FIDUCIARY FINANCIAL PARTNERS, LLC

Item 1: Cover Page Item 1: Cover Page Part 2A of Form ADV Firm Brochure December 15, 2025 Fiduciary Financial Partners, LLC SEC No. 801-78241 1250 East Diehl Road, Suite 404 Naperville, IL 60563 phone: 630-780-1534 email: dslawson@fiduciaryfp.com website: FiduciaryFinancialPartners.com This brochure provides information about the qualifications and business practices of Fiduciary Financial Partners, LLC. If you have any questions about the contents of this brochure, please contact us at 630- 780-1534 or email dslawson@fiduciaryfp.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. Registration with the SEC or state regulatory authority does not imply a certain level of skill or expertise. Additional information about Fiduciary Financial Partners, LLC, is also available on the SEC’s website at www.adviserinfo.sec.gov. Page 1 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 2: Material Changes Item 2: Material Changes This Firm Brochure is our disclosure document prepared according to regulatory requirements and rules. Consistent with the rules, we will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business fiscal year. Furthermore, we will provide you with other interim disclosures about material changes as necessary. There are no material changes to this Brochure from the last annual update issued on February 24, 2025. Page 2 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 3: Table of Contents Item 3: Table of Contents Item 1: Cover Page ...................................................................................................................................................... 1 Item 2: Material Changes .......................................................................................................................................... 2 Item 3: Table of Contents ......................................................................................................................................... 3 Item 4: Advisory Business ......................................................................................................................................... 4 Item 5: Fees and Compensation ............................................................................................................................ 9 Item 6: Performance-Based Fees and Side-by-Side Management ......................................................... 13 Item 7: Types of Clients ........................................................................................................................................... 14 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ................................................. 15 Item 9: Disciplinary Information ........................................................................................................................... 21 Item 10: Other Financial Industry Activities and Affiliations ........................................................................ 22 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................................................................................................................................................... 24 Item 12: Brokerage Practices ................................................................................................................................... 26 Item 13: Review of Accounts ................................................................................................................................... 33 Item 14: Client Referrals and Other Compensation ........................................................................................ 34 Item 15: Custody .......................................................................................................................................................... 35 Item 16: Investment Discretion ............................................................................................................................... 36 Item 17: Voting Client Securities ............................................................................................................................ 37 Item 18: Financial Information ................................................................................................................................ 38 Page 3 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 4: Advisory Business Item 4: Advisory Business A. Ownership/Advisory History Fiduciary Financial Partners, LLC (the “firm,” “we,” and/or “us”) is a limited liability company formed in the State of Delaware. Our firm has been in business as an investment adviser since 2011 and is principally owned by Nicholas Economos through his solely owned entity NE Financial Services, Inc. B. Advisory Services Offered We are dedicated to providing individuals and other types of clients with a wide array of investment advisory services. We specialize in the following types of services: Comprehensive Wealth Management; Financial Planning and Consulting; and Retirement Plan Advisory and Consulting Services. Comprehensive Wealth Management Our comprehensive wealth management service encompasses asset management as well as providing comprehensive financial planning to clients. It is designed to assist clients in meeting their financial goals through the use of financial investments. We conduct at least one, but sometimes more than one meeting (in person if possible, otherwise via telephone conference) with clients in order to understand their current financial situation, existing resources, financial goals, and tolerance for risk. The firm uses applications within e-Money software to establish the client’s general investment and risk framework. Once completed, an Investment Policy Statement is prepared defining the investment strategy and client-requested investment restrictions. Clients will also receive a written financial plan encompassing the client’s financial position, investment planning, tax management, protection planning, retirement planning, and estate planning. We may propose an investment portfolio consisting of exchange traded funds, mutual funds, individual stocks or bonds, or other securities and strategies described in Item 8 of this brochure. Upon the client’s agreement to the proposed investment plan, we work with the client to establish or transfer investment accounts so that we can manage the client’s portfolio. Once the relevant accounts are under our management, we review such accounts on a regular basis and at least annually. We may periodically rebalance or adjust client accounts under our management. If the client experiences any significant changes to his/her financial or personal circumstances, the client must notify us so that we can consider such information in managing the client’s investments. Our comprehensive wealth management service is provided on a discretionary or non- discretionary basis per the terms of the signed Comprehensive Wealth Management Agreement. For our portfolio management services, we receive a limited power of attorney to effect securities transactions on behalf of clients. Clients have the right to provide the firm with any reasonable investment restrictions that should be imposed on the management of their portfolio (to be noted on the client agreement), and should promptly notify the firm in writing of any changes in such restrictions or in the client's Page 4 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 4: Advisory Business personal financial circumstances, investment objectives, goals and tolerance for risk. We will remind clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the client’s account. We will also attempt contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives and tolerance for risk. Retirement Rollovers – Conflicts and Added Fees. Plan participants may be paying little or nothing for the plan’s investment services. As such, investment management costs are likely to be higher when engaging an investment adviser for professional investment management. Alternative courses of action are available to the plan participant: (i) Assuming it is permitted by the Plan, you can leave your money in your current Plan. (ii) If you have changed employers, you can roll your assets into the new employer’s Plan, if permissible by your new employer. (iii) You can establish an IRA R/O and place into a commission-based account at a broker-dealer. (iv) You can establish an IRA R/O and place into a fee-based advisory account. (v) You can withdraw your retirement money and pay the taxes and any applicable penalties. Your decision to roll assets from a qualified plan to a financial professional should be determined by your need for a desired level of investment services, the associated costs, and access to a diverse range of investment products that meet your personal risk tolerance and investment objective. Financial Planning and Consulting We provide a variety of financial planning and consulting services to individuals, families, businesses, and other clients regarding the management of their financial resources based upon an analysis of the client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: ▪ Financial position ▪ Accumulation goals ▪ Investment planning ▪ Education funding ▪ Tax management ▪ Business continuation strategies ▪ Protection planning ▪ Business exit strategies ▪ Retirement planning ▪ Executive/key person compensation strategies ▪ Estate planning ▪ Nonqualified deferred compensation strategies ▪ Asset allocation/investment advice Upon receiving the written financial plan, or in the case of consulting services, a summary of our firm’s recommendations, the client will have the sole responsibility for determining whether to implement the recommendations. The financial plan may include general recommendations about investment strategies, but does not recommend the purchase or sale of specific products. Our firm will not provide accounting or legal advice nor prepare any accounting