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DISCLOSURE BROCHURE
Office Address:
11375 Robinson Drive Suite 200
Coon Rapids, MN 55433-23699
Tel: 763-231-2760
Fax: 763-231-2770
clientservice@ffpwealth.com
www.FFPwealth.com
May 1, 2025
This brochure provides information about the qualifications and business practices of FFP Wealth
Management, LLC. Being registered as an investment adviser does not imply a certain level of skill or
training. If you have any questions about the contents of this brochure, please contact us at 763-231-
2760. 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 FFP Wealth Management, LLC (CRD #300253) is available on the SEC’s website at
www.adviserinfo.sec.gov
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Item 2: Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material changes occur
since the previous release of the Firm Brochure.
Material Changes since the Last Update
Since the last filing of this brochure on February 28, 2025, the following material changes have been
made:
•
Item 4 and 5 have been updated to remove information on Model Portfolios as a service to
clients.
•
Item 4 to update the assets under management for the firm.
•
Item 7 to update the account minimum.
•
Item 13 to update the individuals who perform account reviews.
•
Item 14 to update the economic benefits section.
Full Brochure Available
This Firm Brochure being delivered is the complete brochure for the Firm.
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Item 3: Table of Contents
Form ADV – Part 2A – Firm Brochure
Item 1: Cover Page
Item 2: Material Changes .................................................................................................................... ii
Annual Update ................................................................................................................................................. ii
Material Changes since the Last Update ............................................................................................... ii
Full Brochure Available ............................................................................................................................... ii
Item 3: Table of Contents .................................................................................................................... 3
Item 4: Advisory Business .................................................................................................................. 6
Firm Description ............................................................................................................................................ 6
Types of Advisory Services ........................................................................................................................ 6
Item 5: Fees and Compensation ....................................................................................................... 8
Method of Compensation and Fee Schedule........................................................................................ 8
Client Payment of Fees ...............................................................................................................................10
Additional Client Fees Charged ..............................................................................................................10
Wrap Fee Programs ....................................................................................................................................10
Prepayment of Client Fees ........................................................................................................................11
External Compensation for the Sale of Securities to Clients .......................................................11
Item 6: Performance-Based Fees and Side-by-Side Management ...................................... 11
Sharing of Capital Gains .............................................................................................................................11
Item 7: Types of Clients ..................................................................................................................... 11
Description .....................................................................................................................................................11
Account Minimums .....................................................................................................................................11
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .............................. 11
Methods of Analysis ....................................................................................................................................11
Investment Strategy ....................................................................................................................................11
Security Specific Material Risks .............................................................................................................12
Item 9: Disciplinary Information ................................................................................................... 13
Criminal or Civil Actions ...........................................................................................................................13
Administrative Enforcement Proceedings .........................................................................................13
Self-Regulatory Organization Enforcement Proceedings .............................................................13
Item 10: Other Financial Industry Activities and Affiliations ............................................. 13
Broker-Dealer or Representative Registration ................................................................................13
Futures or Commodity Registration .....................................................................................................13
Material Relationships Maintained by this Advisory Business and Conflicts of Interest 13
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Recommendations or Selections of Other Investment Advisors and Conflicts of Interest
.............................................................................................................................................................................13
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading ................................................................................................................................................... 13
Code of Ethics Description .......................................................................................................................13
Investment Recommendations Involving a Material Financial Interest and Conflict of
Interest .............................................................................................................................................................14
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest .............................................................................................................................................................14
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Transactions and Conflicts of Interest .................................................................................................14
Item 12: Brokerage Practices ......................................................................................................... 15
Factors Used to Select Broker-Dealers for Client Transactions .................................................15
Aggregating Securities Transactions for Client Accounts ............................................................15
Item 13: Review of Accounts ........................................................................................................... 15
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved ..........................................................................................................................................15
Review of Client Accounts on Non-Periodic Basis ..........................................................................15
Content of Client Provided Reports and Frequency .......................................................................16
Item 14: Client Referrals and Other Compensation ................................................................ 16
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts
of Interest ........................................................................................................................................................16
Advisory Firm Payments for Client Referrals ...................................................................................16
Item 15: Custody .................................................................................................................................. 16
Account Statements ....................................................................................................................................16
Item 16: Investment Discretion ..................................................................................................... 17
Discretionary Authority for Trading ....................................................................................................17
Item 17: Voting Client Securities ................................................................................................... 18
Proxy Votes ....................................................................................................................................................18
Item 18: Financial Information ...................................................................................................... 18
Balance Sheet .................................................................................................................................................18
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
Commitments to Clients ............................................................................................................................18
Bankruptcy Petitions during the Past Ten Years .............................................................................18
Material Relationship Maintained by this Advisory Business or Management persons
with Issuers of Securities ..........................................................................................................................18
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Brochure Supplement (Part 2B of Form ADV) .......................................................................... 20
Principal Executive Officer - Tiffany K. Brynteson-Johnson, CRPC® ........................................20
Item 2 Educational Background and Business Experience .........................................................20
Professional Certifications .......................................................................................................................20
Item 3 Disciplinary Information ............................................................................................................21
Item 4 Other Business Activities ............................................................................................................21
Item 5 Additional Compensation ...........................................................................................................21
Item 6 Supervision ......................................................................................................................................21
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 23
Additional Investment Advisor Representative - Anthony G. Rush .........................................23
Item 2 Educational Background and Business Experience .........................................................23
Item 3 Disciplinary Information ............................................................................................................23
Item 4 Other Business Activities ............................................................................................................23
Item 5 Additional Compensation ...........................................................................................................23
Item 6 Supervision ......................................................................................................................................23
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Item 4: Advisory Business
Firm Description
FFP Wealth Management, LLC (hereinafter “FFP”) was founded in 2019. Tiffany
Brynteson-Johnson and Anthony Rush are each 50% owner.
