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1540 Silver Creek Ln
Montgomery, TX 77316
Form ADV Part 2A – Firm Brochure
346-901-4434
March 10, 2026
This Brochure provides information about the qualifications and business practices of FIFIT LLC, “FIFIT”. If you
have any questions about the contents of this Brochure, please contact us at 346-901-4434. 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.
FIFIT LLC is registered as an Investment Adviser with the Securities and Exchange Commission (“SEC”).
Registration of an Investment Adviser does not imply any level of skill or training.
Additional information about FIFIT LLC is available on the SEC’s website at www.adviserinfo.sec.gov, which
can be found using the firm’s identification number, CRD# 307957.
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Item 2: Material Changes
Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes
materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required
to notify you and provide you with a description of the material changes.
Since our firm’s last annual updating amendment dated February 22, 2026, we have amended this Brochure to
disclose that Scott Udkler, Managing Member of our firm, is also an investment adviser representative of Promus
Asset Management, LLC (“Promus”), an unaffiliated investment adviser registered with the SEC. Please refer to
Item 10 of this Brochure for more information.
In the future, this section of the Brochure will discuss only the specific material changes that were made to the
Brochure and will provide you with a summary of all material changes that have occurred since the last filing of
this Brochure. This section will also identify the date of our last annual Brochure update.
We will ensure that you receive a summary of any material changes to this and subsequent Brochures within 90
days of the close of our business’ fiscal year end which is December 31st. We will provide other ongoing
disclosure information about material changes as they occur. We will also provide you with information on how
to obtain the complete brochure. Currently, our Brochure may be requested at any time, without charge, by
contacting Scott Udkler at 346-901-4434.
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Item 3: Table of Contents
Item 2: Material Changes .......................................................................................................................................... 2
Item 3: Table of Contents .......................................................................................................................................... 3
Item 4: Advisory Business ......................................................................................................................................... 4
Item 5: Fees and Compensation ................................................................................................................................ 7
Item 6: Performance-Based Fees and Side-By-Side Management ............................................................................ 8
Item 7: Types of Clients ............................................................................................................................................ 8
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ..................................................................... 9
Item 9: Disciplinary Information ............................................................................................................................. 12
Item 10: Other Financial Industry Activities and Affiliations ................................................................................. 12
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................ 13
Item 12: Brokerage Practices ................................................................................................................................... 14
Item 13: Review of Accounts .................................................................................................................................. 15
Item 14: Client Referrals and Other Compensation ................................................................................................ 16
Item 15: Custody ..................................................................................................................................................... 16
Item 16: Investment Discretion ............................................................................................................................... 16
Item 17: Voting Client Securities ............................................................................................................................ 17
Item 18: Financial Information ................................................................................................................................ 17
Item 19: Requirements for State-Registered Advisers ............................................................................................ 17
Form ADV Part 2B – Brochure Supplement ........................................................................................................... 19
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Item 4: Advisory Business
Description of Advisory Firm
FIFIT LLC (“FIFIT”) is registered as an Investment Adviser with the Securities and Exchange Commission
(“SEC”). We were founded in March of 2020. Scott Udkler is the principal owner of FIFIT LLC. FIFIT currently
reports $123,061,323 in discretionary Assets Under Management and $0 non-discretionary Assets Under
Management. Assets Under Management were calculated as of December 31, 2025.
Types of Advisory Services
Investment Advisory Services
We are in the business of managing individually tailored investment portfolios. Our firm provides continuous
advice to a Client regarding the investment of Client funds based on the individual needs of the Client. Through
personal discussions in which goals and objectives based on a Client's particular circumstances are established,
we develop a Client's personal investment policy or an investment plan with an asset allocation target and create
and manage a portfolio based on that policy and allocation targets. We may also review and discuss a Client’s
prior investment history, as well as family composition and background.
Account supervision is guided by the stated objectives of the Client (e.g., maximum capital appreciation, growth,
income, or growth, and income), as well as tax considerations. Clients may impose reasonable restrictions on
investing in certain securities, types of securities, or industry sectors. Fees pertaining to this service are outlined in
Item 5 of this brochure.
Financial Planning Services
We provide financial planning services on topics such as retirement planning, risk management, college savings,
cash flow, debt management, work benefits, investment analysis and estate and incapacity planning.
Financial planning is a comprehensive evaluation of a Client's current and future financial state by using currently
known variables to predict future cash flows, asset values, and withdrawal plans. The key defining aspect of
financial planning is that through the financial planning process, all questions, information, and analysis will be
considered as they affect and are affected by the entire financial and life situation of the Client. Clients purchasing
this service will receive a written or an electronic report, providing the Client with a detailed financial plan
designed to achieve his or her stated financial goals and objectives.