or legal documents for the implementation of the client’s financial planning objectives. The client is Page 5 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 4: Advisory Business urged to work closely with his/her attorney and/or accountant in implementing recommendations set forth in the financial plan. We also provide an update to a previous financial plan (the “Plan Update”). A Plan Update will require you to provide updated information regarding your financial needs and circumstance. You complete a detailed questionnaire and discuss your current financial resources and projected needs. We will prepare a Plan Update document that will indicate if any changes to your original financial plan are warranted. You have the sole responsibility for determining whether to implement the recommendations in the Plan Update. The Plan Update may include general recommendations about investment strategies, but does not recommend the purchase or sale of specific products. Retirement Plan Advisory and Consulting Services We provide fiduciary and non-fiduciary retirement plan advisory and consulting services to employer plan sponsors. Our Retirement Plan Advisory and Consulting Services shall be in compliance with the applicable state law(s) regulating pension consulting services. This applies to client accounts that are pension or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and we accept appointments to provide our services to such accounts, we acknowledge that we are a fiduciary within the meaning of Section 3(21) of ERISA (but only with respect to the provision of services described in Appendix A of the Retirement Plan Advisory and Consulting Services Agreement). Fiduciary Services ▪ Provide non-discretionary investment advice to the client about asset classes and investment alternatives available for the retirement plan (“Plan”) in accordance with the Plan’s investment policies and objectives. Client shall have the final decision-making authority regarding the initial selection, retention, removal and addition of investment options. ▪ Assist the client with the selection of a broad range of investment options consistent with ERISA section 404(c) and the regulations thereunder. ▪ Assist the client in the development of an investment policy statement (IPS). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the investment policy statement. ▪ Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain or remove and replace investment options. ▪ Meet with client on a periodic basis to discuss the reports and the investment recommendations. Page 6 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 4: Advisory Business ▪ Provide non-discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative (“QDIA”) for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election. The client retains the sole responsibility to provide all notices to participants required under ERISA section 404(c)(5). Non-Fiduciary Services ▪ Assist in the education of the participants in the Plan about general investment principles and the investment alternatives available under the Plan. Client understands that the firm’s assistance in participant investment education shall be consistent with and within the scope of Department of Labor Interpretive Bulletin 96-1 ((i.e., the definition of investment education). As such, the firm is not providing fiduciary advice (as defined in ERISA) to the participants. Generally, the firm will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan unless the Participant provides investment and general client profile information and acknowledges in writing receipt of the firm’s disclosure documents. ▪ Assist in the group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees. ▪ Assist in the selection of a plan provider based on research and analysis of vendors, including an evaluation of administrative, recordkeeping, compliance, and employee communications services, administrative and investment-related fees, and an investment overview that incorporates a very similar analysis to the investment due diligence process described above. ▪ Prepare quarterly market reviews to help inform and educate client on the prevailing capital markets. ▪ Provide detailed reviews that include an analysis of relevant design features, including; age and service eligibility requirements, vesting, employer contribution formulae; and other relevant design features. ▪ Facilitate plan conversions by generally overseeing process and providing sample letters and correspondence related to the plan conversion. ▪ Provide checklists, plan design analysis, and other analyses to address plan compliance and efficiency. Such review may include a list of action items and suggestions, based on plan dynamics and discussions with the Plan’s fiduciaries. ▪ Respond to ongoing questions, concerns, and issues raised by the client that are related to the Plan. Such services include plan pricing and contract negotiation with current providers, recommendations of specific Plan enhancements, helping solve service, administrative, recordkeeping issues, and plan compliance assistance. Page 7 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 4: Advisory Business Participant Account Management (Discretionary) We use a third-party platform (Pontera Order Management System) to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of client funds since we do not have direct access to client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the client allowing them to connect an account(s) to the platform. Once client account(s) is connected to the platform, we will review the current account allocations. When deemed necessary, we will rebalance the account considering client investment goals and risk tolerance, and 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. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. We may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between our firm and the client. C. Client-Tailored Services and Client-Imposed Restrictions We offer individualized investment advice to clients for our Comprehensive Wealth Management service. Additionally, we offer general investment advice to clients utilizing the following services offered by our firm: Financial Planning and Consulting and Retirement Plan Advisory and Consulting Services. Each client’s account will be managed on the basis of the client’s financial situation and investment objectives and in accordance with any reasonable restrictions imposed by the client on the management of the account—for example, restricting the type or amount of security to be purchased in the portfolio. D. Wrap Fee Programs We do not participate in wrap fee programs, where brokerage commissions and transaction costs are included in the asset-based fee charged to the client. E. Client Assets Under Management As of December 31, 2024, our firm managed $226,966,478 of discretionary assets and $20,701,190 of non-discretionary assets. Additionally, assets under advisement for retirement plan accounts amount to $243,791,577. Page 8 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 5: Fees and Compensation Item 5: Fees and Compensation A. Methods of Compensation and Fee Schedule Comprehensive Wealth Management Services The annual fee for comprehensive wealth management services will be charged as a percentage of assets under management according to the following fee schedule, which represents the firm’s maximum fees for individual services. All fees are negotiable. Assets under Management Annual Fee Rate Initial $1,000,000 1.00% Next $1,000,000 0.85% Next $3,000,000 0.75% Next $2,500,000 0.50% Next $2,500,000 0.35% All Assets over $10,000,000 0.25% Asset-based fees are always subject to the investment advisory agreement between the client and our firm. Such fees are payable monthly in arrears and are calculated by multiplying the fee rate by the average daily balance of the account on each business day of the prior month. We require a minimum client fee of $7,500 annually. Financial Planning and Consulting Services Financial planning fees will be billed at the rate of $300 per hour or a fixed fee mutually agreed upon by the client and the firm. For fixed fee arrangements, we will provide the prospective client with an estimate of the fixed charges prior to finalizing the financial planning agreement. Retirement Plan Advisory and Consulting Services Specific fee arrangements may vary from other clients’ fee arrangements for similar services. Our fees for Retirement Plan Advisory and Consulting Services can involve (1) an annual asset-based fee, (2) an annual flat/fixed fee, or (3) a combination of both. In general, we require a minimum flat fee of $5,000. Asset-based fees shall be based on the fair market value of the Plan assets on the last day of the calendar month. The annual fee for Plan Services shall be calculated as follows: Plan Size Annual Fee Rate First $500,000 1.00% Next $500,000 0.35% Next $1,000,000 0.30% Next $2,000,000 0.25% Next $2,000,000 0.20% Page 9 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 5: Fees and Compensation Next $4,000,000 0.15% Next $5,000,000 0.10% Over $15,000,000 0.05% Fees will be paid monthly in arrears by the client directly, paid out of Plan assets, or paid by the Plan’s investment Recordkeeper as a fee offset pursuant to client’s instructions. Alternatively, fees may be paid quarterly in arrears. The initial fee will be the amount, prorated for the number of days remaining in the initial fee period from the effective date of the agreement until the last business day of the initial fee period. B. Client Payment of Fees Comprehensive Wealth Management Services We do not require the prepayment of fees. Clients are required to authorize the direct debit of fees from their accounts. Exceptions may be granted subject to the firm’s consent for clients to be billed directly for our fees. For directly debited fees, the custodian’s periodic statements will show each fee deduction from the account. Clients may withdraw