusts. We always recommend that you consult with a qualified attorney when you initiate, update, or complete estate planning activities. We may provide you with contact information for attorneys who specialize in estate planning when you wish to hire an attorney for such purposes. From time-to- time, we will participate in meetings or phone calls between you and your attorney with your approval or request. • Financial Goals: We will help clients identify financial goals and develop a plan to reach them. We will identify what you plan to accomplish, what resources you will need to make it happen, how much time you will need to reach the goal, and how much you should budget for your goal. • Insurance: Review of existing policies to ensure proper coverage for life, health, disability, long- term care, liability, home and automobile. • 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 5  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 during your retirement years. • Risk Management: A risk management review includes an analysis of your exposure to major risks that could have a significantly adverse effect 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 consideration that there is always a possibility of future changes to federal, state or local tax laws and rates that may affect 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. Accounting Services Curran Financial Partners does not provide accounting advice or tax preparation services to clients directly. We have established a relationship with Tyson Accounting, LLC (“Tyson”) to provide clients access to Tyson’s accounting advice and/or tax preparation services. Louis Tyson is the owner of Tyson Accounting, LLC. Our clients are under no obligation to use Tyson for their tax form preparation and planning needs. The minimum fee for tax preparation services can be negotiated and is ultimately at the discretion of Tyson Accounting, LLC. Tyson’s services are rendered independently of Curran Financial Partners pursuant to a separate agreement between the client and Tyson. Clients should be aware that there is a service level agreement between Curran Financial Partners and Tyson Accounting, LLC, and the agreement provides Tyson will be compensated with the use of office space maintained by Curran for giving access to its tax services to our clients. Sub-Adviser Services We are the sub-adviser for an exchange traded fund, The God Bless America ETF (YALL) . We select investments for the Fund from a universe of U.S. listed equity securities with market capitalizations of at least $1 billion. From the initial investment universe, we eliminate companies that, in our 6  assessment, have emphasized politically left and/or liberal political activism and social agendas at the expense of maximizing shareholder returns. For additional information please refer to the prospectus of YALL, available at https://www.godblessamericaetf.com/. Client Tailored Services and Client Imposed Restrictions We offer the same suite of services to all of our clients. However, specific services and their implementation are dependent upon each client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. Wrap Fee Programs We do not participate in wrap fee programs. Please note, unless a client has received the firm’s disclosure brochure at least 48 hours prior to signing the investment advisory contract, the investment advisory contract may be terminated by the client within five Item 5: Fees and Compensation (5) business days of signing the contract without incurring any advisory fees and without penalty. How we are paid depends on the type of advisory service we are performing. Please review the fee and compensation information below. Investment Management Services Passive Management Service: Our standard advisory fee for our passive management service is 1.00%. Active Management Service: Our standard advisory fee for our active management service is based on the market value of the assets under management and is calculated as follows: Account Value Annual Advisory Fee Total Fee 1.50% 1.50% All Assets The annual fees are negotiable and are pro-rated and paid in advance on a quarterly basis. No increase in the annual fee shall be effective without agreement from the client by signing a new agreement or amendment to their current advisory agreement. Advisory fees are directly debited from client accounts. Accounts initiated or terminated during a calendar quarter will be charged a pro-rated fee based on the amount of time remaining in the billing period. An account may be terminated with written notice. Upon termination of the account, any unearned fee will be refunded to the client on a prorated basis. Fee Refund for Investment Management and Advisory Services If a client of CFP is not satisfied with services provided in their first year, CFP will refund 100% of the client’s advisory fees paid. This refund is specific to Investment Management Services and Investment Advisory Services fees paid to CFP over the last 12 months and does not relate to mutual fund fees (i.e., 12(b) 1 or 7  expense ratios), investment fees, commissions paid in relation to insurance products to related persons of CFP, or any other fee associated with an unrelated third party. Financial Planning Hourly Fee Financial Planning fee is an hourly rate of $300.00. The fee may be negotiable in certain cases and is due at the completion of the engagement. In the event of early termination by client, any fees for the hours already worked will be due. Financial Planning Fixed Fee CFP charges a negotiable fixed fee for financial planning depending upon the complexity of the plan and the unique needs of the client. Prior to the planning process the client will be provided an estimated plan fee. The services include, but are not limited to, a thorough review of all applicable topics including