This service involves working one-on-one with a planner over an extended period of time. By paying a fixed
annual fee, paid on a monthly basis in arrears, Clients get to work with a planner who will work with them to
develop, implement their plan and recommend any changes on an on-going basis and ensure the plan is up to date.
These areas may include, but are not limited to, the following:
● Business Planning: We provide consulting services for Clients who currently operate their own business,
are considering starting a business, or are planning for an exit from their current business. Under this type
of engagement, we work with you to assess your current situation, identify your objectives, and develop a
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plan aimed at achieving your goals.
● Cash Flow and Debt Management: We will conduct a review of your income and expenses to
determine your current surplus or deficit along with advice on prioritizing how any surplus should be
used or how to reduce expenses if they exceed your income. Advice may also be provided on which debts
to pay off first based on factors such as the interest rate of the debt and any income tax ramifications. We
may also recommend what we believe to be an appropriate cash reserve that should be considered for
emergencies and other financial goals, along with a review of accounts (such as money market funds) for
such reserves, plus strategies to save desired amounts.
● College Savings: Includes projecting the amount that will be needed to achieve college or other post-
secondary education funding goals, along with advice on ways for you to save the desired amount.
Recommendations as to savings strategies are included, and, if needed, we will review your financial
picture as it relates to eligibility for financial aid or the best way to contribute to grandchildren (if
appropriate).
● Employee Benefits Optimization: We will provide review and analysis as to whether you, as an
employee, are taking the maximum advantage possible of your employee benefits. If you are a business
owner, we will consider and/or recommend the various benefit programs that can be structured to meet
both business and personal retirement goals.
● Estate Planning: This usually includes an analysis of your exposure to estate taxes and your current
estate plan, which may include whether you have a will, powers of attorney, trusts, and other related
documents. Our advice also typically includes ways for you to minimize or avoid future estate taxes by
implementing appropriate estate planning strategies such as the use of applicable trusts. We always
recommend that you consult with a qualified attorney when you initiate, update, or complete estate
planning activities. We may provide you with contact information for attorneys who specialize in estate
planning when you wish to hire an attorney for such purposes. From time-to-time, we will participate in
meetings or phone calls between you and your attorney with your approval or request.
● Financial Goals: We will help Clients identify financial goals and develop a plan to reach them. We will
identify what you plan to accomplish, what resources you will need to make it happen, how much time
you will need to reach the goal, and how much you should budget for your goal.
● Insurance: Review of existing policies to ensure proper coverage for life, health, disability, long-term
care, liability, home, and automobile.
● Investment Analysis: This may involve developing an asset allocation strategy to meet Clients’ financial
goals and risk tolerance, providing information on investment vehicles and strategies, reviewing
employee stock options, as well as assisting you in establishing your own investment account at a selected
broker/dealer or custodian. The strategies and types of investments we may recommend are further
discussed in Item 8 of this brochure.
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● Retirement Planning: Our retirement planning services typically include projections of your likelihood
of achieving your financial goals, typically focusing on financial independence as the primary objective.
For situations where projections show less than the desired results, we may make recommendations,
including those that may impact the original projections by adjusting certain variables (e.g., working
longer, saving more, spending less, taking more risk with investments).
If you are near retirement or already retired, advice may be given on appropriate distribution strategies to
minimize the likelihood of running out of money or having to adversely alter spending during your
retirement years.
● Risk Management: A risk management review includes an analysis of your exposure to major risks that
could have a significant adverse impact on your financial picture, such as premature death, disability,
property and casualty losses, or the need for long‐term care planning. Advice may be provided on ways to
minimize such risks and about weighing the costs of purchasing insurance versus the benefits of doing so
and, likewise, the potential cost of not purchasing insurance (“self‐insuring”).
● Tax Planning Strategies: Advice may include ways to minimize current and future income taxes as a
part of your overall financial planning picture. For example, we may make recommendations on which
type of account(s) or specific investments should be owned based in part on their “tax efficiency,” with
the consideration that there is always a possibility of future changes to federal, state or local tax laws and
rates that may impact your situation.
We recommend that you consult with a qualified tax professional before initiating any tax planning
strategy, and we may provide you with contact information for accountants or attorneys who specialize in
this area if you wish to hire someone for such purposes. We will participate in meetings or phone calls
between you and your tax professional with your approval.
Client Tailored Services and Client Imposed Restrictions
We offer the same suite of services to all of our Clients. However, specific Client financial plans and their
implementation are dependent upon the Client Investment Policy Statement which outlines each Client’s current
situation (income, tax levels, and risk tolerance levels) and is used to construct a Client specific plan to aid in the
selection of a portfolio that matches Client imposed restrictions on asset types or other restrictions, needs, and
targets.