this authorization for direct billing of these fees at any time by notifying us or their custodian in writing. We will deduct advisory fees directly from the client’s account provided that (i) the client provides written authorization to the qualified custodian, and (ii) the qualified custodian sends the client a statement, at least quarterly, indicating all amounts disbursed from the account. The client is responsible for verifying the accuracy of the fee calculation, as the client’s custodian will not verify the calculation. The agreement may be terminated at any time by the client, or by the firm with 30 days’ prior written notice to the client. Upon termination any earned, unpaid fees will be immediately due and payable. Financial Planning and Consulting Services We require a retainer of fifty percent (50 %) of the estimated total financial planning or consulting fee, with the remainder of the fee directly billed to the client and due to us within 30 days of the financial plan being delivered or consultation rendered to the client. For prepaid fees in excess of $1,200, services will be completed within six months of the date fees are received. Either party may terminate the agreement at any time by providing written notice. For purposes of calculating refunds, all work performed by us up to the point of termination shall be calculated at our hourly fee of $300. The client will receive a pro-rata refund of unearned fees based on the time and effort expended by the firm. Retirement Plan Advisory and Consulting Services If client elects to have fees deducted from Plan assets, client grants the firm the authority to have fees that are chargeable to the Plan automatically deducted from the Plan’s accounts held by the recordkeeper (or other custodian of Plan assets, herein also referred to as the Page 10 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 5: Fees and Compensation “recordkeeper”) and paid directly to the firm upon recordkeeper’s receipt of the billing notice. A quarterly statement setting forth the fees deducted from the Plan (as well as identifying the amount of funds and of each security in the account at the end of the period and setting forth all transactions in the account during that period) shall be provided to the Plan by the recordkeeper. The specifics of any arrangement will be set forth in the Retirement Plan Advisory and Consulting Services Agreement. Either party may terminate the agreement upon 30 days’ prior written notice to the other party. If the agreement is terminated prior to the end of a fee period, the firm shall be entitled to a fee, prorated for the number of days in the fee period prior to the effective date of termination, based upon the Plan assets on the effective date of termination. C. Additional Client Fees Charged All fees paid for investment advisory services are separate and distinct from the fees and expenses charged by exchange-traded funds, mutual funds, separate account managers, private placement, pooled investment vehicles, broker-dealers, and custodians retained by clients. Such fees and expenses are described in each exchange-traded fund and mutual fund’s prospectus, each separate account manager’s Form ADV and Brochure and Brochure Supplement or similar disclosure statement, each private placement or pooled investment vehicle’s confidential offering memoranda, and by any broker-dealer or custodian retained by the client. Clients are advised to read these materials carefully before investing. If a mutual fund also imposes sales charges, a client may pay an initial or deferred sales charge as further described in the mutual fund’s prospectus. A client using our firm may be precluded from using certain mutual funds or separate account managers because they may not be offered by the client's custodian. Please refer to the Brokerage Practices section (Item 12) for additional information regarding the firm’s brokerage practices. D. External Compensation for the Sale of Securities to Clients Our firm’s advisory professionals are compensated primarily through a salary and bonus structure. Advisory professionals may be paid sales, service or administrative fees for the sale of mutual funds or other investment products. Advisory professionals may receive commission- based compensation for the sale of securities and insurance products. Investment adviser representatives, in their capacity as a Purshe Kaplan Sterling Investments, Inc. (“PKS”) registered representative, are prohibited from earning an advisory fee on the securities value transferred from an advisory client’s PKS brokerage account unless commissions earned on such securities transactions occurred at least a 12–18 months prior to the transfer. Please see Item 10.C. for detailed information and conflicts of interest. E. Important Disclosure – Custodian Investment Programs Please be advised that certain of the firm’s investment adviser representatives are registered with a broker-dealer and/or the firm is a broker-dealer or affiliated with a broker-dealer. Under these arrangements, we can access certain investment programs offered through the broker- Page 11 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 5: Fees and Compensation dealer that offer certain compensation and fee structures that create conflicts of interest of which clients need to be aware. As such, the investment adviser representative and/or the firm may have an economic incentive to recommend the purchase of 12b-1 or revenue share class mutual funds offered through the broker-dealer platform rather than from the investment adviser platform. Please be advised that the firm utilizes certain custodians/broker-dealers. Under these arrangements we can access certain investment programs offered through such custodian(s) that offer certain compensation and fee structures that create conflicts of interest of which clients need to be aware. Please note the following: Limitation on Mutual Fund Universe for Custodian Investment Programs: Please note that as a matter of policy we prohibit the receipt of revenue share fees from any mutual funds utilized for our advisory clients’ portfolios. There are certain programs in which we participate where a client’s investment options may be limited in certain of these programs to those mutual funds and/or mutual fund share classes that pay 12b-1 fees and other revenue sharing fee payments, and the client should be aware that the firm is not selecting from among all mutual funds available in the marketplace when recommending mutual funds to the client. Conflict Between Revenue Share Class (12b-1) and Non-Revenue Share Class Mutual Funds: Revenue share class/12b-1 fees are deducted from the net asset value of the mutual fund and generally, all things being equal, cause the fund to earn lower rates of return than those mutual funds that do not pay revenue sharing fees. The client is under no obligation to utilize such programs or mutual funds. Although many factors will influence the type of fund to be used, the client should discuss with their investment adviser representative whether a share class from a comparable mutual fund with a more favorable return to investors is available that does not include the payment of any 12b-1 or revenue sharing fees given the client’s individual needs and priorities and anticipated transaction costs. In addition, the receipt of such fees can create conflicts of interest in instances (i) where our adviser representative is also licensed as a registered representative of a broker-dealer and receives a portion of 12b-1 and or revenue sharing fees as compensation – such compensation creates an incentive for the investment adviser representative to use programs which utilize funds that pay such additional compensation; and (ii) where the custodian receives the entirety of the 12b-1 and/or revenue sharing fees and takes the receipt of such fees into consideration in terms of benefits it may elect to provide to the firm, even though such benefits may or may not benefit some or all of the firm clients. Page 12 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 6: Performance-Based Fees and Side-by-Side Management Item 6: Performance-Based Fees and Side-by-Side Management The firm does not charge performance-based fees and therefore has no economic incentive to manage clients’ portfolios in any way other than what is in their best interests. Page 13 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 7: Types of Clients Item 7: Types of Clients We have the following types of clients: ▪ Individuals and High Net Worth Individuals ▪ Pension and Profit Sharing Plans In general, we require a minimum client fee of $7,500 annually. For portfolio values less than $750,000, clients may be able to obtain comparable services at a lower cost elsewhere. For Retirement Plan Advisory and Consulting Services, we require a minimum flat fee of $5,000. The firm, at its sole discretion, may waive the minimum requirements. Page 14 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis and Investment Strategies Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. There is no guarantee that any specific investment or strategy will be profitable for a particular client. Methods of Analysis The firm uses a variety of sources of data to conduct its economic, investment and market analysis, which may include economic and market research materials prepared by others, conference calls hosted by individual companies or mutual funds, corporate rating services, annual reports, prospectuses, and company press releases, and financial newspapers and magazines. It is important to keep in mind that there is no specific approach to investing that guarantees success or positive returns; investing in securities involves risk of loss that clients should be prepared to bear. The firm and its investment adviser representatives are responsible for identifying and implementing the methods of analysis used in formulating investment recommendations to clients. The methods of