FFP has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts:
$233,283,585
$1,085,955
Date Calculated:
April 28, 2025
FFP Wealth Management, LLC is a fee-only registered investment advisor that has taken a
fiduciary oath to act in the best interest of their Clients with integrity and candor. Whether
it is regarding financial planning or wealth management, FFP operates with a high level of
professionalism, fairness, and transparency.
FFP is strictly a fee-only financial planning and investment management firm. The firm
does not receive commissions for purchasing or selling annuities, insurance, stocks,
bonds, mutual funds, limited partnerships, or other commissioned products. The firm is
not affiliated with entities that sell financial products or securities. No commissions or
finder’s fees in any form are accepted.
FFP provides personalized confidential financial planning and investment management to
individuals, pension and profit-sharing plans, trusts, estates, charitable organizations and
small businesses. Advice is provided through consultation with the Client and may
include determination of financial objectives, identification of financial problems, cash
flow management, tax planning, insurance review, investment management, education
funding, retirement planning, and estate planning.
Investment advice is an integral part of financial planning. In addition, FFP advises clients
regarding cash flow, college planning, retirement planning, tax planning, inheritance and
estate planning.
The initial consultation, which may be by telephone, is complementary and is considered
an exploratory interview to determine the extent to which financial planning and
investment management may be beneficial to the client.
Types of Advisory Services
FFP provides investment supervisory services, also known as asset management services;
furnishes investment advice through consultations.
FFP may furnish advice to Clients on matters not involving securities, such as financial
planning matters, taxation issues, and trust services that often include estate planning
concepts.
Clients may choose to have FFP manage their assets in order to obtain ongoing in-depth
advice and life planning. A wide range of aspects of the Client’s financial affairs are
reviewed. Realistic and measurable goals are set and objectives to reach those goals are
defined. As goals and objectives change over time, suggestions are made and implemented
on an ongoing basis.
The scope of work and fee for an Advisory Service Agreement is provided to the Client in
writing prior to the start of the relationship. An Advisory Service Agreement is in addition
to financial planning such as: cash flow management; insurance review; investment
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management (including performance reporting); education planning; retirement
planning; inheritance planning; estate planning; income tax planning and tax preparation,
as well as the implementation of recommendations within each area.
Clients may execute a financial planning agreement as a part of the Advisory service
process with the investment management agreement being signed separately.
FFP determines the Client’s goals and objectives during the planning process, ultimately
determining if FFP provides services appropriate to the Client’s needs. If it is determined
that FFPs services are not in line with the Clients goals and objectives, we will decline the
engagement. Clients may impose restrictions on investing in certain securities or types of
securities.
Agreements may not be assigned without written Client consent.
ASSET MANAGEMENT
FFP’s Fiduciary Oath is present throughout the entire investment management
relationship with each Client. Upon retention of discretionary direct asset management
services, FFP will offer Clients ongoing portfolio management services through
determining individual investment goals, time horizons, objectives, and risk tolerance.
Investment strategies, investment selection, asset allocation, portfolio monitoring, and
the overall investment program will be based on the above factors. The Client will
authorize FFP discretionary authority to execute selected
investment program
transactions, as stated within the Investment Advisory Agreement.
Assets are invested primarily in no-load mutual funds and exchange-traded funds, usually
through discount brokers or fund companies. Fund companies charge each fund
shareholder an investment management fee that is disclosed in the fund prospectus.
Discount brokerages may charge a transaction fee for the purchase of some funds.
Stocks and bonds may be purchased or sold through a brokerage account when
appropriate. The brokerage firm charges a fee for stock and bond trades. FFP does not
receive any commissions for the sale of stocks and bonds.
Investments may also include equities (stocks), warrants, corporate debt securities,
commercial paper, certificates of deposit, municipal securities, investment company
securities (variable life insurance, variable annuities, and mutual funds shares), U. S.
government securities, options contracts, futures contracts, and interests in partnerships.