Wills, Estate Plan/Trusts, Investments, Taxes, and Insurance. Client will pay half of the estimated fee at the signing of the agreement. Services are completed and delivered inside of thirty (30) days. Client may cancel within five (5) business days of signing Agreement for a full refund. If the client cancels after five (5) business days, any unearned fees will be refunded to the client, or any unpaid earned fees will be due to CFP. Unpaid fees will be calculated based on an hourly rate of $300.00. Financial Planning Services are offered based on flat fees between $750 and $1,500. Fees for Sub-advisory services to Investment Companies For the sub-advisory portfolio management services offered to YALL, CFP shall be paid an asset-based fee from Tidal Investments, LLC (“Tidal”). This fee shall be an annual rate of 0.02% of the fund’s average daily net assets. This fee shall be calculated daily and paid monthly. As we have agreed to assume the obligation of Tidal to pay all expenses incurred by the fund, except excluded expenses, Tidal has agreed to pay us the profits, if any, generated by the fund’s unitary management fee. See the fund’s offering documents for additional information regarding the fees associated with the fund. Other Types of Fees and Expenses Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses that 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 broker-dealers for client’s transactions and determining the reasonableness of their compensation (e.g., commissions). We 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. 8  Other Compensation CFP Investment Adviser Representatives may recommend and sell life, disability, health, and long-term care insurance and may receive additional compensation from the sale of investment products. While CFP Investment Adviser Representatives endeavor at all times to put the interest of our clients first as part of our fiduciary duty, the possibility of receiving additional compensation creates a conflict of interest, and may affect their judgment when making recommendations. We require that all representatives disclose this conflict of interest when such recommendations are made. Also, we require representatives to disclose that Clients may purchase recommended products from other registered representatives not affiliated with us. Item 6: Performance-Based Fees and Side-By- Side Management Fees are not based on a share of the capital gains or capital appreciation of managed securities. CFP 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 more risk to the client. We provide financial planning and portfolio management services to individuals and high net-worth individuals. We do not have a minimum account size requirement. Item 7: Types of Clients We practice both passive investment management and active investment management and our primary methods of investment analysis is technical analysis. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss 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. 9  Finally, a technical trading method may under perform other trading methods when fundamental factors dominate price moves within a given market. Passive Investment Management Passive investing involves building portfolios that are comprised 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. The funds that are used to build passive portfolios are typically index mutual funds or exchange traded funds. Passive investment management is characterized by low portfolio expenses (i.e. the funds inside the portfolio have low internal costs), minimal trading costs (due to infrequent trading activity), and relative tax efficiency (because the funds inside the portfolio are tax efficient and turnover inside the portfolio is minimal). In contrast, active management 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 designated benchmark. Academic research indicates most active managers underperform the market. 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 medium cap companies may face a greater risk of business failure, which could increase the volatility of the client’s portfolio. Turnover Risk: At times, the strategy may have a portfolio turnover rate that is higher than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect the account’s performance. Concentration Risk: Certain investment strategies focus on particular asset-classes, industries, sectors or types of investment. From time to time these strategies may be subject to greater risks of adverse developments in such areas of focus than a strategy that is more broadly diversified across a wider variety of investments. 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 10  price changes. Most other investments are also sensitive to the level and direction of interest rates. 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 such factors 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. 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. 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. Investment Companies Risk. 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). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. The Adviser has no control over the risks taken by the underlying funds in which clients 11  invest. Risks Associated Sub-advisory Services for ETF In addition to risks outlined above which apply to all types of investments, the following also apply to our ETF sub-advisory services: New Fund Risk The fund is recently organized with no operating history, as a result prospective investors do not have a track record or history on which to base their investment decision. There can be no assurance that the fund will grow or maintain an economically viable size. Political Criteria Risk Because we evaluate the political activity of companies in the Fund’s investment universe as part of its portfolio management process, we may forgo some market opportunities available to other funds that do not consider political factors. The fund’s consideration of political activity is a consideration of political activity may also prompt the Fund to sell a security at inappropriate times, which may cause the fund to underperform funds that do not evaluate companies based on political activity. Criminal or Civil Actions Item 9: Disciplinary Information CFP and its management have not been involved in any criminal or civil action. Administrative Enforcement Proceedings CFP and its management have not been involved in administrative enforcement proceedings. Self-Regulatory Organization Enforcement Proceedings CFP and its management have not been involved in legal or disciplinary events that are material to a client’s or prospective client’s evaluation of Advisor or the integrity of its management. No CFP employee is registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. Item 10: Other Financial Industry Activities and Affiliations No CFP employee is registered, or have an application pending to register, as a futures commission merchant, commodity pool operator or a commodity trading advisor. CFP does not have any related parties. We are the sub-adviser for an exchange traded fund, The God Bless America ETF (YALL) (“the Fund”). We select investments for the Fund from a universe of U.S. listed equity securities with market 12  capitalizations of at least $1 billion. From the initial investment universe, we eliminate companies that, in our assessment, have emphasized politically left and/or liberal political activism and social agendas at the expense of maximizing shareholder returns. For additional information please refer to the prospectus of YALL, available at https://www.godblessamericaetf.com/. Adam Curran is portfolio manager of The God Bless America ETF (YALL) since its inception in 2022. Mr. Curran is primary responsible for the day-to-day management of the fund. Associated persons at CFP are licensed to sell life and health insurance and may engage in product sales with our clients, for which CFP will receive additional compensation. This does create an incentive to recommend these products based on compensation and not client need, however careful review is done to ensure that recommendations are made in the best interests of the client. Any commissions received through life or health insurance sales do not offset advisory fees the client may pay for advisory services under CFP. Curran Financial Partners does not provide accounting advice or tax preparation services to clients directly. We have established a relationship with Tyson Accounting, LLC (“Tyson”) to provide clients access to Tyson’s accounting advice and/or tax preparation services. Clients should be aware that there is a service level agreement between Curran Financial Partners and Tyson Accounting, LLC, and the agreement provides Tyson will be compensated with the use of office space maintained by Curran for giving access to its tax services to our clients. Our clients are under no obligation to use Tyson for their tax form preparation and planning needs. Recommendations or Selections of Other Investment Advisers As briefly described in Item 4, we may engage third-party investment managers as part of the investment management process. We seek to only engage managers who are available through TD Ameritrade’s Unified Managed Account Exchange ("UMAX"). UMAX is a program which expands the types of investments independent registered investment advisors, like CFP, can offer to clients and provides more flexibility in how portfolios are managed. Through this program, the use of third-party managers may provide access to investment platforms not otherwise available to other investment Advisors (such as those requiring high investment minimums or institutional investment programs). The third-party investment managers may also offer specialized investment services or expertise in certain facets of investing. We and any selected third- party investment manager will work in tandem to manage the investments within the client’s account(s). We will perform analysis and due diligence on any third-party investment manager we may engage and will update its due diligence information no less than annually. We do not receive any additional compensation for the selection of third-party investment manager. We will continue to provide our own management services to investments allocated to one or more third-party investment managers and will continue to act as the client's primary investment advisor. Additionally, we will monitor the investment management services and performance of the selected third-party investment manager. In most cases, we and the selected third-party investment manager will manage only a portion of the client’s overall investment portfolio. In each case, we will consider the client's stated financial situation, expressed needs and objectives before utilizing the services of one or more unaffiliated independent investment management programs depending upon the client’s unique situation. We will utilize third-party investment managers based upon areas of expertise, experience, philosophies and other factors that formulate a suitable match, based upon 13  what we know about the client and our market outlook. The services of third-party investment managers are separate and distinct from the services provided by CFP. The selected third-party investment manager is responsible for providing the agreed upon financial and/or investment services, suitability and due diligence, portfolio reporting (if applicable), prompt correction of any trade errors and best execution within their respective programs and pursuant to their written agreement with clients. Insurance Product Recommendations Due to the CFP’s financial planning philosophy, it is common for our