analysis may include quantitative methods for optimizing client portfolios, computer-based risk/return analysis, technical analysis, and statistical and/or computer models utilizing long-term economic criteria. ▪ Fundamental analysis is a method of evaluating the intrinsic value of an asset and analyzing the factors that could influence its price in the future. This form of analysis is based on external events and influences, as well as financial statements and industry trends. ▪ Factor investing is an investment approach that involves targeting specific drivers of return across asset classes. There are two main types of factors: macroeconomic and style. ▪ Optimization involves the use of mathematical algorithms to determine the appropriate mix of assets given the firm’s current capital market rate assessment and a particular client’s risk tolerance. ▪ Quantitative methods include analysis of historical data such as price and volume statistics, performance data, standard deviation and related risk metrics, how the security performs relative to the overall stock market, earnings data, price to earnings ratios, and related data. ▪ Computer models may be used to derive the future value of a security based on assumptions of various data categories such as earnings, cash flow, profit margins, sales, and a variety of other company specific metrics. In addition, the firm reviews research material prepared by others, as well as corporate filings, corporate rating services, and a variety of financial publications. The firm may employ outside vendors or utilize third-party software to assist in formulating investment recommendations to clients. Page 15 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Mutual Funds and Exchange-Traded Funds, Individual Securities The firm may recommend ”institutional share class” mutual funds and individual securities (including fixed income instruments). A description of the criteria to be used in formulating an investment recommendation for mutual funds, ETFs, and individual securities (including fixed- income securities) is set forth below. The firm has formed relationships with third-party vendors that ▪ provide a technological platform for separate account management ▪ prepare performance reports ▪ perform or distribute research of individual securities ▪ perform billing and certain other administrative tasks The firm may utilize additional independent third parties to assist it in recommending and monitoring individual securities and mutual funds to clients as appropriate under the circumstances. The firm reviews certain quantitative and qualitative criteria related to mutual funds and to formulate investment recommendations to its clients. Quantitative criteria may include ▪ the performance history of a mutual fund evaluated against that of its peers and other benchmarks ▪ an analysis of risk-adjusted returns ▪ an analysis of the contribution to the investment return (e.g., manager’s alpha), standard deviation of returns over specific time periods, sector and style analysis ▪ the fund’s fee structure ▪ the relevant portfolio manager’s tenure Qualitative criteria used in selecting/recommending mutual funds include the investment objectives and/or management style and philosophy of a mutual fund; a mutual fund’s consistency of investment style; and employee turnover and efficiency and capacity. Quantitative and qualitative criteria related to mutual funds are reviewed by the firm on a quarterly basis or such other interval as appropriate under the circumstances. In addition, mutual funds are reviewed to determine the extent to which their investments reflect efforts to time the market, or evidence style drift such that their portfolios no longer accurately reflect the particular asset category attributed to the mutual fund by the firm (both of which are negative factors in implementing an asset allocation structure). The firm may negotiate reduced account minimum balances and reduced fees under various circumstances (e.g., for clients with minimum level of assets committed for specific periods of time, etc.). There can be no assurance that clients will receive any reduced account minimum balances or fees, or that all clients, even if apparently similarly situated, will receive any reduced account minimum balances or fees available to some other clients. Also, account minimum balances and fees may significantly differ between clients. Each client’s individual needs and circumstances will determine portfolio weighting, which can have an impact on fees given the Page 16 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss funds utilized. The firm will endeavor to obtain equal treatment for its clients with funds, but cannot assure equal treatment. The firm will regularly review the activities of mutual funds utilized for the client. Clients that invest in mutual funds should first review and understand the disclosure documents of those mutual funds, which contain information relevant to such retention or investment, including information on the methodology used to analyze securities, investment strategies, fees, and conflicts of interest. Material Risks of Investment Instruments The firm generally invests in the following types of securities: ▪ Equity securities ▪ Mutual fund securities ▪ Exchange-traded funds ▪ Fixed income securities ▪ Corporate debt obligations ▪ Variable annuities Equity Securities Investing in individual companies involves inherent risk. The major risks relate to the company’s capitalization, quality of the company’s management, quality and cost of the company’s services, the company’s ability to manage costs, efficiencies in the manufacturing or service delivery process, management of litigation risk, and the company’s ability to create shareholder value (i.e., increase the value of the company’s stock price). Foreign securities, in addition to the general risks of equity securities, have geopolitical risk, financial transparency risk, currency risk, regulatory risk and liquidity risk. Mutual Fund Securities Investing in mutual funds carries inherent risk. The major risks of investing in a mutual fund include the quality and experience of the portfolio management team and its ability to create fund value by investing in securities that have positive growth, the amount of individual company diversification, the type and amount of industry diversification, and the type and amount of sector diversification within specific industries. In addition, mutual funds tend to be tax inefficient and therefore investors may pay capital gains taxes on fund investments while not having yet sold the fund. Exchange-Traded Funds (“ETFs”) ETFs are investment companies whose shares are bought and sold on a securities exchange. An ETF holds a portfolio of securities designed to track a particular market segment or index. Some examples of ETFs are SPDRs®, streetTRACKS®, DIAMONDSSM, NASDAQ 100 Index Tracking StockSM (“QQQs SM”) iShares® and VIPERs®. ETFs have embedded expenses that the client indirectly bears. Page 17 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Investing in ETFs involves risk. Specifically, ETFs, depending on the underlying portfolio and its size, can have wide price (bid and ask) spreads, thus diluting or negating any upward price movement of the ETF or enhancing any downward price movement. Also, ETFs require more frequent portfolio reporting by regulators and are thereby more susceptible to actions by hedge funds that could have a negative impact on the price of the ETF. Certain ETFs may employ leverage, which creates additional volatility and price risk depending on the amount of leverage utilized, the collateral and the liquidity of the supporting collateral. Further, the use of leverage (i.e., employing the use of margin) generally results in additional interest costs to the ETF. Certain ETFs are highly leveraged and therefore have additional volatility and liquidity risk. Volatility and liquidity can severely and negatively impact the price of the ETF’s underlying portfolio securities, thereby causing significant price fluctuations of the ETF. Fixed Income Securities Fixed income securities carry additional risks than those of equity securities described above. These risks include the company’s ability to retire its debt at maturity, the current interest rate environment, the coupon interest rate promised to bondholders, legal constraints, jurisdictional risk (U.S or foreign) and currency risk. If bonds have maturities of ten years or greater, they will likely have greater price swings when interest rates move up or down. The shorter the maturity the less volatile the price swings. Foreign bonds have liquidity and currency risk. Corporate Debt Obligations Corporate debt obligations include corporate bonds, debentures, notes, commercial paper and other similar corporate debt instruments. Companies use these instruments to borrow money from investors. The issuer pays the investor a fixed or variable rate of interest and must repay the amount borrowed at maturity. Commercial paper (short-term unsecured promissory notes) is issued by companies to finance their current obligations and normally has a maturity of less than nine months. In addition, the firm may also invest in corporate debt securities registered and sold in the United States by foreign issuers (Yankee bonds) and those sold outside the U.S. by foreign or U.S. issuers (Eurobonds). Variable Annuities Variable Annuities are long-term financial products designed for retirement purposes. In essence, annuities are contractual agreements in which payment(s) are made to an insurance company, which agrees to pay out an income or a lump sum amount at a later date. There are contract limitations and fees and charges associated with annuities, administrative fees, and charges for optional benefits. They also may carry early withdrawal penalties and surrender charges, and carry additional risks such as the insurance carrier's ability to pay claims. Moreover, variable