Initial public offerings (IPOs) are not available through FFP.
FINANCIAL PLANNING AND CONSULTING
FFP upholds the duty to ensure that its investment advice is suitable to each Client’s
objectives, needs, and circumstances. A financial plan is tailored to help each Client with
all aspects of financial planning without requiring ongoing investment management after
the financial plan is completed.
The financial plan may include, but is not limited to: a net worth statement; a cash flow
statement; a review of investment accounts, including reviewing asset allocation and
providing repositioning recommendations; strategic tax planning; a review of retirement
accounts and plans including recommendations; a review of insurance policies and
recommendations for changes, if necessary; one or more retirement scenarios; estate
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funding
planning review and recommendations; and education planning with
recommendations.
Advice regarding investments and recommendations regarding their finances are
provided as part of a financial plan. Implementation of the recommendations is at the
discretion of the Client.
The scope of work and fee for an Advisory Service Agreement is provided to the Client in
writing prior to the start of the relationship. An Advisory Service Agreement is in addition
to financial planning such as: cash flow management; insurance review; investment
management (including performance reporting); education planning; retirement
planning; inheritance planning; estate planning; income tax planning and tax preparation,
as well as the implementation of recommendations within each area.
A Client may execute a financial planning agreement and continue with the Advisory
Service process with the investment management agreement being signed separately.
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
FFP’s policy is to charge fair and competitive advisory fees and to disclose such fees fully
and accurately to Clients and prospective Clients. FFP bases its fees on a percentage of
assets under management, hourly charges and/or fixed fees.
FULL SERVICE ASSET MANAGEMENT fees include Financial Planning and Consulting
Services with regards to the assets under management. Additional fees may apply for
financial planning and consulting regarding assets outside of the Advisor, or the
circumstances beyond the scope of the Client’s finances. Some Retainer Agreements may
be priced based on the complexity of work, especially when asset management is not the
most significant part of the relationship.
Financial plans are priced according to the degree of complexity associated with the
Client’s situation. Fees are negotiable at the sole discretion of the Advisor.
FULL SERVICE ASSET MANAGEMENT
The annual Advisory Service Agreement fee is based on a percentage of the investable
assets according to the following schedule:
Investment Management Fees
Marginal Fee Table
$3,750 for the portion from 0 up to $250,000
plus
1.25% of the portion over $250,000 and up to $500,000
plus
1.00% of the portion over $500,000 and up to $750,000
plus
0.75% of the portion over $750,000 and up to $2,000,000
plus
0.50% of the portion over $2,000,000 and up to $5,000,000 plus
0.35% of the portion over $5,000,000
The minimum annual fee is $3,750 and is negotiable. Existing Client relationships may
exist where the fees are higher or lower than the fee schedule above.
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It is FFP’s policy not to charge any performance-based fees. Instead on a quarterly basis,
the fees for the accounts that are engaged in our advisory investment services, are
prorated one fourth of the annual fee across all accounts listed under Exhibit A of the
investment agreement. The total is applied to the above marginal brackets to determine
the annual management fee which is aggregated and collected each quarter in advance.
CALCULATING THE ASSET MANAGEMENT FEE
The minimum fee of $3,750 applies to the amount up to $250,000.
The 1.25% fee applies to the amount over $250,000 and up to $500,000 and is in addition
to the amount in the prior bracket of $3,750.
The 1.00% fee applies to the amount over $500,000 and up to $750,000 and is in addition
to the aggregated amounts in the prior two brackets of $3,750 and $3,125.
The 0.75% fee applies to the amount over $750,000 and up to $2,000,000 and is in
addition to the aggregated amounts in the prior three brackets of $3,750, $3,125, and
$2,500.
The 0.50% fee applies to the amount over $2,000,000 and up to $5,000,000 and is in
addition to the aggregated amounts in the prior four brackets of $3,750 and $3,125 and
$2,500 and $9,375.
The 0.35% fee applies to the amount over $5,000,000 and is in addition to the five prior
brackets of $3,750, $3,125, $2,500, $9,375 and $15,000.
Although the Advisory Service Agreement is an ongoing agreement and constant
adjustments are required, the length of service to the Client is at the Client’s discretion.
The Client or the investment manager may terminate an Agreement by written notice to
the other party. At termination, fees will be billed on a pro rata basis for the portion of the
quarter completed. The portfolio value at the completion of the prior full billing quarter
is used as the basis for the fee computation, adjusted for the number of days during the
billing quarter prior to termination. There will be a $150 account termination fee to cover
all additional work and time needed to communicate with the custodian regarding
payment of final fees, closing the account(s), potential trades and processing our internal
termination procedures. In addition, the Client agrees that by the virtue of the effort put
forth by Advisor to acquire a Client, to pay a fee equal to 1% of the assets under
management, but not less than $2,000 and not more than $5,000 as an early termination
fee if the agreement is terminated before the end of the 24th month beginning with the
first month following the execution date of this agreement.