financial professionals to recommend that clients utilize insurance products (for example, a fixed index annuity (“FIA”)) as part of the client’s overall financial plan in lieu of separately managed accounts (specifically, in lieu of cash and fixed income asset classes). You should be aware that there are a number of conflicts of interests that are present due to our planning philosophy and recommendations to utilize insurance products in this nature. As an estimate, our financial professionals that are registered as investment advisor representatives spend approximately 50% of their time on insurance sales and services and 50% of their time on investment advisory services in the future. Please refer to Item 5 – Fees and Compensation for more details. You may therefore work with your financial professional in both their capacity as an investment adviser representative, as well as in their capacity as an insurance agent. As such, your CFP financial professional, in their dual capacity as an IAR and insurance agent, may advise you to purchase insurance products (general disability insurance, life insurance, annuities, and other insurance products to you), and then assist you in implementing the recommendations by selling you those same products. For the reasons described below, this creates a variety of conflicts of interest that you should be aware of. • Commissions: Although CFP and its investment adviser representatives owe you a fiduciary duty, it should be noted that the receipt of a commission provides a variety of incentives for our affiliate and our shared financial professionals to recommend these products. For example, your financial professional will earn a larger commission the more assets are invested in an annuity, therefore they are economically incentivized to recommend that you purchased an annuity over placing those assets in a brokerage or advisory account, which may provide lower total compensation. Our financial professional could also be incentivized to recommend a product that pays a commission now, versus an advisory product that pays fees over a longer period of time. As an example, all other variables held equal, a 5% commission paid by an insurance company upon sale of a $100,000 annuity product, may be more attractive to a financial professional than a one percent (1%) advisory fee charged on a $100,000 account paid over a period of five (5) years, despite the overall pre-tax compensation paid to the financial professional being equal. Note that some products pay a higher street or bonus commission than others, increasing this incentive and creating an economic incentive to favor higher fee-paying products. • Additional Compensation: CFP may also receive additional compensation or incentives in the form of bonus commissions, gifts, meals or entertainment, reimbursement for training, marketing, education, advertising, or travel expenses associated with sponsored conferences or events. The exact compensation cannot be accurately calculated at the time of recommendation because they 14  rely on sales goals, but you should be aware that there are a variety of forms of indirect compensation paid by carriers and insurance marketing organizations, and this compensation creates a conflict of interest. • In addition, each of the individual insurance carriers that our financial professionals work with may also separately provide incentive-based bonuses or awards in exchange for sales-related production over specific periods of time, which is a conflict of interest. They may also provide indirect compensation by providing marketing assistance, business development tools, technology, back office/operations support, business succession planning, business conferences, and incentive trips. These incentive programs do not directly affect fees paid by the client. Although some of these services can benefit a client, other services obtained by our IARs such as marketing assistance, business development, and incentive trips, will not benefit an existing client and is a conflict of interest. • from distributors of investment and/or At times, our financial professionals receive expense reimbursement for travel and/or marketing expenses insurance products. Travel expense reimbursements are a result of attendance at due diligence and/or investment training events hosted by product sponsors. Marketing expense reimbursements are the result of informal expense sharing arrangements in which product sponsors will underwrite costs incurred for marketing, such as client appreciation events, advertising, publishing, and seminar expenses. Although receipt of these travel and marketing expense reimbursements are not predicated upon specific sales quotas, the product sponsor reimbursements are made by those sponsors for which sales have been made or for which it is anticipated sales will be made. This creates a conflict of interest in that there is an incentive to recommend certain products and investments based on the receipt of this compensation instead of what is in the best interest of clients. • Exchanges & Replacement Recommendations: Your financial professional may recommend that you exchange or replace an existing annuity with a new annuity if they believe it is appropriate. You should be aware that the firm and financial professional receive additional commission when an exchange or replacement is made, in the form of commissions and bonuses, and other additional compensation described above. You may also incur a surrender charge on the old annuity. The new purchase be also subject to the commencement of a new surrender period, lose existing benefits, such as accumulated value, death, living or other contractual benefits, or be subject to increased fees, or additional charges for riders and similar product enhancements. • Other Issues: There are other conflicts present as well. CFP