annuities carry investment risk similar to mutual funds. Investors should carefully review the terms of the variable annuity contract before investing. Page 18 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss B. Investment Strategy and Method of Analysis Material Risks Our investment strategy is custom-tailored to the client’s goals, investment objectives, risk tolerance, and personal and financial circumstances. Margin Leverage Although the firm, as a general business practice, does not utilize leverage, there may be instances in which the use of leverage may be appropriate for certain clients and situations or requested by the clients for personal use. In this regard please review the following: The use of margin leverage enhances the overall risk of investment gain and loss to the client’s investment portfolio. For example, investors are able to control $2 of a security for $1. So if the price of a security rises by $1, the investor earns a 100% return on their investment. Conversely, if the security declines by $.50, then the investor loses 50% of their investment. The use of margin leverage entails borrowing, which results in additional interest costs to the investor. Broker-dealers who carry customer accounts require a minimum equity requirement when clients utilize margin leverage. The minimum equity requirement is stated as a percentage of the value of the underlying collateral security with an absolute minimum dollar requirement. For example, if the price of a security declines in value to the point where the excess equity used to satisfy the minimum requirement dissipates, the broker-dealer will require the client to deposit additional collateral to the account in the form of cash or marketable securities. A deposit of securities to the account will require a larger deposit, as the security being deposited is included in the computation of the minimum equity requirement. In addition, when leverage is utilized and the client needs to withdraw cash, the client must sell a disproportionate amount of collateral securities to release enough cash to satisfy the withdrawal amount based upon similar reasoning as cited above. Regulations concerning the use of margin leverage are established by the Federal Reserve Board and vary if the client’s account is held at a broker-dealer versus a bank custodian. Broker-dealers and bank custodians may apply more stringent rules as they deem necessary. Short-Term Trading Although the firm, as a general business practice, does not utilize short-term trading, there may be instances in which short-term trading may be necessary or an appropriate strategy. In this regard, please read the following: There is an inherent risk for clients who trade frequently in that high-frequency trading creates substantial transaction costs that in the aggregate could negatively impact account performance. Option Strategies Various option strategies give the holder the right to acquire or sell underlying securities at the contract strike price up until expiration of the option. Each contract is worth 100 shares of the Page 19 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss underlying security. Options entail greater risk but allow an investor to have market exposure to a particular security or group of securities without the capital commitment required to purchase the underlying security or groups of securities. In addition, options allow investors to hedge security positions held in the portfolio. For detailed information on the use of options and option strategies, please contact the Options Clearing Corporation for the current Options Risk Disclosure Statement. The firm as part of its investment strategy may employ the following option strategies: ▪ Covered call writing ▪ Long call options purchases ▪ Long put options purchases Covered Call Writing Covered call writing is the sale of in-, at-, or out-of-the-money call option against a long security position held in the client portfolio. This type of transaction is used to generate income. It also serves to create downside protection in the event the security position declines in value. Income is received from the proceeds of the option sale. Such income may be reduced to the extent it is necessary to buy back the option position prior to its expiration. This strategy may involve a degree of trading velocity, transaction costs and significant losses if the underlying security has volatile price movement. Covered call strategies are generally suited for companies with little price volatility. Long Call Option Purchases Long call option purchases allow the option holder to be exposed to the general market characteristics of a security without the outlay of capital necessary to own the security. Options are wasting assets and expire (usually within nine months of issuance), and as a result can expose the investor to significant loss. Long Put Option Purchases Long put option purchases allow the option holder to sell or “put” the underlying security at the contract strike price at a future date. If the price of the underlying security declines in value, the value of the long put option increases. In this way long puts are often used to hedge a long stock position. Options are wasting assets and expire (usually within nine months of issuance), and as a result can expose the investor to significant loss. C. Concentration Risks There is an inherent risk for clients who have their investment portfolios heavily weighted in one security, one industry or industry sector, one geographic location, one investment manager, one type of investment instrument (equities versus fixed income). Clients who have diversified portfolios, as a general rule, incur less volatility and therefore less fluctuation in portfolio value than those who have concentrated holdings. Concentrated holdings may offer the potential for higher gain, but also offer the potential for significant loss. Page 20 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 9: Disciplinary Information Item 9: Disciplinary Information A. Criminal or Civil Actions There is nothing to report on this item. B. Administrative Enforcement Proceedings There is nothing to report on this item. C. Self-Regulatory Organization Enforcement Proceedings There is nothing to report on this item. Page 21 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 10: Other Financial Industry Activities and Affiliations Item 10: Other Financial Industry Activities and Affiliations A. Broker-Dealer or Representative Registration Neither the firm nor its affiliates, employees, or independent contractors are registered broker- dealers and do not have an application to register pending. John Hillman, investment adviser representative, is a registered representative of Purshe Kaplan Sterling Investments, Inc. (“PKS”), member FINRA/SIPC. Fiduciary Financial Partners, LLC is not affiliated with PKS. B. Futures or Commodity Registration Neither the firm nor its affiliates are registered as a commodity firm, futures commission merchant, commodity pool operator or commodity trading advisor and do not have an application to register pending. C. Material Relationships Maintained by this Advisory Business and Conflicts of Interest Broker-Dealer Registration John Hillman, investment adviser representative, is a registered representative of PKS. Please be advised that the firm’s professionals who effect transactions for advisory clients may receive transaction or commission compensation from PKS. The recommendation of securities transactions for commission creates a conflict of interest in that our firm is economically incented to effect securities transactions for clients. Although we strive to put our clients’ interests first, such recommendations may be viewed as being in the best interests of our firm rather than in the client’s best interest. Our advisory clients are not compelled to effect securities transactions through PKS. In their capacity as registered representatives of PKS, our firm’s advisory professionals are subject to the oversight of PKS and the Financial Industry Regulatory Authority, Inc. (“FINRA”). As such, clients of the firm should understand that their personal and account information is available to FINRA and PKS personnel in the fulfillment of their oversight obligations and duties. Insurance Sales Certain managers, members, and registered employees of the firm are licensed insurance agents and may recommend insurance products offered by such carriers for whom they function as an agent and receive a commission for doing so. Please be advised there is a conflict of interest in that there is an economic incentive to recommend insurance and other products of such carriers. Please also be advised that the firm strives to put its clients’ interests first and foremost. Other than for insurance products that require a securities license, such as variable insurance products, clients may utilize any insurance carrier or insurance agency they desire. For products Page 22 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 10: Other Financial Industry Activities and Affiliations requiring a securities and insurance license, clients may be limited to those insurance carriers that have a selling agreement with the firm’s employing broker-dealer. D. Recommendation or Selection of Other Investment Advisors and Conflicts of Interest The firm does not recommend separate account managers or other investment products in which it receives any form of referral or solicitor compensation from the separate account manager or client. Page 23 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Description In accordance with the Advisers Act, the firm has adopted policies and procedures designed to detect and prevent insider trading. In addition, the firm has adopted a Code of Ethics (the “Code”). Among other things, the Code includes written procedures governing the conduct of the firm 's advisory and access persons. The Code also imposes certain reporting obligations on persons subject to the Code. The Code and applicable securities transactions are monitored by the chief compliance officer of the firm. The firm will send clients a copy of its Code of Ethics upon written request. The firm has policies and procedures in place to ensure that the interests of its clients are given preference over those of the firm, its affiliates and its employees. For example, there are policies in place to prevent the misappropriation of material non-public information, and such other policies and procedures reasonably designed to comply with federal and state securities laws. B. Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest The firm does not engage in principal trading (i.e., the practice of selling stock to advisory clients from a firm’s inventory or buying stocks from advisory clients into a firm’s inventory). In addition, the firm does not recommend any securities to advisory clients in which it has some proprietary or ownership interest. C. Advisory Firm Purchase or Sale of Same Securities Recommended to Clients and Conflicts of Interest The firm, its affiliates, employees and their families, trusts, estates, charitable organizations and retirement plans established by it may purchase or sell the same securities as are purchased or sold for clients in accordance with its Code of Ethics policies and procedures. The personal securities transactions by advisory representatives and employees may raise potential conflicts of interest when they trade in a security that is: ▪ owned by the client, or ▪ considered for purchase or sale for the client. Such conflict generally refers to the practice of front-running (trading ahead of the client), which the firm specifically prohibits. The firm has adopted policies and procedures that are intended to address these conflicts of interest. These policies and procedures: ▪ require our advisory representatives and employees to act in the client’s best interest ▪ prohibit fraudulent conduct in connection with the trading of securities in a client account Page 24 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ▪ prohibit employees from personally benefitting by causing a client to act, or fail to act in making investment decisions ▪ prohibit the firm or its employees from profiting or causing others to profit on knowledge of completed or contemplated client transactions ▪ allocate investment opportunities in a fair and equitable manner ▪ provide for the review of transactions to discover and correct any trades that result in an advisory representative or employee benefitting at the expense of a client. Advisory representatives and employees must follow the firm’s procedures when purchasing or selling the same securities purchased or sold for the client. D. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest The firm, its affiliates, employees and their families, trusts, estates, charitable organizations, and retirement plans established by it may effect securities transactions for their own accounts that differ from those recommended or effected for other clients. The firm will make a reasonable attempt to trade securities in client accounts at or prior to trading the securities in its affiliate, corporate, employee or employee-related accounts. Trades executed the same day will likely be subject to an average pricing calculation. It is the policy of the firm to place the clients’ interests above those of the firm and its employees. Page 25 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 12: Brokerage Practices Item 12: Brokerage Practices A. Factors Used to Select Broker-Dealers for Client Transactions Custodian Recommendations The firm recommends that clients establish brokerage accounts with the Schwab Advisor Services division of Charles Schwab & Co., Inc. (“Schwab” or “custodian”), a FINRA-registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. Although the firm may recommend that clients establish accounts at the custodian, it is the client’s decision to custody assets with the custodian. The firm is independently owned and operated and not affiliated with custodian. For client accounts maintained in the firm’s custody, the custodian generally does not charge separately for custody services but is compensated by account holders through commissions and other transaction-related or asset-based fees for securities trades that are executed through the custodian or that settle into custodian accounts. The firm considers the financial strength, reputation, operational efficiency, cost, execution capability, level of customer service, and related factors in recommending broker-dealers or custodians to advisory clients. In certain instances and subject to approval by the firm, the firm will recommend to clients certain other broker-dealers and/or custodians based on the needs of the individual client, and taking into consideration the nature of the services required, the experience of the broker-dealer or custodian, the cost and quality of the services, and the reputation of the broker-dealer or custodian. The final determination to engage a broker-dealer or custodian recommended by the firm will be made by and in the sole discretion of the client. The client recognizes that broker- dealers and/or custodians have different cost and fee structures and trade execution capabilities. As a result, there may be disparities with respect to the cost of services and/or the transaction prices for securities transactions executed on behalf of the client. Clients are responsible for assessing the commissions and other costs charged by broker-dealers and/or custodians. How We Select Brokers/Custodians to Recommend The firm seeks to recommend a custodian/broker who will hold client assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others, the following: ▪ combination of transaction execution services along with asset custody services (generally without a separate fee for custody) ▪ capability to execute, clear, and settle trades (buy and sell securities for client accounts) ▪ capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) ▪ breadth of investment products made available (stocks, bonds, mutual funds, exchange- traded funds (ETFs), etc.) Page 26 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 12: Brokerage Practices ▪ availability of investment research and tools that assist us in making investment decisions ▪ quality of services ▪ competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate them ▪ reputation, financial strength, and stability of the provider ▪ their prior service to us and our other clients ▪ availability of other products and services that benefit us, as discussed below Client’s Custody and Brokerage Costs For client accounts that the firm maintains, the custodian generally does not charge clients separately for custody services but is compensated by charging either transaction fees or custodian asset-based fees on trades that it executes or that settle into the custodian’s accounts. The custodian’s commission rates applicable to the firm’s client accounts were negotiated based on the firm’s commitment to maintain a certain minimum amount of client assets at the custodian. This commitment benefits the client because the overall commission rates paid are lower than they would be if the firm had not made the commitment. In addition to commissions, the custodian charges a flat dollar amount as a “prime broker” or “trade away” fee for each trade that the firm has executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into the client’s custodian account. These fees are in addition to the commissions or other compensation the client pays the executing broker-dealer. Because of this, in order to minimize the client’s trading costs, the firm has the custodian execute most trades for the account. Soft Dollar Arrangements The firm does not utilize soft dollar arrangements. The firm does not direct brokerage transactions to executing brokers for research and brokerage services. Institutional Trading and Custody Services The custodian provides the firm with access to its institutional trading and custody services, which are typically not available to the custodian’s retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as a certain minimum amount of the advisor’s clients’ assets are maintained in accounts at a particular custodian. The custodian’s brokerage services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. Other Products and Services Custodian also makes available to the firm other products and services that benefit the firm but may not directly benefit its clients’ accounts. Many of these products and services may be used to service all or some substantial number of the firm's accounts, including accounts not Page 27 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 12: Brokerage Practices maintained at custodian. The custodian may also make available to the firm software and other technology that ▪ provide access to client account data (such as trade confirmations and account statements) ▪ facilitate trade execution and allocate aggregated trade orders for multiple client accounts ▪ provide research, pricing and other market data ▪ facilitate payment of the firm’s fees from its clients’ accounts ▪ assist with back-office functions, recordkeeping and client reporting The custodian may also offer other services intended to help the firm manage and further develop its business enterprise. These services may include ▪ compliance, legal and business consulting ▪ publications and conferences on practice management and business succession ▪ access to employee benefits providers, human capital consultants and insurance providers The custodian may also provide other benefits such as educational events or occasional business entertainment of the firm personnel. In evaluating whether to recommend that clients custody their assets at the custodian, the firm may take into account the availability of some of the foregoing products and services and other arrangements as part