FINANCIAL PLANNING AND CONSULTING
A financial plan is tailored based on each Client’s specific objectives, needs, and
circumstances. The plan will either be a fixed fee with a deposit payable upon signing the
Advisory Agreement, with the balance due upon plan delivery, or an hourly fee for follow
up work. The typical fee for a financial plan is predicated upon the facts known at the start
of the engagement. The fees could range from $2,500 to $25,000 and are negotiable. Since
financial planning is a discovery process, situations occur wherein the Client is unaware
of certain financial exposures or predicaments.
In the event that the Client’s situation is substantially different than disclosed at the initial
meeting, a revised fee will be provided for mutual agreement. The Client must approve
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the change of scope in advance of the additional work being performed when a fee
increase is necessary.
After delivery of a financial plan, future face-to-face meetings may be scheduled as
necessary for up to one month without
incurring additional fees. Follow-on
implementation work may be billed separately at the rate of $250 per hour.
FFP provides hourly planning and consulting services for Clients who need advice on a
limited scope of work. The hourly rate for limited scope engagements is $250.
FFP reserves the right to stop work on any account that is more than 30 days overdue. In
addition, FFP reserves the right to terminate any financial planning engagement where a
Client has willfully concealed or has refused to provide pertinent information about
financial situations when necessary and appropriate, in FFP’s judgment, to providing
proper financial advice. Any unused portion of fees collected in advance will be refunded
within 90 days.
Client Payment of Fees
Investment management fees are billed quarterly, in ADVANCE, meaning that the Client’s
fee covers the period until the end of the calendar quarter. For example, the fee paid on
April 5th covers the period from April 1st until June 30th. Payment in full is expected upon
invoice presentation. Fees are usually deducted from a designated Client account to
facilitate billing. The Client must consent in advance to direct debiting of their investment
account.
Fees for most financial plans are usually billed in two installments. Typically, a $500
retainer fee is billed in advance with the balance of the total agreed upon planning fee
billed due upon delivery of the financial plan. More complicated cases may require larger
fees in advance.
Additional Client Fees Charged
Custodians may charge transaction fees on purchases or sales of certain mutual funds and
exchange-traded funds. The selection of the security is more important than the nominal
fee that the custodian charges to buy or sell the security. The custodian may have other
fees and charges including custody fees, statement fees, termination fees or other fees.
FFP, in its sole discretion, may waive its minimum fee and/or charge a lesser investment
advisory fee based upon certain criteria (e.g., historical relationship, type of assets,
anticipated future earning capacity, anticipated future additional assets, dollar amounts
of assets to be managed, related accounts, account composition, negotiations with Clients,
etc.).
Mutual funds generally charge a management fee for their services as investment
managers. The management fee is called an expense ratio. For example, an expense ratio
of 0.50 means that the mutual fund company charges 0.5% for their services. These fees
are in addition to the fees paid by you to FFP or the custodian.
Performance figures quoted by mutual fund companies in various publications are after
their fees have been deducted.
For more details on the brokerage practices, see Item 12 of this brochure.
Wrap Fee Programs
FFP does not sponsor any wrap fee programs.
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Prepayment of Client Fees
FFP does not require prepayment of fees of more than $1,200 per Client and six months
or more in advance.
External Compensation for the Sale of Securities to Clients
FFP does not receive any external compensation for the sale of securities to Clients, nor
do any of the investment advisor representatives of FFP.
Item 6: Performance-Based Fees and Side-by-Side Management
Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of managed
securities.
FFP does not use a performance-based fee structure because of the conflict of interest.
Performance based compensation may create an incentive for the adviser to recommend
an investment that may carry a higher degree of risk to the Client.
Item 7: Types of Clients
Description
FFP generally provides investment advice to individuals. FFP may advise pension and
profit sharing plans, trusts, estates, charitable organizations, corporations or business
entities.
Client relationships vary in scope and length of service.
Account Minimums
The FULL SERVICE ASSET MANAGEMENT minimum account size is $500,000.
FFP has the discretion to waive the account minimum.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Security analysis methods may include charting, fundamental analysis, technical analysis,
and cyclical analysis.
The main sources of information may include: financial newspapers and magazines,
inspections of corporate activities, research materials prepared by others, corporate
rating services, timing services, annual reports, prospectuses, filings with the Securities
and Exchange Commission, and company press releases.
Other sources of information that FFP may use include Bloomberg, CNBC, CSPAN, articles,
radio and television broadcast; YCharts, Morningstar, Institutional Research Partners, and
the World Wide Web.
Investment Strategy
The primary investment strategy used on Client accounts is strategic asset allocation
utilizing a core and satellite approach. This means that we use a target portfolio allocation
and then modify it on a per Client basis. Our primary focus is on income, with a secondary
focus on growth. Portfolios are diversified to attempt to control the risk associated with
individual markets.
