FALCON WEALTH PLANNING, INC.

3400 Inland Empire Blvd. #100 Ontario, CA 91764 855-963-2526 Fax 844-822-4127 www.falconwealthplanning.com info@falconwp.com Registration does not imply a certain level of skill or training. Version Date: 05/01/2025 This brochure provides information about the qualifications and business practices of Falcon Wealth Planning, Inc.. If you have any questions about the contents of this brochure, please contact us at (855) 963-2526 or by email at: info@falconwp.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 Falcon Wealth Planning, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. Falcon Wealth Planning, Inc.’s CRD number is: 174092. i  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of Falcon Wealth Planning, Inc on February 20, 2025, are described below. Material changes relate to Falcon Wealth Planning, Inc.’s policies, practices or conflicts of interests. • • The firm updated its disclosures regarding fees and compensation. (Item 5) • The firm has updated its Assets Under Management. • The firm updated Items 4, 5 & 8 to disclose third party financial planning services. ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ....................................................................................................................................... ii Item 3: Table of Contents ...................................................................................................................................... iii Item 4: Advisory Business ......................................................................................................................................2 Item 5: Fees and Compensation .............................................................................................................................5 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 Investment Loss .......................................9 Item 9: Disciplinary Information .........................................................................................................................12 Item 10: Other Financial Industry Activities and Affiliations .........................................................................12 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...............13 Item 12: Brokerage Practices ................................................................................................................................14 Item 13: Reviews of Accounts ..............................................................................................................................15 Item 14: Client Referrals and Other Compensation ..........................................................................................16 Item 15: Custody ....................................................................................................................................................16 Item 16: Investment Discretion ............................................................................................................................16 Item 17: Voting Client Securities (Proxy Voting) ..............................................................................................17 Item 18: Financial Information .............................................................................................................................17 iii  Item 4: Advisory Business A. Description of the Advisory Firm Falcon Wealth Planning, Inc. (hereinafter “FWP”) is a Corporation organized in the State of California. The firm was formed in March 2015, and the principal owner is Gabriel Shahin through the Falcon Family Revocable Living Trust. B. Types of Advisory Services Portfolio Management Services FWP offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. FWP creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring FWP evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. FWP will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. FWP seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of FWP’s economic, investment or other financial interests. To meet its fiduciary obligations, FWP attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, FWP’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is FWP’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. In some cases, we use a third-party platform to manage held away assets such as defined contribution plan participant accounts on a discretionary basis. By using this platform, we will be able to effect trades in the accounts, but will not otherwise access have direct access to Client log-in credentials. We are not affiliated with the platform in any way and receive no compensation from them for using their platform; however we pay a fee to the third- party for use of its platform. A link will be provided to the Client allowing them to connect 2  an account(s) to the platform. Once a client account(s) is connected to the platform, FWP will review the current account allocations. When we deem it necessary, we will rebalance the account considering client investment goals and risk tolerance. Any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. We will review held away client account(s) at least quarterly and make allocation changes as deemed necessary. Falcon Wealth Family Office Service Service offering for FWP’s high net worth clients that have +$5 million under management. As part of our Family Office, FWP covers the expenses for the following ancillary services: 1. Tax (Preparation, filing, and planning done by Falcon Tax Services) 2. Estate (3rd party estate planning cost reimbursement for the review and drafting of estate planning documents) 3. Family Charitable Foundation (Formation, management, and filing costs) 4. Real Estate (Consulting on acquisition and management of real estate portfolio) 5. Insurance (Annual review of personal and property & casualty insurance policies) 6. Legacy (Education meetings with the next generation to prepare them to manage inheritance, develop a healthy relationship with money, and grow their financial literacy) Selection of Other Advisers FWP has discretion to choose third-party investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, FWP will always ensure those other advisers are properly licensed or registered as an investment adviser. FWP conducts due diligence on any third-party investment adviser, which may involve one or more of the following: phone calls, meetings and review of the third-party adviser's performance and investment strategy. FWP then makes investments with a third-party investment adviser by investing with the third-party adviser. FWP will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning, estate, budget, goal, cash flow planning; and debt/credit planning. 