utilizes the services of a third-party insurance marketing organization ("IMO") to select the appropriate product for our clients. The purpose of the IMO is to assist us in finding the insurance product that best fits the client’s situation, although the IMO and insurance carrier may also offer special bonus or incentive compensation to our firm and our investment adviser representatives when they act in their separate capacities as insurance agents when they meet certain overall sales goals by placing annuities and/or other insurance products through the IMO. This creates a conflict of interest for the firm and our financial professionals in utilizing the products recommended by the IMO. 15  The sale of commission-based products is supervised by the firm’s President, and the firm makes periodic reviews of its insurance recommendations to ensure that our financial professionals act in accordance with our fiduciary duty. If you have any questions or concerns about annuity recommendations made during the financial planning process, we encourage you to immediately bring them to the attention of the President or the CCO. Finally, you should be aware that there are other insurance products that are offered by other insurance agents other than those recommended by our financial professionals. You are under no obligation to implement any insurance or annuity transaction through CFP. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading As a fiduciary, our firm and its associates have 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 basis of all our dealings. Code of Ethics Description This code does not attempt to identify all possible conflicts of interest, and literal compliance with each of its specific provisions will not shield associated persons from liability for personal trading or other conduct that violates a fiduciary duty to advisory clients. A summary of the Code of Ethics' Principles is outlined below. Integrity - Associated persons shall offer and provide professional services with integrity. • • Objectivity - Associated persons shall be objective in providing professional services to clients. • Competence - Associated 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 - Associated 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 - Associated 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 - Associated persons’ conduct in all matter shall reflect credit of the profession. • Diligence - Associated 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 16  firm access persons to attest to their understanding of and adherence to the Code of Ethics at least annually. Our firm will provide of 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 associates 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, etc. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest Our firm and its “related persons” may buy or sell securities similar to, or different from, those we recommend to clients for their accounts. To reduce or eliminate certain conflicts of interest involving the firm or personal trading, our policy requires the pre-clearance of associates’ transactions in specific reportable securities. Pre-clearance requests and any exceptions to the policy must be approved by the firm principal in advance of the transaction in an account, and we maintain the required personal securities transaction records per regulation. Trading Securities At/Around the Same Time as Client’s Securities From time to time, our firm or its “related persons” may buy or sell securities for themselves at or around the same time as clients. To reduce or eliminate certain conflicts of interest involving the firm or personal trading, our policy requires the pre-clearance of associates’ transactions in specific reportable securities. Preclearance may be denied if the frim principal determines that the transaction is inconsistent with the best interests of any client, including the Fund. Factors Used to Select Custodians and/or Broker-Dealers Item 12: Brokerage Practices Curran Financial Partners, LLC does not have any affiliation with Broker-Dealers. Specific custodian recommendations are made to client based on their need for such services. We recommend custodians based on the reputation and services provided by the firm. Curran Financial Partners, LLC recommends Charles Schwab & Co., Inc. Advisor Services. 1. Research and Other Soft-Dollar Benefits We currently do not receive soft dollar benefits. 2. Brokerage for Client Referrals We receive no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use We do recommend a specific custodian for clients to use, however, clients may custody their assets at a 17  custodian of their choice. Clients may also direct us to use a specific broker-dealer to execute transactions. By allowing clients to choose a specific custodian, we may be unable to achieve most favorable execution of client transaction and this may cost clients’ money over using a lower-cost custodian. Aggregating (Block) Trading for Multiple Client Accounts Outside Managers used by CFP may block client trades at their discretion. Their specific practices are further discussed in their ADV Part 2A, Item 12. For clients enrolled in our investment management service, we generally 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 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 persons associated with our firm may participate in block trading with your accounts; however, they will not be given preferential treatment. Item 13: Review of Accounts Client accounts with the Investment Management Service will be reviewed regularly at least on an annual basis by Adam Curran, President. The account is reviewed with regard to the client’s investment policies and risk tolerance levels. 