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The investment strategy for a specific Client is based upon the objectives stated by the
Client during consultations. The Client may change these objectives at any time.
Security Specific Material Risks
All investment programs have certain risks that are borne by the investor. Fundamental
analysis may involve interest rate risk, market risk, business risk, and financial risk. Risks
involved in technical analysis are inflation risk, reinvestment risk, and market risk.
Cyclical analysis involves inflation risk, market risk, and currency risk.
Our investment approach constantly keeps the risk of loss in mind. Investors face the
following investment risks and should discuss these risks with FFP:
•
Interest-rate Risk: Fluctuations in interest rates may also cause investment prices
to fluctuate. For example, when interest rates rise, yields on existing bonds
become less attractive, which can cause their market values to decline.
• Market Risk: The price of a security, bond, or mutual fund may drop in reaction to
tangible and intangible events and conditions. This type of risk can be caused by
external factors independent of a security’s particular underlying circumstances.
For example, political, economic and social conditions may trigger market events.
•
Inflation Risk: When any type of inflation is present, a dollar today might buy more
than a dollar next year, because purchasing power can erode at a similar rate of
inflation.
• Currency Risk: Overseas investments can be subject to fluctuations in the value of
the dollar against the currency of the investment’s originating country. This is also
referred to as exchange rate risk.
• Reinvestment Risk: This is the risk that future proceeds from investments may
have to be reinvested at a potentially lower rate of return (i.e. interest rate). This
primarily relates to fixed income securities.
• Business Risk: These risks are associated with a particular industry or a particular
company within an industry. For example, oil-drilling companies depend on
finding oil and then refining it, which can be a lengthy process, before they can
generate a profit. They can carry a higher risk of profitability than an electric
company which generates its income from a steady stream of customers who buy
electricity, which typically doesn’t fluctuate based on how the economic
environment is trending.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash.
Generally, assets are more liquid if many traders are interested in a standardized
product. For example, Treasury Bills are highly liquid, while real estate properties
are typically not.
• Financial Risk: Excessive borrowing to finance a business’ operations can increase
the risk of profitability, because the company must meet the terms of its
obligations in good times and bad. During periods of financial stress, the inability
to meet loan obligations may result in bankruptcy and/or a declining market
value.
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Item 9: Disciplinary Information
Criminal or Civil Actions
The firm and its management have not been involved in any criminal or civil action.
Administrative Enforcement Proceedings
The firm and its management have not been involved in administrative enforcement
proceedings.
Self-Regulatory Organization Enforcement Proceedings
The firm and its management have not been involved in legal or disciplinary events
related to past or present investment Clients.
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer or Representative Registration
The firm is not registered as a broker dealer and no affiliated representatives of FFP are
registered representatives of a broker-dealer.
Futures or Commodity Registration
Neither FFP nor its employees are registered or have an application pending to register
as a futures commission merchant, commodity pool operator, or a commodity trading
advisor.
Material Relationships Maintained by this Advisory Business and Conflicts of
Interest
FFP also provides tax preparation services separate from advisory services. Tax services
will be offered to advisory Clients for an additional fee separate from advisory fees.
This situation creates a conflict of interest because it gives an incentive to recommend
services bases on the fees received. This conflict is mitigated by disclosures, and the firm’s
Fiduciary obligation to place the best interest of the Client first and the Clients are not
required to purchase any products or services. Clients have the option to purchase these
services through another tax professional of their choosing.
Recommendations or Selections of Other Investment Advisors and Conflicts of
Interest
FFP does not recommend or select other investment advisors.
Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
Code of Ethics Description
The employees of FFP have committed to a Code of Ethics (“Code”). The purpose of our
Code is to set forth standards of conduct expected of FFP employees and addresses
conflicts that may arise. The Code defines acceptable behavior for employees of FFP. The
Code reflects FFP and its supervised persons’ responsibility to act in the best interest of
their Client.
One area which the Code addresses is when employees buy or sell securities for their
personal accounts and how to mitigate any conflict of interest with our Clients. We do not
13
allow any employees to use non-public material information for their personal profit or
to use internal research for their personal benefit in conflict with the benefit to our Clients.
FFP’s policy prohibits any person from acting upon or otherwise misusing non-public or
inside information. No advisory representative or other employee, officer or director of
FFP may recommend any transaction in a security or its derivative to advisory Clients or
engage in personal securities transactions for a security or its derivatives if the advisory
representative possesses material, non-public information regarding the security.
FFP’s Code is based on the guiding principle that the interests of the Client are our top
priority. FFP’s officers, directors, advisors, and other employees have a fiduciary duty to
our Clients and must diligently perform that duty to maintain the complete trust and
confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s
interests over the interests of either employees or the company.
The Code applies to “access” persons. “Access” persons are employees who have access to
non-public information regarding any Clients' purchase or sale of securities, or non-public
information regarding the portfolio holdings of any reportable fund, who are involved in
making securities recommendations to Clients, or who have access to such
recommendations that are non-public.