3  In offering financial planning, a conflict exists between the interests of the investment adviser and the interests of the client. The client is under no obligation to act upon the investment adviser's recommendation, and, if the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through the investment adviser. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions FWP offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent FWP from properly servicing the client account, or if the restrictions would require FWP to deviate from its standard suite of services, FWP reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. FWP does not participate in any wrap fee programs. E. Assets Under Management FWP has the following assets under management: 4  Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 1,126,475,119.00 $ 33,062,926.00 December 2024 Item 5: Fees and Compensation A. Fee Schedule Lower fees for comparable services may be available from other sources. Asset-Based Fees for Portfolio Management Total Assets Under Management Quarterly Fee $0 - $350,000 0.5000% $350,001 - $500,000 0.4375% $500,001 - $750,000 0.3750% $750,001 - $1,000,000 0.2875% $1,000,001 - $2,000,000 0.2500% $2,000,000 - $5,000,000 0.1875% $5,000,001 And Up 0.1625% Asset-based portfolio management fees are withdrawn directly from the client's accounts with the client's written authorization. Fees are paid in advance on a quarterly basis. The Fee Chart above references quarterly fees. For example, if the quarterly fee is 0.5000%, the annual fee would be 2.000%. For clients who signed their investment advisory agreements prior to June 2017, billing occurs in arrears. This exception is in place to honor the terms agreed upon at the time of signing, and these accounts are billed after the completion of the billing period. Generally, management fees are withdrawn directly from the client account that incurred said fees. This is the default billing method of billing. Fees may be withdrawn from a different account within the client’s household in limited circumstances. Clients will be informed about indirect fee billing prior to any withdrawals being performed. FWP charges fees on a tiered fee structure, meaning that we may apply multiple percentages to your assets under management to calculate our fee depending on the total amount of your assets under our management. For example, if your total assets under our 5  management are $400,000 and assuming we charge the maximum fee schedule, each quarter we will charge the first $350,000 at 0.5000% and the next $50,000 at 0.4375%. FWP will charge an additional 0.25% for all non-discretionary accounts. A $5,000 annual minimum fee will be applied if total investable assets are below $250,000. These fees are generally negotiable, and the final fee schedule is attached as an Exhibit to the Investment Advisory Contract. Clients may terminate the agreement without penalty for a full refund of FWP's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 30 days written notice. Falcon Wealth Family Office Service Fees Total Assets Under Management Quarterly Fee $0 - $5,000,000 0.25% $5,000,001- $10,000,000 0.1875% $10,000,001- $ 25,000,000 0.15% $25,000,001- $50,000,000 0.125% $50,000,001- $100,000,000 0.10% $100,000,001 And up 0.0625% Selection of Other Advisers Fees FWP will receive its standard fee on top of the fee paid to the third-party adviser. This relationship will be memorialized in each contract between FWP and each third-party adviser. The fees will not exceed any limit imposed by any regulatory agency. The notice of termination requirement and payment of fees for third-party investment advisers will depend on the specific third-party adviser selected. These fees are negotiable. FWP may engage in the selection of third-party money managers but does not have any such arrangements in place at this time. This service may be canceled with 5 days’ notice. Financial Planning Fees FWP charges hourly fees and annual fixed fees for financial planning. For clients who do not engage FWP for ongoing planning services, FWP charges $500/hour for the creation of a financial plan. For clients who engage FWP for ongoing planning services, FWP charges a minimum of $5,000 and then a minimum annual fee of at least $5,000 thereafter. 6  The annual fee may vary depending on the complexity of the client’s needs and will be specified in the Financial Planning Agreement. The fixed rate for creating a financial plan range from a minimum of $5,000 and up to $25,000+. The fixed fee for ongoing planning services is negotiable. FWP will bill clients for financial planning fees. After the initial fee for ongoing services, annual fixed fees may be paid in quarterly installments. Clients may terminate the agreement without penalty for a full refund of FWP's fees within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally upon written notice. Hourly and fixed planning fees are charged in advance but never more than six months in advance. Third Party Financial Planning When appropriate, FWP may utilize the services of third-party financial planning advisors to provide financial planning services to our clients. We assist clients in determining the suitability of a financial plan for them and we help facilitate the introduction to the Outside Advisor. Additionally, we monitor our clients on a periodic basis to understand changes in their personal or financial situation, suitability, and any new or revised restrictions to be applied to the account based on recommendations provided in their financial plan. We negotiate the fees collected by the Outside Advisors from our clients and we receive a share of those fees. We discuss our approach to evaluating and engaging with Outside Advisors further in Item 8: Method of Analysis, Investment Strategy, and Risk of Loss. B. Payment of Fees Payment of Asset-Based Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client’s accounts (or indirectly from an account in the client's household) with client’s written authorization on a quarterly basis. Fees are paid in advance (for client’s with pre-June 2017 agreements, fees are paid in arrears). Falcon Wealth Family Office Service Fees Falcon Wealth Family Office Service fees are withdrawn directly from the client’s accounts (or indirectly from an account in the client's household) with client’s written authorization on a quarterly basis. Fees are paid in advance (for client’s with pre-June 2017 agreements, fees are paid in arrears). Payment of Selection of Other Advisers Fees The timing, frequency, and method of paying fees for selection of third-party managers will depend on the specific third-party adviser selected. 