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. Clients will receive trade confirmations from the broker(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. CFP will provide written reports by our Investment Management clients on an as requested basis. We urge clients to compare these reports against the account statements they receive from their custodian. Item 14: Client Referrals and Other Compensation Charles Schwab & Co., Inc. Advisor Services provides CFP with access to Charles Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. Advisor Services retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & 18  Co., Inc. Advisor Services includes brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For CFP client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset- based fees for securities trades that are executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co., Inc. Advisor Services accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to CFP other products and services that benefit CFP but may not benefit its clients’ accounts. These benefits may include national, regional or CFP specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services. Other potential benefits may include occasional business entertainment of personnel of CFP by Charles Schwab & Co., Inc. Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist CFP in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide 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, if applicable), provide research, pricing information and other market data, facilitate payment of CFP’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of CFP’s accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to CFP other services intended to help CFP manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, and human capital consultants, insurance and marketing. In addition, Charles Schwab & Co., Inc. Advisor Services may make available, arrange and/or pay vendors for these types of services rendered to CFP by independent third parties. Charles Schwab & Co., Inc. Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to CFP. CFP is independently owned and operated and not affiliated with Charles Schwab & Co., Inc. Advisor Services. CFP receives client referrals from SmartAsset, a lead generation firm, who is independent of and unaffiliated with the Advisor and its employees. SmartAsset does not supervise CFP and has no responsibility for CFP’s management of client portfolios or other advice or services. CFP pays SmartAsset a flat monthly subscription fee to be included on the SmartAsset Advisor Marketing Platform and to be connected with potential clients. CFP will not charge clients referred to through its relationship with SmartAsset any fees or costs higher than its standard fee schedule offered to its clients. For additional information regarding CFP’s relationship with SmartAsset, please contact us at curran@keybridgecompliance.com. 19 Item 15: Custody  CFP does not provide custodial services and encourages clients to work with a qualified custodian to custody their assets, typically Schwab. Under the Amended Custody Rule, CFP is deemed to have custody over certain client assets because of (1) its authority from most clients to directly deduct fees from the clients’ custodial accounts, and (2) its ability to disburse client funds to a third party as authorized by a standing letter of authorization (SLOA) given by the client. CFP does not accept custody of client funds. Clients should receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains client's investment assets. We urge you to carefully review such statements and compare such official custodial records to the account statements or reports that we may provide to you. Our statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. When clients choose to use Outside Managers for investment management, we will not exercise discretion for their accounts. Item 16: Investment Discretion For those client accounts where we provide investment management services, we maintain discretion over client accounts with respect to securities to be bought and sold and the amount of securities to be bought and sold. 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. Additionally, the discretionary relationship will be outlined in the advisory contract and signed by the client. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Item 17: Voting Client Securities We do not vote Client proxies. Therefore, Clients maintain exclusive responsibility for: (1) voting proxies, and (2) acting on corporate actions pertaining to the Client’s investment assets. The Client shall instruct the Client’s qualified custodian to forward to the Client copies of all proxies and shareholder communications relating to the Client’s investment assets. If the client would like our opinion on a particular proxy vote, they may contact us at the number listed on the cover of this brochure. In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward you any electronic solicitation to vote proxies. 20 Item 18: Financial Information  Balance Sheet A balance sheet is not required to be provided because CFP does not serve as a custodian for client funds or securities and CFP does not require prepayment of fees of more than $1,200.00 per client and six months or more in advance. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients In light of the COVID-19 coronavirus and historic decline in market values, CFP elected to participate in the CARES Act’s Paycheck Protection Program (“PPP”) to strengthen its balance sheet. CFP utilized this loan predominantly to continue payroll for the firm and ultimately obtained loan forgiveness per the terms of the PPP. Due to this and other measures taken internally, CFP was able to operate and continue serving its clients. Bankruptcy Petitions during the Past Ten Years Neither CFP nor its management has had any bankruptcy petitions in the last ten years. 21