The firm will provide a copy of the Code of Ethics to any Client or prospective Client upon
request.
Investment Recommendations Involving a Material Financial Interest and Conflict
of Interest
FFP and its employees do not recommend to Clients, securities in which we have a
material financial interest.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts
of Interest
FFP and its employees may buy or sell securities that are also held by Clients. In order to
mitigate conflicts of interest such as trading ahead of Client transactions, employees are
required to disclose all reportable securities transactions as well as provide FFP with
copies of their brokerage statements.
The Chief Compliance Officer of FFP is Tiffany Brynteson-Johnson. The CCO reviews all
employee trades each quarter. Her trades are reviewed by Anthony Rush. The personal
trading reviews ensure that the personal trading of employees does not affect the markets,
and that Clients of the firm receive preferential treatment. Since most employee trades
are small mutual fund trades or exchange-traded fund trades, the trades typically do not
affect the securities markets.
Client Securities Recommendations or Trades and Concurrent Advisory Firm
Securities Transactions and Conflicts of Interest
FFP does not maintain a firm proprietary trading account and does not have a material
financial interest in any securities being recommended and therefore no conflicts of
interest exist. However, employees may buy or sell securities at the same time they buy
or sell securities for Clients. In order to mitigate conflicts of interest such as front running,
employees are required to disclose all reportable securities transactions as well as
provide FFP with copies of their brokerage statements.
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Item 12: Brokerage Practices
Factors Used to Select Broker-Dealers for Client Transactions
FFP may recommend the use of a particular broker-dealer or may utilize a broker-dealer
of the Client's choosing. FFP will select appropriate brokers based on a number of factors
including but not limited to their relatively low transaction fees and reporting ability. FFP
relies on its broker to provide its execution services at the best prices available. Lower
fees for comparable services may be available from other sources. Clients pay for any and
all custodial fees in addition to the advisory fee charged by FFP.
• Directed Brokerage
In circumstances where a Client directs FFP to use a certain broker-dealer, FFP still
has a fiduciary duty to its Clients. The following may apply with Directed Brokerage:
FFP's inability to negotiate commissions, to obtain volume discounts, there may be a
disparity in commission charges among Clients and conflicts of interest arising from
brokerage firm referrals.
• Best Execution
Investment advisors who manage or supervise Client portfolios on a discretionary
basis have a fiduciary obligation of best execution. The determination of what may
constitute best execution and price in the execution of a securities transaction by a
broker involves a number of considerations and is subjective. Factors affecting
brokerage selection include the overall direct net economic result to the portfolios,
the efficiency with which the transaction is affected, the ability to affect the
transaction where a large block is involved, the operational facilities of the broker-
dealer, the value of an ongoing relationship with such broker and the financial
strength and stability of the broker. The firm does not receive any portion of the
trading fees.
• Soft Dollar Arrangements
FFP does not receive soft dollars from clearing firms, custodians, mutual funds or
other sources.
Aggregating Securities Transactions for Client Accounts
Most trades are mutual funds where trade aggregation does not garner any significant
Client benefit. Where appropriate and beneficial, trades of exchange-traded funds will be
aggregated.
Item 13: Review of Accounts
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved
Account reviews are performed not less than annually by advisors Tiffany Brynteson-
Johnson, Anthony Rush, and Carter Colemer. Account reviews are typically performed
more frequently when market conditions dictate. Financial Plans are considered complete
when recommendations are delivered to the Client and a review is done only upon request
of Client.
Review of Client Accounts on Non-Periodic Basis
Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws,
new investment information, and changes in a Client's own situation.
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Content of Client Provided Reports and Frequency
Account reviewers are members of the firm's Investment Committee. They are instructed
to consider the Client's current security positions and the likelihood that the performance
of each security will contribute to the investment objectives of the Client.
Clients receive periodic communications on at least an annual basis. Advisory Service
Agreement Clients, Investment Management Clients, and Retainer Agreement Clients
receive updates via email or US Mail from their custodian and FFP. The written updates
may include a net worth statement, portfolio statement, tax return (if the client requests
tax preparation services).
Full Service Clients are annually provided net worth statements and net worth graphs that
are generated from our Client relationship management system. These are also provided
upon request: net worth statements contain approximations of bank account balances
provided by the Client, as well as the value of land and hard-to-price real estate. FFP is not
deemed to be managing assets based on the submission of statements by a Client or by a
listing of an asset on a net worth or other FFP generated statement. The net worth
statements are used for long-term financial planning where the exact values of assets are
not material to the financial planning tasks.
Item 14: Client Referrals and Other Compensation
Economic Benefits Provided to the Advisory Firm from External Sources and
Conflicts of Interest
Custodians and investment companies that manage mutual funds or ETF’s utilized by FFP
provide access to services that are not available to retail investors on an unsolicited basis.