7  Payment of Financial Planning Fees Financial planning fees are paid via check or credit card. Financial planning fees are paid in advance, but never more than six months in advance. Payment of Third Party Financial Planning Fees The timing, frequency, and method of paying fees for selection of third-party financial planning advisors will depend on the specific third-party financial planning advisor selected. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by FWP. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees FWP collects some fees in advance, as indicated above. Refunds for fees paid in advance will be returned within fourteen days to the client via check, or return deposit back into the client’s account. Fees will only be refunded if client provides FWP with a thirty-day written notice of termination. E. Outside Compensation For the Sale of Securities to Clients Neither FWP nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management FWP does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients FWP generally provides advisory services to the following types of clients: ❖ Individuals ❖ High-Net-Worth Individuals ❖ Charitable Organizations ❖ Corporations or Business Entities 8  Minimum Account Size There is no account minimum for any of FWP’s services. Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss A. Methods of Analysis and Investment Strategies Methods of Analysis FWP’s methods of analysis include fundamental analysis, technical analysis and modern portfolio theory. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Technical analysis involves the analysis of past market data, primarily price and volume. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Investment Strategies FWP uses long term trading, margin transactions and options trading (including covered options, uncovered options, or spreading strategies). Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. 9  Modern Portfolio Theory assumes that investors are risk adverse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Investment Strategies FWP's use of margin transactions and options trading generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Margin transactions use leverage that is borrowed from a brokerage firm as collateral. When losses occur, the value of the margin account may fall below the brokerage firm’s threshold thereby triggering a margin call. This may force the account holder to either allocate more funds to the account or sell assets on a shorter time frame than desired. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Selection of Other Advisers: Although FWP will seek to select only money managers who will invest clients' assets with the highest level of integrity, FWP's selection process cannot ensure that money managers will perform as desired and FWP will have no control over the day-to-day operations of any of its selected money managers. FWP would not necessarily be aware of certain activities at the underlying money manager level, including without limitation a money manager's engaging in unreported risks, investment “style drift” or even regulator breach or fraud. Outside Managers: FWP may refer clients to third-party financial planning advisors. Our analysis of Outside Managers involves the examination of the reputation, experience, expertise, investment philosophies, and client satisfaction of the Outside Managers to try and determine if the Outside Manager has demonstrated an ability to serve our client base with comprehensive, personalized, actionable, and suitable financial plans. While we do not control the recommendations the Outside Manager's makes, we partner with the Outside Manager to make sure that the investment philosophies and the method of analysis align with our own. We further monitor the Outside Manager's recommendations 10  on an ongoing basis as well as our clients' satisfaction from the overall experience as part of our overall periodic risk assessment. There is a risk that an Outside Manager may deviate from their stated investment philosophy, making it a less suitable investment for our clients. Moreover, as we do not control the Outside Manager's daily business and compliance operations, we may be unaware of the lack of internal controls necessary to prevent business, regulatory or reputational deficiencies. As part of our due diligence process, we survey the Outside Manager's systems, compliance processes, and other business operations risks to mitigate these risks. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized FWP's use of margin transactions and options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best-known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of 11  transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions a. There are no criminal or civil actions to report. B. Administrative Proceedings a. There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings a. There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative a. Neither FWP nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. 12  B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor a. Neither FWP nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests a. Gabriel Shahin is the General Partner and a Business Consultant of Falcon Wealth Tax Services, an accounting firm. From time to time, he may offer clients advice or products from those activities and clients should be aware that these services may involve a conflict of interest. Falcon Wealth Planning, Inc. always acts in the best interest of the client and clients always have the right to decide whether or not to utilize the services of any representative of Falcon Wealth Planning, Inc. in such individual’s outside capacities. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections FWP has discretion to choose third-party investment advisers to manage all or a portion of the client's assets. Clients will pay FWP its standard fee in addition to the standard fee for the advisers to which it directs those clients. This relationship will be memorialized in each contract between FWP and each third-party advisor. The fees will not exceed any limit imposed by any regulatory agency. FWP will always act in the best interests of the client, including when determining which third-party investment adviser to recommend to clients. FWP will ensure that all recommended advisers are licensed or notice filed in the states in which FWP is recommending them to clients. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics FWP has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. FWP's Code of Ethics is available free upon request to any client or prospective client. 13  B. Recommendations Involving Material Financial Interests FWP does not recommend that clients buy or sell any security in which a related person to FWP or FWP has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of FWP may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of FWP to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, FWP will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities Please see Item 11.C above. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on FWP’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and FWP may also consider the market expertise and research access provided by the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in FWP's research efforts. FWP will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. 1. Research and Other Soft-Dollar Benefits FWP does not receive soft dollar benefits from any broker-dealer or third-party. 2. Brokerage for Client Referrals FWP receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 14  3. Clients Directing Which Broker/Dealer/Custodian to Use FWP will require clients to use one or more of the following broker-dealers: Fidelity Brokerage Services LLC, Charles Schwab & Co. Inc., Ameritas Investment Company, TIAA-CREF Institutional Services, Altruist Financial LLC, MTG, LLC dba Betterment Securities and Apex Clearing Corporation. B. Aggregating (Block) Trading for Multiple Client Accounts If FWP buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, FWP would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. FWP would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). Item 13: Reviews of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for FWP's advisory services provided on an ongoing basis are reviewed at least quarterly by Gabriel A. Shahin, (Principal), the CCO, or designated Associates with regard to clients’ respective investment policies and risk tolerance levels. All accounts at FWP are assigned to this reviewer. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Gabriel A Shahin, Principal. There is only one level of review for financial planning, and that is the total review conducted to create the financial plan. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). With respect to financial plans, FWP’s services will generally conclude upon delivery of the financial plan. C. Content and Frequency of Regular Reports Provided to Clients Each client of FWP's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and 15  calculation of fees. This written report will come from the custodian. FWP will also provide at least quarterly a separate written statement to the client. Each financial planning client will receive the financial plan upon completion. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) FWP does not receive any economic benefit, directly or indirectly from any third party for advice rendered to FWP's clients. B. Compensation to Non – Advisory Personnel for Client Referrals FWP will, in some cases, compensate third parties via written agreement to refer clients to FWP. FWP currently has an arrangement in place with Zoe Financial Inc. All compensation with respect to the foregoing will be fully disclosed to each client to the extent required by applicable law. FWP will ensure each third party is properly registered in all appropriate jurisdictions. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, FWP will be deemed to have custody of client's assets and must have written authorization from the client to do so. Clients will receive account statements from the custodian and they should carefully review those statements for accuracy. Because client fees will be withdrawn directly from client accounts, FWP will: (A) possess written authorization from the client to deduct advisory fees from an account held by a qualified custodian, and (B) verify that the qualified custodian sends invoices to the client at least quarterly. Item 16: Investment Discretion FWP provides discretionary and non-discretionary investment advisory services to clients. The Investment Advisory Contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, FWP generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. Where FWP does not have discretionary authority to place trade orders, FWP will secure client permission prior to effecting securities transactions for the client’s account. 16  FWP may also accept discretionary authority to determine the broker or dealer to be used for a purchase or sale of securities for a client's account. Item 17: Voting Client Securities (Proxy Voting) FWP accepts proxy voting authority and acknowledges its fiduciary obligation to vote proxies on behalf of those clients that have delegated such authority to it. FWP will vote proxies on behalf of a client solely in the best interest of the client. FWP has established general guidelines for voting proxies. FWP may also abstain from voting if, based on factors such as expense or difficulty of exercise, it determines that a client’s interests are better served by abstaining. Further, because proxy proposals and individual company facts and circumstances may vary, FWP may vote in a manner that is contrary to the general guidelines if it believes that it would be in a client’s best interest to do so. If a proxy proposal presents a conflict of interest between FWP and a client, then FWP will disclose the conflict of interest to the client prior to the proxy vote and, if participating in the vote, will vote in accordance with the client’s wishes. Clients may obtain a complete copy of FWP’s proxy voting policies and procedures by emailing FWP at the email address on the cover page of this brochure and requesting such information. Each client may also request in a similar manner, information concerning how FWP cast proxy votes with respect to securities held by the client during the prior annual period. Item 18: Financial Information A. Balance Sheet FWP neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. The firm has no financial conditions that are reasonably likely to impair its ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years FWP has not been the subject of a bankruptcy petition in the last ten years. 17