Wrap Fee Programs
We do not participate in wrap fee programs.
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Item 5: Fees and Compensation
Please note, unless a Client has received the firm’s Disclosure Brochure at least 48 hours prior to signing the
investment advisory contract, the investment advisory contract may be terminated by the Client within five (5)
business days of signing the contract without incurring any advisory fees. How we are paid depends on the type of
advisory service we are performing. Please review the fee and compensation information below.
Investment Advisory Services
Our standard advisory fee is based on the market value of the assets under management and is calculated as
follows:
Account Value
Annual Advisory Fee
0.50%
$0 - $1,000,000
0.40%
$1,000,000 and Above
The annual fees are negotiable and are pro-rated and paid in arrears on a monthly or quarterly basis. The advisory
fee is a blended fee and is calculated by assessing the percentage rates using the predefined levels of assets as shown
in the above chart resulting in a combined weighted fee. In this calculation we use your average daily balance and
do not include accrued interest in the calculation. For example, an account valued at $2,000,000 would pay an
effective fee of 0.45% with the annual fee of $9,000.00. The monthly or quarterly fee is determined by the following
calculation: (($1,000,000 x 0.50%) + ($1,000,000 x 0.40%)) ÷ 4 = $2,250 quarterly or (($1,000,000 x 0.50%) +
($1,000,000 x 0.40%)) ÷ 12 = $750 monthly. No increase in the annual fee shall be effective without agreement
from the Client by signing a new agreement or amendment to their current advisory agreement.
Advisory fees are directly debited from Client accounts, or the Client may choose to pay by check. Accounts
initiated or terminated during a calendar quarter will be charged a pro-rated fee based on the amount of time
remaining in the billing period. An account may be terminated with written notice at least 15 calendar days in
advance. Since fees are paid in arrears, no refund will be needed upon termination of the account.
Financial Planning Services
This service is no longer offered as a stand alone service. Clients who are currently enrolled in this service will
remain active. Financial Planning will be offered on a fixed fee basis below:
Net Worth (Minus Primary Residence)
$0 - $100,000
$100,001 - $250,000
$250,001 - $500,000
$500,001 - $750,000
$750,001 - $1,000,000
$1,000,001 - $1,500,000
$1,500,001 - $2,000,000
Every additional $1 million in excess of $2 million
Annual Fee
$360
$1,200
$2,400
$3,600
$4,800
$6,000
$7,500
$1,500
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The fixed fee will be billed monthly in arrears and is negotiable. FIFIT LLC will not bill an amount above
$500.00 more than 6 months in advance. Fees for this service may be paid by electronic funds transfer or check.
In the event of early termination any prepaid but unearned fees will be refunded to the Client, and any completed
deliverables of the project will be provided to the Client and no further fees will be charged. Fees for Financial
Planning Services will be waived for Clients who are serviced in our Investment Advisory Services.
Other Types of Fees and Expenses
Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which
may be incurred by the Client. Clients may incur certain charges imposed by custodians, brokers, and other third
parties such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer, and
electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual fund and
exchange-traded funds also charge internal management fees, which are disclosed in a fund's prospectus. Such
charges, fees, and commissions are exclusive of and in addition to our fee, and we shall not receive any portion of
these commissions, fees, and costs.
Item 12 further describes the factors that we consider in selecting or recommending broker-dealers for Client’s
transactions and determining the reasonableness of their compensation (e.g., commissions).
We do not accept compensation for the sale of securities or other investment products including asset-based sales
charges or service fees from the sale of mutual funds.
Item 6: Performance-Based Fees and Side-By-
Side Management
We do not offer performance-based fees and do not engage in side-by-side management.
Item 7: Types of Clients
We provide financial planning and portfolio management services to individuals, high net-worth individuals,
banking or thrift institutions, investment companies, business development companies, pool investment vehicles,
pension and profiting sharing plans, charitable organizations, corporations or other businesses, state or municipal
government entities, other investment advisers, insurance companies.
We do not have a minimum account size requirement.
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Item 8: Methods of Analysis, Investment
Strategies and Risk of Loss
Our primary methods of investment analysis include the use of modern portfolio theory and an asset allocation
approach to investment management.
Modern Portfolio Theory
The underlying principles of MPT are:
•
Investors are risk averse. The only acceptable risk is that which is adequately compensated by an
expected return. Risk and investment return are related and an increase in risk requires an increase
expected return.
• Markets are efficient. The same market information is available to all investors at the same time. The
market prices every security fairly based upon this equal availability of information.