The services include consulting, publications and conferences and/or lunches/dinners on
practice management, investment research, information technology, business succession,
regulatory compliance, and marketing. They may occasionally offer tickets to sporting
events or concerts. They may sponsor or reimburse FFP in connection with educational
client meetings or marketing initiatives. The sponsorship is fully disclosed to attendees of
the client event. They may also provide small non-ancillary marketing materials at client
events.
These benefits are not contingent upon commitments from FFP in exchange for any
services.
Advisory Firm Payments for Client Referrals
FFP has been fortunate to receive many Client referrals over the years. The referrals came
from current Clients, estate planning attorneys, accountants, employees, personal friends
of employees and other similar sources. FFP does not compensate referring parties for
these referrals.
Item 15: Custody
Account Statements
All assets are held at qualified custodians, which means the custodians provide account
statements directly to Clients at their address of record or electronically, at least
quarterly. Clients are urged to compare the account statements received directly from
their custodians to the performance report statements prepared by FFP.
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FFP is deemed to have constructive custody solely because advisory fees are directly
deducted from Client’s account by the custodian on behalf of FFP.
FFP is also deemed to have limited custody due to its Third-Party Standing Letters of
Authorization (“SLOA”).
FFP and its qualified custodian meet the following seven (7) conditions in order to avoid
maintaining full custody and be subject to the surprise exam requirement:
1. The Client provides an instruction to the qualified custodian, in writing, that includes
the Client’s signature, the third party’s name, and either the third party’s address or
the third party’s account number at a custodian to which the transfer should be
directed.
2. The Client authorizes FFP, in writing, either on the qualified custodian’s form or
separately, to direct transfers to the third party either on a specified schedule or from
time to time.
3. The Client’s qualified custodian performs appropriate verification of the instruction,
such as a signature review or other method to verify the Client’s authorization and
provides a transfer of funds notice to the Client promptly after each transfer.
4. The Client has the ability to terminate or change the instruction to the Client’s qualified
custodian.
5. FFP has no authority or ability to designate or change the identity of the third party,
the address, or any other information about the third party contained in the Client’s
instruction.
6. FFP maintains records showing that the third party is not a related party nor located
at the same address as FFP.
7. The Client’s qualified custodian sends the Client, in writing, an initial notice confirming
the instruction and an annual notice reconfirming the instruction.
Item 16: Investment Discretion
Discretionary Authority for Trading
FFP accepts discretionary authority to manage securities accounts on behalf of Clients.
FFP has the authority to determine, without obtaining specific Client consent, the
securities to be bought or sold, and the amount of the securities to be bought or sold.
However, FFP consults with the Client prior to each trade to obtain concurrence if a
blanket trading authorization has not been given.
The Client approves the custodian to be used and the commission rates paid to the
custodian. FFP does not receive any portion of the transaction fees or commissions paid
by the Client to the custodian on certain trades.
Discretionary trading authority facilitates placing trades in Client’s accounts on the
Client’s behalf so that we may promptly implement the FFP investment strategies.
A limited power of attorney is a trading authorization for this purpose. The FFP
Investment Management Agreement and Liability Disclosure contains a limited power of
attorney so that we may execute the trades that the Client has approved.
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Item 17: Voting Client Securities
Proxy Votes
FFP does not vote proxies on securities. Clients are expected to vote their own proxies.
The Client will receive their proxies directly from the custodian of their account or from a
transfer agent.
When assistance on voting proxies is requested, FFP will provide information to the Client
in an effort to allow the Client to make an informed decision. If a conflict of interest exists,
it will be disclosed to the Client.
Item 18: Financial Information
Balance Sheet
A balance sheet is not required to be provided because FFP does not serve as a custodian
for Client funds or securities. FFP does not require prepayment of fees of more than $1200
per Client and six months or more in advance.
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
Commitments to Clients
FFP does not have any condition that is reasonably likely to impair our ability to meet
contractual commitments to our Clients.
Bankruptcy Petitions during the Past Ten Years
Neither FFP nor its management has had any bankruptcy petitions in the last ten years.
Material Relationship Maintained by this Advisory Business or Management
persons with Issuers of Securities
There are no material relationships with issuers of securities to disclose.
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SU PER VISE D PER SON BR OCHUR E
F O R M A D V P A R T 2 B
Tiffany K. Brynteson-Johnson, CRPC®
Office Address:
11375 Robinson Drive Suite 200
Coon Rapids, MN 55433-23699
Tel: 763-231-2760
Fax: 763-231-2770
tiffany.brynteson@ffpwealth.com
www.FFPwealth.com
This brochure supplement provides information about Tiffany K. Brynteson-Johnson and supplements the
FFP Wealth Management, LLC brochure. You should have received a copy of that brochure. Please contact
Tiffany K. Brynteson-Johnson if you did not receive the brochure or if you have any questions about the
contents of this supplement.