of the total mix of factors it considers, and not solely the nature, cost or quality of custody and brokerage services provided by the custodian, which may create a potential conflict of interest. Independent Third Parties The custodian may make available, arrange, and/or pay third-party vendors for the types of services rendered to the firm. The custodian may discount or waive fees it would otherwise charge for some of these services or all or a part of the fees of a third party providing these services to the firm. Additional Compensation Received from Custodians The firm may participate in institutional customer programs sponsored by broker-dealers or custodians. The firm may recommend these broker-dealers or custodians to clients for custody and brokerage services. There is no direct link between the firm’s participation in such programs and the investment advice it gives to its clients, although the firm receives economic benefits through its participation in the programs that are typically not available to retail investors. These benefits may include the following products and services (provided without cost or at a discount): ▪ Receipt of duplicate client statements and confirmations ▪ Research-related products and tools ▪ Consulting services ▪ Access to a trading desk serving the firm’s participants Page 28 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 12: Brokerage Practices ▪ Access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts) ▪ The ability to have advisory fees deducted directly from client accounts ▪ Access to an electronic communications network for client order entry and account information ▪ Access to mutual funds with no transaction fees and to certain institutional money managers ▪ Discounts on compliance, marketing, research, technology, and practice management products or services provided to the firm by third-party vendors The custodian may also pay for business consulting and professional services received by the firm’s related persons, and may pay or reimburse expenses (including client transition expenses, travel, lodging, meals and entertainment expenses for the firm’s personnel to attend conferences). Some of the products and services made available by such custodian through its institutional customer programs may benefit the firm but may not benefit its client accounts. These products or services may assist the firm in managing and administering client accounts, including accounts not maintained at the custodian as applicable. Other services made available through the programs are intended to help the firm manage and further develop its business enterprise. The benefits received by the firm or its personnel through participation in these programs do not depend on the amount of brokerage transactions directed to the broker-dealer. The firm also participates in similar institutional advisor programs offered by other independent broker-dealers or trust companies, and its continued participation may require the firm to maintain a predetermined level of assets at such firms. In connection with its participation in such programs, the firm will typically receive benefits similar to those listed above, including research, payments for business consulting and professional services received by the firm’s related persons, and reimbursement of expenses (including travel, lodging, meals and entertainment expenses for the firm’s personnel to attend conferences sponsored by the broker-dealer or trust company). As part of its fiduciary duties to clients, the firm endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by the firm or its related persons in and of itself creates a potential conflict of interest and may indirectly influence the firm’s recommendation of broker-dealers for custody and brokerage services. The Firm’s Interest in Custodian’s Services The availability of these services from the custodian benefits the firm because the firm does not have to produce or purchase them. The firm does not have to pay for the custodian’s services so long as a certain minimum of client assets is kept in accounts at the custodian. Custodian’s services may give the firm an incentive to recommend that clients maintain their accounts with the custodian based on the firm’s interest in receiving the custodian’s services that benefit the firm’s business rather than based on the client’s interest in receiving the best value in custody services and the most favorable execution of client transactions. This is a Page 29 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 12: Brokerage Practices potential conflict of interest. The firm believes, however, that the selection of the custodian as custodian and broker is in the best interest of clients. It is primarily supported by the scope, quality, and price of the custodian’s services and not the custodian’s services that benefit only the firm. Brokerage for Client Referrals The firm does not engage in the practice of directing brokerage commissions in exchange for the referral of advisory clients. Directed Brokerage Firm Recommendations The firm typically recommends Schwab as custodian for clients’ funds and securities and to execute securities transactions on its clients’ behalf. Client-Directed Brokerage Occasionally, clients may direct the firm to use a particular broker-dealer to execute portfolio transactions for their account or request that certain types of securities not be purchased for their account. Clients who designate the use of a particular broker-dealer should be aware that they will lose any possible advantage the firm derives from aggregating transactions. Such client trades are typically effected after the trades of clients who have not directed the use of a particular broker-dealer. The firm loses the ability to aggregate trades with other the firm advisory clients, potentially subjecting the client to inferior trade execution prices as well as higher commissions. B. Aggregating Securities Transactions for Client Accounts Best Execution The firm, pursuant to the terms of its investment advisory agreement with clients, has discretionary authority to determine which securities are to be bought and sold, and the amount of such securities. The firm recognizes that the analysis of execution quality involves a number of factors, both qualitative and quantitative. The firm will follow a process in an attempt to ensure that it is seeking to obtain the most favorable execution under the prevailing circumstances when placing client orders. These factors include but are not limited to the following: ▪ The financial strength, reputation and stability of the broker ▪ The efficiency with which the transaction is effected ▪ The ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any) ▪ The availability of the broker to stand ready to effect transactions of varying degrees of difficulty in the future ▪ The efficiency of error resolution, clearance and settlement ▪ Block trading and positioning capabilities Page 30 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 12: Brokerage Practices ▪ Performance measurement ▪ Online access to computerized data regarding customer accounts ▪ Availability, comprehensiveness, and frequency of brokerage and research services ▪ Commission rates ▪ The economic benefit to the client ▪ Related matters involved in the receipt of brokerage services Consistent with its fiduciary responsibilities, the firm seeks to ensure that clients receive best execution with respect to clients’ transactions by blocking client trades to reduce commissions and transaction costs. To the best of the firm’s knowledge, these custodians provide high- quality execution, and the firm’s clients do not pay higher transaction costs in return for such execution. Commission rates and securities transaction fees charged to effect such transactions are established by the client’s independent custodian and/or broker-dealer. Based upon its own knowledge of the securities industry, the firm believes that such commission rates are competitive within the securities industry. Lower commissions or better execution may be able to be achieved elsewhere. Security Allocation Since the firm may be managing accounts with similar investment objectives, the firm may aggregate orders for securities for such accounts. In such event, allocation of the securities so purchased or sold, as well as expenses incurred in the transaction, is made by the firm in the manner it considers to be the most equitable and consistent with its fiduciary obligations to such accounts. The firm’s allocation procedures seek to allocate investment opportunities among clients in the fairest possible way, taking into account the clients’ best interests. The firm will follow procedures to ensure that allocations do not involve a practice of favoring or discriminating against any client or group of clients. Account performance is never a factor in trade allocations. The firm’s advice to certain clients and entities and the action of the firm for those and other clients are frequently premised not only on the merits of a particular investment, but also on the suitability of that investment for the particular client in light of his or her applicable investment objective, guidelines and circumstances. Thus, any action of the firm with respect to a particular investment may, for a particular client, differ or be opposed to the recommendation, advice, or actions of the firm to or on behalf of other clients. Order Aggregation Orders for the same security entered on behalf of more than one client will generally be aggregated (i.e., blocked or bunched) subject to the aggregation being in the best interests of all participating clients. Subsequent orders for the same security entered during the same trading day may be aggregated with any previously unfilled orders. Subsequent orders may also be aggregated with filled orders if the market price for the security has not materially changed and the aggregation does not cause any unintended duration