•
• The design of the portfolio as a whole is more important than the selection of any particular security. The
appropriate allocation of capital among asset classes will have far more influence on long-term portfolio
performance than the selection of individual securities. Investing for the long-term (preferably longer than
ten years) becomes critical to investment success because it allows the long-term characteristics of the
asset class to surface.
Increasing diversification of the portfolio with lower correlated asset class positions can decrease
portfolio risk. Correlation is the statistical term for the extent to which two asset classes move in tandem
or opposition to one another.
Asset Allocation is the focus of our investment strategy. In the portfolio construction process, we focus not only
asset classes such as equities, fixed income and cash, but also on investment strategy styles such as active and
passive. We believe that diversification across both asset classes and investment strategies is critical for achieving
an attractive reward-to-risk ratio in the portfolio. Through strategic asset allocation, we construct our long-term
targets weights for asset classes and strategies based on the Client’s time horizon, risk tolerance, and required rate
of return to meet his or her financial goals.
Fundamental analysis involves analyzing individual companies and their industry groups, such as a company’s
financial statements, details regarding the company’s product line, the experience, and expertise of the company’s
management, and the outlook for the company’s industry. The resulting data is used to measure the true value of
the company’s stock compared to the current market value. The risk of fundamental analysis is that the
information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which
may be the basis for a stock’s value. If securities prices adjust rapidly to new information, utilizing fundamental
analysis may not result in favorable performance.
Technical analysis involves using chart patterns, momentum, volume, and relative strength in an effort to pick
sectors that may outperform market indices. However, there is no assurance of accurate forecasts or that trends will
develop in the markets we follow. In the past, there have been periods without discernible trends and similar periods
will presumably occur in the future. Even where major trends develop, outside factors like government intervention
could potentially shorten them.
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Furthermore, one limitation of technical analysis is that it requires price movement data, which can translate into
price trends sufficient to dictate a market entry or exit decision. In a trendless or erratic market, a technical method
may fail to identify trends requiring action. In addition, technical methods may overreact to minor price movements,
establishing positions contrary to overall price trends, which may result in losses. Finally, a technical trading method
may underperform other trading methods when fundamental factors dominate price moves within a given market.
Cyclical analysis is a type of technical analysis that involves evaluating recurring price patterns and trends based
upon business cycles. Economic/business cycles may not be predictable and may have many fluctuations
between long-term expansions and contractions. The lengths of economic cycles may be difficult to predict with
accuracy and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and
consequently the changing value of securities that would be affected by these changing trends.
Charting analysis involves the gathering and processing of price and volume information for a particular
security. This price and volume information is analyzed using mathematical equations. The resulting data is then
applied to graphing charts, which is used to predict future price movements based on price patterns and trends.
Charts may not accurately predict future price movements. Current prices of securities may not reflect all
information about the security and day-to-day changes in market prices of securities may follow random patterns
and may not be predictable with any reliable degree of accuracy.
Passive Investment Management
Passive investing involves building portfolios that are comprised of various distinct asset classes. The asset classes
are weighted in a manner to achieve the desired relationship between correlation, risk, and return. Funds that
passively capture the returns of the desired asset classes are placed in the portfolio. The funds that are used to build
passive portfolios are typically index mutual funds or exchange-traded funds.
Passive investment management is characterized by low portfolio expenses (i.e., the funds inside the portfolio have
low internal costs), minimal trading costs (due to infrequent trading activity), and relative tax efficiency (because
the funds inside the portfolio are tax efficient and turnover inside the portfolio is minimal).
In contrast, active management involves a single manager or managers who employ some method, strategy, or
technique to construct a portfolio that is intended to generate returns that are greater than the broader market or a
designated benchmark. Academic research indicates most active managers underperform the market.
Material Risks Involved
All investing strategies we offer involve risk and may result in a loss of your original investment which you
should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities, and any other
investment or security. Material risks associated with our investment strategies are listed below.
Market Risk: Market risk involves the possibility that an investment’s current market value will fall because of a
general market decline, reducing the value of the investment regardless of the operational success of the issuer’s
operations or its financial condition.
Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended.
Small and Medium Cap Company Risk: Securities of companies with small and medium market capitalizations
are often more volatile and less liquid than investments in larger companies. Small and medium cap companies
may face a greater risk of business failure, which could increase the volatility of the Client’s portfolio.
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Turnover Risk: At times, the strategy may have a portfolio turnover rate that is higher than other strategies. A
high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in
the distribution of additional capital gains for tax purposes. These factors may negatively affect the account’s
performance.
Limited markets: Certain securities may be less liquid (harder to sell or buy) and their prices may at times be
more volatile than at other times. Under certain market conditions, we may be unable to sell or liquidate
investments at prices we consider reasonable or favorable or find buyers at any price.