May 1, 2025
Additional information about Tiffany K. Brynteson-Johnson (CRD#6269285) is available on the SEC’s
website at www.adviserinfo.sec.gov.
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Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Principal Executive Officer - Tiffany K. Brynteson-Johnson, CRPC®
• Year of birth: 1971
Item 2 Educational Background and Business Experience
Educational Background:
• University of Wisconsin - River Falls, Wisconsin
Bachelor of Arts – Physical Education - 1995
Minors: Health Education and Coaching
• College of Financial Planning
Chartered Retirement Planning Counselor Certification 2002
Business Experience:
• TNT Properties II, LLC
o Owner 07/2020 – Present
• FFP Wealth Management, LLC
o Owner/Financial Advisor/Chief Compliance Officer 02/2019 – current
• FFP Wealth Management, LLC, (formerly Foundation Financial Planning, LLP)
o University of Minnesota guest lecturer 2007 – 05/2019
o Financial Advisor 5/2006 – 05/2019
o Business Manager 1/2011 – 05/2019
• Wade Financial Group, Inc.
o Financial Advisor, Manager of Asset Mgmt/Client Services 4/2003 – 4/2006
o Manager of Marketing and Client Services 4/2000 – 4/2003
• Lifetime Fitness
o General Manager – Brooklyn Park Location 1998 - 2000
o Sales Manager/Operations Manager – Roseville Location 1997 – 1998
Professional Certifications
Some employees have earned certifications and credentials that are required to be
explained in further detail.
Chartered Retirement Planning CounselorSM (CRPC ®): Chartered Retirement Planning
Counselor is a designation granted by the College for Financial Planning. CRPC®
certification requirements:
• Successfully complete the program
• Pass the final exam
• Comply with the Code of Ethics
• When you achieve your CRPC® designation, you must complete 16 hours of
continuing education
• Reaffirm to abide by the Standards of Professional Conduct
• Pay a biennial renewal fee
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Item 3 Disciplinary Information
None to report.
Item 4 Other Business Activities
Tiffany K. Brynteson-Johnson does not maintain any outside business activities.
Item 5 Additional Compensation
Tiffany K. Brynteson-Johnson does not receive additional compensation outside of FFP, nor
does she receive any performance-based fees.
Item 6 Supervision
Since Tiffany K. Brynteson-Johnson is the, Chief Compliance Officer, she is ultimately
responsible for all supervision and formulation and monitoring of investment advice
offered to Clients. In addition, she will adhere to the policies and procedures as described
in the FFP’s Compliance Manual.
Mrs. Brynteson-Johnson can be contacted by email at tiffany.brynteson@ffpwealth.com or
at 763-231-2760.
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SU PER VISE D PER SON BR OCHUR E
F O R M A D V P A R T 2 B
Anthony G. Rush
Office Address:
11375 Robinson Drive Suite 200
Coon Rapids, MN 55433-23699
Tel: 763-231-2760
Fax: 763-231-2770
tony.rush@ffpwealth.com
www.FFPwealth.com
This brochure supplement provides information about Anthony G. Rush and supplements the
FFP Wealth Management, LLC’s brochure. You should have received a copy of that brochure.
Please contact Anthony G. Rush if you did not receive the brochure or if you have any questions
about the contents of this supplement.
May 1, 2025
Additional information about Anthony G. Rush (CRD 5893654) is available on the SEC’s website
at www.adviserinfo.sec.gov.
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Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Additional Investment Advisor Representative - Anthony G. Rush
• Year of birth: 1990
Item 2 Educational Background and Business Experience
Educational Background:
• Minnesota State University, Finance: 2012
Business Experience:
• TNT Properties II, LLC
o Owner 07/2020 – Present
• FFP Wealth Management, LLC
o Owner/Financial Advisor/Investment Committee Director/Investment Officer
02/2019 – Present
• FFP Wealth Management, LLC (formerly Foundation Financial Planning, LLP)
o Investment Committee Director 11/2017 – 05/2019
o Financial Advisor 12/2013 – 05/2019
o Paraplanner 05/2012 – 12/2013
• Wealth Enhancement Group
o Intern 01/2011 – 05/2011
• Minnesota State University
o Full time student 08/2008 – 05/2012
Item 3 Disciplinary Information
None to report.
Item 4 Other Business Activities
Anthony G. Rush does not maintain any outside business activities.
Item 5 Additional Compensation
Anthony G. Rush does not receive additional compensation outside of FFP, nor does he
receive any performance-based fees.
Item 6 Supervision
Anthony G. Rush is supervised by Tiffany K. Brynteson-Johnson, Chief Compliance Officer
of FFP Wealth Management, LLC. She reviews Anthony’s work through Client account
reviews, quarterly personal transaction reports as well as face-to-face and phone
interactions.
Mrs. Brynteson-Johnson can be contacted by email at tiffany.brynteson@ffpwealth.com or
at 763-231-2760.
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