exposure. All clients participating Page 31 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 12: Brokerage Practices in each aggregated order will receive the average price and, subject to minimum ticket charges and possible step outs, pay a pro rata portion of commissions. To minimize performance dispersion, “strategy” trades should be aggregated and average priced. However, when a trade is to be executed for an individual account and the trade is not in the best interests of other accounts, then the trade will only be performed for that account. This is true even if the firm believes that a larger size block trade would lead to best overall price for the security being transacted. Allocation of Trades All allocations will be made prior to the close of business on the trade date. In the event an order is “partially filled,” the allocation will be made in the best interests of all the clients in the order, taking into account all relevant factors including, but not limited to, the size of each client’s allocation, clients’ liquidity needs and previous allocations. In most cases, accounts will get a pro forma allocation based on the initial allocation. This policy also applies if an order is “over-filled.” The firm acts in accordance with its duty to seek best price and execution and will not continue any arrangements if the firm determines that such arrangements are no longer in the best interest of its clients. Trade Errors From time to time, the firm may make an error in submitting a trade order on the client’s behalf. When this occurs, the firm may place a correcting trade with the broker-dealer. If an investment gain results from the correcting trade, the gain will remain in client’s account unless the same error involved other client account(s) that should have received the gain, it is not permissible for client to retain the gain, or the firm confers with client and client decides to forego the gain (e.g., due to tax reasons). If the gain does not remain in client’s account and Schwab is the custodian, Schwab will donate the amount of any gain $100 and over to charity. If a loss occurs greater than $100, the firm will pay for the loss. Schwab will maintain the loss or gain (if such gain is not retained in client’s account) if it is under $100 to minimize and offset its administrative time and expense. Generally, if related trade errors result in both gains and losses in client’s account, they may be “netted.” Page 32 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 13: Review of Accounts Item 13: Review of Accounts A. Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved We review accounts at least annually for our clients subscribing to our Comprehensive Portfolio Management Service. The nature of these reviews is to learn whether clients’ accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. Only our financial advisors or portfolio managers will conduct reviews. Financial planning clients do not receive reviews of their written plans unless they take action to schedule a financial consultation with us. We do not provide ongoing services to financial planning clients, but are willing to meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. Retirement Plan Advisory and Consulting Services clients receive reviews of their pension plans for the duration of the Retirement Plan Advisory and Consulting Services. We also provide ongoing services to Retirement Plan Advisory and Consulting Services clients where we meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. B. Review of Client Accounts on Non-Periodic Basis The firm may perform ad hoc reviews on an as-needed basis if there have been material changes in the client’s investment objectives or risk tolerance, or a material change in how the firm formulates investment advice. C. Content of Client-Provided Reports and Frequency Per the Comprehensive Portfolio Management agreement, the firm reports to the client on a quarterly basis or at some other interval agreed upon with the client, information on contributions and withdrawals in the client's investment portfolio, and the performance of the client's portfolio measured against appropriate benchmarks (including benchmarks selected by the client). The client’s independent custodian provides account statements directly to the client no less frequently than quarterly. The custodian’s statement is the official record of the client’s securities account and supersedes any statements or reports created on behalf of the client by the firm. Page 33 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 14: Client Referrals and Other Compensation Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest The firm receives an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors that have their clients maintain accounts at Schwab. These products and services, how they benefit us, and the related conflicts of interest are described above in Item 12: Brokerage Practices. The availability of Schwab’s products and services to us is not based on our giving particular investment advice, such as buying particular securities for our clients. B. Advisory Firm Payments for Client Referrals The firm may enter into arrangements with endorsers, promoters, solicitors, or with clients for testimonials (herein collectively referred to as “endorser”) who will endorse the advisory firm for compensation. Agreements are required when compensation to the endorser is equal to or greater than $1,000. The receipt of such compensation creates a conflict of interest in that the endorser is economically incented to endorse our firm. Please be advised that the firm’s payment of compensation to the endorser does not increase the client’s advisory fee paid to the firm. Page 34 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 15: Custody Item 15: Custody The firm is considered to have custody of client assets for purposes of the Advisers Act for the following reasons: ▪ The client authorizes us to instruct their custodian to deduct our advisory fees directly from the client’s account. The custodian maintains actual custody of clients’ assets. ▪ Our authority to direct client requests, utilizing standing instructions, for wire transfer of funds for first-party money movement and third-party money movement (checks and/or journals, ACH, Fed-wires). The firm has elected to meet the SEC’s seven conditions to avoid the surprise custody exam, as outlined below: 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 the investment adviser, 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. The investment adviser 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. The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. 7. The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Individual advisory clients will receive at least quarterly account statements directly from their custodian containing a description of all activity, cash balances, and portfolio holdings in their accounts. Clients are urged to compare the account balance(s) shown on their account statements to the quarter-end balance(s) on their custodian's monthly statement. The custodian’s statement is the official record of the account. Page 35 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 16: Investment Discretion Item 16: Investment Discretion Clients may grant a limited power of attorney to the firm with respect to trading activity in their accounts by signing the appropriate custodian limited power of attorney form. In those cases, the firm will exercise full discretion as to the nature and type of securities to be purchased and sold and the amount of securities for such transactions. Investment limitations may be designated by the client as outlined in the investment advisory agreement. Page 36 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 17: Voting Client Securities Item 17: Voting Client Securities The firm does not take discretion with respect to voting proxies on behalf of its clients. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. The firm will endeavor to make recommendations to clients on voting proxies regarding shareholder vote, consent, election or similar actions solicited by, or with respect to, issuers of securities beneficially held as part of the firm supervised and/or managed assets. In no event will the firm take discretion with respect to voting proxies on behalf of its clients. Except as required by applicable law, the firm will not be obligated to render advice or take any action on behalf of clients with respect to assets presently or formerly held in their accounts that become the subject of any legal proceedings, including bankruptcies. From time to time, securities held in the accounts of clients will be the subject of class action lawsuits. The firm has no obligation to determine if securities held by the client are subject to a pending or resolved class action lawsuit. The firm also has no duty to evaluate a client’s eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, the firm has no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients. Where the firm receives written or electronic notice of a class action lawsuit, settlement, or verdict affecting securities owned by a client, it will forward all notices, proof of claim forms, and other materials to the client. Electronic mail is acceptable where appropriate and where the client has authorized contact in this manner. Page 37 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure  Item 18: Financial Information Item 18: Financial Information A. Balance Sheet We do not require the prepayment of fees of $1200 or more, six months or more in advance, and as such are not required to file a balance sheet. B. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients We do not have any financial issues that would impair our ability to provide services to clients. C. Bankruptcy Petitions During the Past Ten Years There is nothing to report on this item. Page 38 Part 2A of Form ADV: Fiduciary Financial Partners, LLC, Brochure