Concentration Risk: Certain investment strategies focus on particular asset-classes, industries, sectors or types of
investment. From time to time these strategies may be subject to greater risks of adverse developments in such
areas of focus than a strategy that is more broadly diversified across a wider variety of investments.
Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall
below par value or the principal investment. The opposite is also generally true: bond prices generally rise when
interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these price
changes. Most other investments are also sensitive to the level and direction of interest rates.
Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or the
securities’ claim on the issuer’s assets and finances.
Inflation: Inflation may erode the buying power of your investment portfolio, even if the dollar value of your
investments remains the same.
Risks Associated with Securities
Apart from the general risks outlined above which apply to all types of investments, specific securities may have
other risks.
Commercial Paper is, in most cases, an unsecured promissory note that is issued with a maturity of 270 days or
less. Being unsecured the risk to the investor is that the issuer may default.
Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s bankruptcy or
restructuring could lose all value. A slower-growth or recessionary economic environment could have an adverse
effect on the price of all stocks.
Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest and
repay the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively,
investors can purchase other debt securities, such as zero coupon bonds, which do not pay current interest, but
rather are priced at a discount from their face values and their values accrete over time to face value at maturity.
The market prices of debt securities fluctuate depending on factors such as interest rates, credit quality, and
maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest
rates fall. The longer the time to a bond’s maturity, the greater its interest rate risk.
Bank Obligations including bonds and certificates of deposit may be vulnerable to setbacks or panics in the
banking industry. Banks and other financial institutions are greatly affected by interest rates and may be adversely
affected by downturns in the U.S. and foreign economies or changes in banking regulations.
Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes, including the
construction of public facilities. Municipal bonds pay a lower rate of return than most other types of bonds.
However, because of a municipal bond’s tax-favored status, investors should compare the relative after-tax return
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to the after-tax return of other bonds, depending on the investor’s tax bracket. Investing in municipal bonds
carries the same general risks as investing in bonds in general. Those risks include interest rate risk, reinvestment
risk, inflation risk, market risk, call or redemption risk, credit risk, and liquidity and valuation risk.
Options and other derivatives carry many unique risks, including time-sensitivity, and can result in the complete
loss of principal. While covered call writing does provide a partial hedge to the stock against which the call is
written, the hedge is limited to the amount of cash flow received when writing the option. When selling covered
calls, there is a risk the underlying position may be called away at a price lower than the current market price.
Exchange Traded Funds prices may vary significantly from the Net Asset Value due to market conditions.
Certain Exchange Traded Funds may not track underlying benchmarks as expected. ETFs are also subject to the
following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii)
the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares
may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the
exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices)
halts stock trading generally. The Adviser has no control over the risks taken by the underlying funds in which the
Clients invest.
Investment Companies Risk. When a Client invests in open-end mutual funds or ETFs, the Client indirectly
bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will
incur higher expenses, many of which may be duplicative. In addition, the Client's overall portfolio may be
affected by losses of an underlying fund and the level of risk arising from the investment practices of an
underlying fund (such as the use of derivatives).
Item 9: Disciplinary Information
Criminal or Civil Actions
FIFIT LLC and its management have not been involved in any criminal or civil action.
Administrative Enforcement Proceedings
FIFIT LLC and its management have not been involved in administrative enforcement proceedings.
Self-Regulatory Organization Enforcement Proceedings
FIFIT LLC and its management have not been involved in legal or disciplinary events that are material to a
Client’s or prospective Client’s evaluation of FIFIT LLC or the integrity of its management.
Item 10: Other Financial Industry Activities and
Affiliations
No FIFIT LLC employee is registered, or have an application pending to register, as a broker-dealer or a
registered representative of a broker-dealer.
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No FIFIT LLC employee is registered, or have an application pending to register, as a futures commission
merchant, commodity pool operator or a commodity trading advisor.
FIFIT LLC only receives compensation directly from Clients. We do not receive compensation from any outside
source.
Scott Udkler, Managing Member of our firm, is also an investment adviser representative of Promus Asset
Management, LLC (“Promus”), an unaffiliated investment adviser registered with the SEC. Mr. Udkler’s
affiliation with Promus is intended to facilitate business continuity through access to Promus’ operational
infrastructure, including investment management, technology, back-office, and compliance support.
With client consent, Mr. Udkler anticipates transitioning advisory client relationships from the firm to Promus as
part of this business continuity arrangement. Upon completion of this transition, the firm expects to take steps to
withdraw its registration as an investment adviser and Mr. Udkler will remain an investment adviser
representative with Promus.
Disclosure of Material Conflicts
All material conflicts of interest under are disclosed regarding FIFIT LLC, its representatives or any of its
employees, which could be reasonably expected to impair the rendering of unbiased and objective advice.
Item 11: Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading
As a fiduciary, our firm and its associates have a duty of utmost good faith to act solely in the best interests of
each Client. Our Clients entrust us with their funds and personal information, which in turn places a high standard
on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the expected
basis of all of our dealings. The firm also adheres to the Code of Ethics and Professional Responsibility adopted
by the CFP® Board of Standards Inc., and accepts the obligation not only to comply with the mandates and
requirements of all applicable laws and regulations but also to take responsibility to act in an ethical and
professionally responsible manner in all professional services and activities.
Code of Ethics Description
This code does not attempt to identify all possible conflicts of interest, and literal compliance with each of its
specific provisions will not shield associated persons from liability for personal trading or other conduct that violates
a fiduciary duty to advisory Clients. A summary of the Code of Ethics' Principles is outlined below.
•
Integrity - Associated persons shall offer and provide professional services with integrity.
•
Objectivity - Associated persons shall be objective in providing professional services to Clients.
•
Competence - Associated persons shall provide services to Clients competently and maintain the necessary
knowledge and skill to continue to do so in those areas in which they are engaged.
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•
Fairness - Associated persons shall perform professional services in a manner that is fair and reasonable to
Clients, principals, partners, and employers, and shall disclose conflict(s) of interest in providing such
services.
•
Confidentiality - Associated persons shall not disclose confidential Client information without the specific
consent of the Client unless in response to proper legal process, or as required by law.
• Professionalism - Associated persons' conduct in all matter shall reflect the credit of the profession.
•
Diligence - Associated persons shall act diligently in providing professional services.
We periodically review and amend our Code of Ethics to ensure that it remains current, and we require all firm
access persons to attest to their understanding of and adherence to the Code of Ethics at least annually. Our firm
will provide a copy of its Code of Ethics to any Client or prospective Client upon request.
Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest
Neither our firm, its associates or any related person is authorized to recommend to a Client or effect a transaction
for a Client, involving any security in which our firm or a related person has a material financial interest, such as
in the capacity as an underwriter, adviser to the issuer, etc.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest
Our firm and its “related persons” may buy or sell securities similar to, or different from, those we recommend to
Clients for their accounts. In an effort to reduce or eliminate certain conflicts of interest involving the firm or
personal trading, our policy may require that we restrict or prohibit associates’ transactions in specific reportable
securities transactions. Any exceptions or trading pre-clearance must be approved by the firm principal in advance
of the transaction in an account, and we maintain the required personal securities transaction records per
regulation.
Trading Securities At/Around the Same Time as Client’s Securities
From time to time, or its “related persons” may buy or sell securities for themselves at or around the same time as
Clients. Related persons are prohibited from placing trades ahead of Clients unless the trade would be deemed
less favorable to the Client (for example, purchasing shares for a Client and then a related person placing a
purchase order immediately after).
Item 12: Brokerage Practices
Factors Used to Select Custodians and/or Broker-Dealers
FIFIT LLC does not have any affiliation with Broker-Dealers. Specific custodian recommendations are made to
the Client based on their need for such services. We recommend custodians based on the reputation and services
provided by the firm.
1. Research and Other Soft-Dollar Benefits
We currently do not receive soft dollar benefits.
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2. Brokerage for Client Referrals
We receive no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party.
3. Clients Directing Which Broker/Dealer/Custodian to Use
We do recommend a specific custodian for Clients to use, however, Clients may custody their assets at a
custodian of their choice. Clients may also direct us to use a specific broker-dealer to execute transactions. By
allowing Clients to choose a specific custodian, we may be unable to achieve the most favorable execution of
Client transaction, and this may cost Clients money over using a lower-cost custodian.
The Custodians and Brokers We Use
It is our policy that your funds and securities are held in accounts maintained by a qualified custodian
independent of FIFIT LLC with periodic statements delivered directly to you from the custodian. These
statements describe all activity and balances in your custodial accounts. For most of our clients, this
independent custodian is Fidelity Investments (National Financial Services, Fidelity Brokerage Services LLC) or
Schwab Advisor Services (Charles Schwab & Company).
We may prepare reports detailing your portfolio balances. We urge you to compare the account statement you
receive from your independent custodian to the statements provided by us. Our statements may vary modestly
from the custodial statement based on accounting procedures, reporting dates, or valuation methods of certain
securities. If you have any questions regarding this comparison, you should ask us. For tax and other purposes,
the custodial statement and related tax forms are the official record of your account(s) and assets.
FIDELITY INVESTMENTS
FIFIT LLC is an independent organization and is not affiliated with Fidelity Investments. Brokerage services
provided by Fidelity Brokerage Services LLC (FBS), Member NYSE, SIPC. Brokerage accounts carried with National
Financial Services LLC (NFS), Member NYSE, SIPC
SCHWAB ADVISOR SERVICES (Charles Schwab & Company)
FIFIT LLC is an independent organization and is not affiliated with Charles Schwab & Co. Charles Schwab & Co.,
Inc., a registered broker-dealer, member FINRA and SIPC (“Schwab”).
(Please see the disclosure under Item 14 below.)
Item 13: Review of Accounts
Client accounts with the Investment Advisory Service will be reviewed regularly at a minimum on a yearly basis
by Scott Udkler, Managing Member and CCO. The account is reviewed with regards to the Client’s investment
policies and risk tolerance levels. Events that may trigger a special review would be unusual performance,
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addition or deletions of Client imposed restrictions, excessive draw-down, volatility in performance, or buy and
sell decisions from the firm or per Client's needs.
Clients will receive trade confirmations from the broker(s) for each transaction in their accounts as well as
monthly or quarterly statements and annual tax reporting statements from their custodian showing all activity in
the accounts, such as receipt of dividends and interest.
FIFIT LLC will not provide written reports to Investment Advisory Clients.
Item 14: Client Referrals and Other
Compensation
We do not receive any economic benefit, directly or indirectly, from any third party for advice rendered to our
Clients. Nor do we, directly or indirectly, compensate any person who is not advisory personnel for Client
referrals.
Item 15: Custody
FIFIT LLC does not accept custody of Client funds except in the instance of withdrawing Client fees.
For Client accounts in which FIFIT LLC directly debits their advisory fee:
i.
ii.
iii.
FIFIT LLC will send a copy of its invoice to the custodian at the same time that it sends the Client a copy.
The custodian will send at least quarterly statements to the Client showing all disbursements for the account,
including the amount of the advisory fee.
The Client will provide written authorization to FIFIT LLC, permitting them to be paid directly for their
accounts held by the custodian.
Clients should receive at least quarterly statements from the broker-dealer, bank or other qualified custodian that
holds and maintains Client's investment assets. We urge you to carefully review such statements and compare such
official custodial records to the account statements or reports that we may provide to you. Our statements or reports
may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies
of certain securities.
Advisor is not affiliated with the custodians. The custodians do not supervise the advisor, its agents or activities.
Item 16: Investment Discretion
For those Client accounts where we provide Investment Advisory Services, we maintain discretion over Client
accounts with respect to securities to be bought and sold and the amount of securities to be bought and sold.
Investment discretion is explained to Clients in detail when an advisory relationship has commenced. At the start
of the advisory relationship, the Client will execute a Limited Power of Attorney, which will grant our firm
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discretion over the account. Additionally, the discretionary relationship will be outlined in the advisory contract
and signed by the Client.
Item 17: Voting Client Securities
We do not vote Client proxies. Therefore, Clients maintain exclusive responsibility for: (1) voting proxies, and (2)
acting on corporate actions pertaining to the Client’s investment assets. The Client shall instruct the Client’s
qualified custodian to forward to the Client copies of all proxies and shareholder communications relating to the
Client’s investment assets. If the Client would like our opinion on a particular proxy vote, they may contact us at
the number listed on the cover of this brochure.
In most cases, you will receive proxy materials directly from the account custodian. However, in the event we
were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless
you have authorized our firm to contact you by electronic mail, in which case, we would forward you any
electronic solicitation to vote proxies.
Item 18: Financial Information
Registered Investment Advisers are required in this Item to provide you with certain financial information or
disclosures about our financial condition. We have no financial commitment that impairs our ability to meet
contractual and fiduciary commitments to Clients, and we have not been the subject of a bankruptcy proceeding.
We do not have custody of Client funds or securities or require or solicit prepayment of more than $500 in fees
per Client six months in advance.
Item 19: Requirements for State-Registered
Advisers
Other Business Activities
No other business activities to report.
FIFIT LLC is registered with the SEC and not registered with any state.
Performance-Based Fees
FIFIT LLC is not compensated by performance-based fees.
Please refer to Item 6 of this brochure.
FIFIT LLC is registered with the SEC and not registered with any state.
Material Disciplinary Disclosures
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No management person at FIFIT LLC has ever been involved in an arbitration claim of any kind or been found
liable in a civil, self-regulatory organization, or administrative proceeding.
FIFIT LLC is registered with the SEC and not registered with any state.
Material Relationships That Management Persons Have With Issuers of Securities
FIFIT LLC, nor Scott Udkler, have any relationship or arrangement with issuers of securities, in addition to what
is described in Item 10.
FIFIT LLC is registered with the SEC and not registered with any state.
Additional Compensation
Scott Udkler does not receive any economic benefit from any person, company, or organization, in exchange for
providing Clients advisory services through FIFIT LLC.
FIFIT LLC is registered with the SEC and not registered with any state.
Supervision
Scott Udkler, as Managing Member and Chief Compliance Officer of FIFIT LLC, is responsible for supervision.
He may be contacted at the phone number on this brochure supplement.
FIFIT LLC is registered with the SEC and not registered with any state.
Requirements for State Registered Advisers
Scott Udkler has NOT been involved in an arbitration, civil proceeding, self-regulatory proceeding, administrative
proceeding, or a bankruptcy petition.
FIFIT LLC is registered with the SEC and not registered with any state.
Business Continuity Plan
FIFIT LLC maintains a written Business Continuity Plan that identifies procedures related to an emergency or
significant business disruptions, including the death of the investment adviser or any of its representatives.
FIFIT LLC is registered with the SEC and not registered with any state.
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FIFIT LLC
1540 Silver Creek Ln
Montgomery, TX 77316
346-901-4434
Dated March 10, 2026
Form ADV Part 2B – Brochure Supplement
For
Scott Udkler
CRD# 5508273
Managing Member, and Chief Compliance Officer
This brochure supplement provides information about Scott Udkler that supplements the FIFIT LLC (“FIFIT”)
brochure. A copy of that brochure precedes this supplement. Please contact Scott Udkler if the FIFIT brochure is
not included with this supplement or if you have any questions about the contents of this supplement.
Additional information about Scott Udkler is available on the SEC’s website at www.adviserinfo.sec.gov which
can be found using the identification number 5508273.
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Item 2: Educational Background and Business
Experience
Scott Udkler
Born: 1986
Educational Background
• 2010 – Bachelor of Business Administration in Accounting, University of Houston – Downtown
Houston, TX
Business Experience
June 2016 – February 2020, Charles Schwab & Company, VP Financial Consultant
June 2010 – September 2015, Fidelity Investments, Financial Consultant
• February 2026 – Present, Promus Asset Management, LLC, Investment Adviser Representative
• February 2020 – Present, FIFIT LLC, Managing Member and CCO
• February 2020 – February 2023, Bearfoot Companies LLC, Finance Manager
•
• February 2016 – May 2016, JP Morgan Securities, Private Client Advisor
• September 2015 – February 2016, Udkler Financial, Managing Member and CCO
•
• August 2008 – June 2010, Next Financial Group, Inc., Registered Representative
Professional Designations, Licensing & Exams
CFP® 2012
Kaplan University, La Crosse, WI
CFP (Certified Financial Planner)®: The CERTIFIED FINANCIAL PLANNER™, CFP® and federally
registered CFP (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks
granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial
planners to hold CFP® certification. It is recognized in the United States and a number of other countries for
its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3)
ethical requirements that govern professional engagements with Clients. Currently, more than 71,000
individuals have obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
● Education – Complete an advanced college-level course of study addressing the financial planning subject
areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of
financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college
or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include
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insurance planning and risk management, employee benefits planning, investment planning, income tax
planning, retirement planning, and estate planning;
● Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case
studies and Client scenarios designed to test one's ability to correctly diagnose financial planning issues and
apply one's knowledge of financial planning to real-world circumstances;
● Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
● Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents outlining
the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements in
order to maintain the right to continue to use the CFP® marks:
● Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence
and keep up with developments in the financial planning field; and
● Ethics – Renew an agreement to be bound by the Standards of Professional Conduct.
The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary
standard of care. This means CFP® professionals must provide financial planning services in the best interests
of their Clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP
Board’s enforcement process, which could result in suspension or permanent revocation of their
CFP® certification.
Item 3: Disciplinary Information
No management person at FIFIT LLC has ever been involved in an arbitration claim of any kind or been found
liable in a civil, self-regulatory organization, or administrative proceeding.
Item 4: Other Business Activities
Scott Udkler, Managing Member of our firm, is also an investment adviser representative of Promus Asset
Management, LLC (Promus), an unaffiliated investment adviser registered with the SEC. Please refer to Item 10
of our firm’s ADV Part 2A for more information.
Item 5: Additional Compensation
Scott Udkler does not receive any economic benefit from any person, company, or organization, in exchange for
providing Clients advisory services through FIFIT. Mr. Udkler will receive fees in his capacity as an investment
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adviser representative of Promus Asset Management, LLC. Please refer to Item 10 of our firm’s ADV Part 2A for
more information.
Item 6: Supervision
Scott Udkler, Managing Member and Chief Compliance Officer of FIFIT, is responsible for supervision. He may
be contacted at the phone number on this brochure supplement.
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