FINANCIAL ADVISORY PARTNERS, LLC

Financial Advisory Partners, LLC 1201 S. Orlando Avenue; Suite 350 Winter Park, FL 32789 Telephone: 407-478-6314 Fax: 407-478-6314 January 21, 2026 PART 2A - APPENDIX 1 WRAP FEE PROGRAM BROCHURE This Brochure provides information about the qualifications and business practices of Financial Advisory Partners, LLC. If you have any questions about the contents of this Brochure, please contact us at 407- 461-7240. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Financial Advisory Partners, LLC is available on the SEC's website at www.adviserinfo.sec.gov. Financial Advisory Partners, LLC is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. 1  Item 2 Summary of 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 last annual updating amendment, dated March 18, 2025, we have the following material changes to our Form ADV Part 2. We have updated this Brochure to disclose an update to our firm’s ownership structure resulting from planned business continuity and succession plans. There have been no changes to our firm’s day-to-today business operations. Please refer to Item 4 of this Brochure for more information. Please contact us if you have any questions about these changes. 2  Item 3 Table of Contents Item 2 Summary of Material Changes ................................................................................. 2 Item 3 Table of Contents ..................................................................................................... 3 Item 4 Services, Fees, and Compensation .......................................................................... 4 Item 5 Account Requirements and Types of Clients ............................................................ 8 Item 6 Portfolio Manager Selection and Evaluation ............................................................. 9 Item 7 Client Information Provided to Portfolio Managers ................................................. 14 Item 8 Client Contact with Portfolio Managers................................................................... 14 Item 9 Additional Information ............................................................................................ 14 3  Item 4 Services, Fees, and Compensation Description of Firm Financial Advisory Partners, LLC is a registered investment adviser based in Winter Park, FL. We are organized as a limited liability company ("LLC") under the laws of the State of Florida. Our firm has been a legal entity since 2008, and our firm has been providing investment advisory services since November 2020. We are primarily owned by Alexander van den Berg and David Sutphin, each with over 35 years in the financial industry. Our firm also has minority owners. NBC Holdings, LLC, Northstar Bank, and Pierre Allard each hold minority ownership interests in our firm. Please refer to Item 10 of this Brochure for more information on our firm’s affiliates. The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this Brochure, the words "we," "our," and "us" refer to Financial Advisory Partners, LLC and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. Wrap Fee Program - Portfolio Management Services We offer portfolio management services through a wrap-fee program ("Program") as described in this Wrap Fee Program Brochure. We are the sponsor and investment adviser for the Program. We also use unaffiliated third-party manager(s), namely NBC Asset Management (doing business on behalf of NBC Securities), to assist with managing portfolios. A wrap-fee program is a type of investment program that provides clients with portfolio management and brokerage services for one all-inclusive fee. Prior to becoming a client under the Program, you will be required to enter into a separate written agreement with us that sets forth the terms and conditions of the engagement and describes the scope of the services to be provided, and the fees to be paid. If you participate in our wrap fee program, you will pay our firm a single fee, which includes our investment advisory and portfolio management services, custodial services, and the securities transactions associated with your account(s). You are not charged separate fees for the respective components of the total services. We receive a portion of the wrap fee for our services. The overall cost you will incur if you participate in our wrap fee program may be higher or lower than you might incur by separately purchasing the types of securities available. Client Investment Process We offer discretionary portfolio management services tailored to meet our clients' needs and investment objectives. If you engage our firm for discretionary portfolio management services, we require you to grant our firm discretionary authority that will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. This discretionary authority will also provide our firm with authorization to delegate discretionary management services to other unaffiliated third-party managers selected by our firm based on your investment objectives and/or determined portfolio strategy. In our sole discretion, we may accept instructions from you that limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account). Such requests must be presented to our firm in writing. If you enter into non-discretionary arrangements with our firm, we will obtain your approval prior to the execution of any transactions for your account(s). We will regularly monitor the performance of your accounts managed by the selected third-party manager, and may hire and fire any third-party manager in our sole discretion. When determining 4  the third-party manager, the client’s best interest will be the main determining factor. Other factors that we take into consideration include, but are not limited to, the third-party manager's services, performance, investment strategies, fees, and other added value that we believe will benefit our clients. To compare the cost of the wrap fee program with non-wrap fee portfolio management services, you should consider the frequency of trading activity associated with our investment strategies and the brokerage commissions charged by respective broker-dealer/custodian and the advisory fees charged by our firm in comparison to other registered investment advisers. investment objectives, risk Changes in Your Financial Circumstances In providing the contracted services, we are not required to verify any information we receive from you or from your other professionals (e.g., attorney, accountant, etc.) and we are expressly authorized to rely on the information you provide. Furthermore, unless you indicate to the contrary, we shall assume that there are no restrictions on our services, other than to manage your account in accordance with your designated time horizon (collectively, "investment tolerance, and parameters"). It is your responsibility to promptly notify us if there are ever any changes in your financial situation or investment parameters for the purpose of reviewing, evaluating, and/or revising our previous recommendations and services. The Program Fee We charge an annual "wrap-fee" for participation in the Program where you will pay our firm a single fee, which covers portfolio management fees, custodial service fees, and the associated costs of the related securities transaction. Our annual fee is based on a percentage of the assets in your account, which ranges up to 2.00% (inclusive of any third-party manager fees). The annual portfolio management fee is billed and payable quarterly in advance based on the value of your account on the last business day of the previous quarter. If the portfolio management agreement is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. Our advisory fee is negotiable, depending on individual client circumstances. Where we use the services of a third-party manager to assist with your investments, we will pay a portion of our advisory fee to the third-party managers. For clients where a managed Futures Mutual Fund advised by PIMCO (symbol PQTIX) and/or a non- traded /limited liquidity Real Estate Investment Trust BREIT managed/advised by Blackstone are included in their allocation, our annual fee for management services is 0.75%. Clients may also incur additional management and/or performance fees imposed by unaffiliated managers. As part of extending this investment opportunity to clients, we will review the investment and respective management fees with all relative clients prior to moving forward with the investment. The minimum account size for each strategy will be $50,000. Our fees for portfolio management services will be deducted directly from your account through the qualified custodian holding your funds and securities. We will deduct our advisory fee only when you have given our firm written authorization permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account, and you should review all statements for accuracy. If you have any questions about the statement(s) you receive from the qualified custodian, please call our main office number located on the cover page of this Brochure. Our agreement for services will continue in effect until terminated by either party upon 30-days' written notice to the other party. You will incur a pro rata charge for services rendered prior to the termination of the agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client. If you have pre-paid advisory fees that we have not yet earned, you 5  will receive a prorated refund of those fees. As a client, you should be aware that the wrap fee charged by our firm may be higher (or lower) than those charged by others in the industry, and that it may be possible to obtain the same or similar services from other firms at lower (or higher) rates. A client may be able to obtain some or all of the types of services available through our firm's wrap fee program on an individual basis through other firms and, depending on the circumstances, the aggregate of any separately paid fees may be lower or higher than the annual fees shown above. Payment of Fees Our fees for portfolio management services will be deducted directly from your account through the qualified custodian holding your funds and securities. We will deduct our advisory fee only when you have given our firm written authorization permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account, and you should review all statements for accuracy. If you have any questions about the statement(s) you receive from the qualified custodian, please call our main office number located on the cover page of this Brochure. FAP may calculate an additional Program fee or refund a portion of the quarterly fee paid in advance if any one deposit or withdrawal (without adjustment for any changes in the value of Account assets during the quarter) causes the value of the assets in the Account to increase or decrease by $25,000 or more. In each case, the additional fee or refund will be equal to the applicable quarterly fee rate times the amount of the deposit or withdrawal pro rated based on the number of days from the date of the triggering deposit or withdrawal to the last day of the quarter. ‐ Termination of Advisory Relationship Our agreement for services will continue in effect until terminated by either party upon 30-days' written notice to the other party. You will incur a pro rata charge for services rendered prior to the termination of the agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client. If you have pre-paid advisory fees that we have not yet earned, you will receive a prorated refund of those fees. Wrap Fee Program Disclosures • The benefits under a wrap fee program depend, in part, upon the size of the Account, the management fee charged, and the number of transactions likely to be generated in the Account. For example, a wrap fee program may not be suitable for Accounts with little trading activity. In order to evaluate whether a wrap fee program is suitable for you, you should compare the Program Fee and any other costs of the Program with the amounts that would be charged by other advisers, broker-dealers, and custodians, for advisory fees, brokerage and other execution costs, and custodial services comparable to those provided under the Program. • In considering the investment programs described in this Brochure, you should be aware that participating in a wrap fee program may cost more or less than the cost of purchasing advisory, brokerage, and custodial services separately from other advisers or broker-dealers. • Our firm and Associated Persons receive compensation as a result of your participation in the Program. This compensation may be more than the amount our firm or the Associated Persons would receive if you paid separately for investment advice, brokerage, and other services. Accordingly, a conflict of interest exists because our firm and our Associated Persons have a financial incentive to recommend the Program. • Similar advisory services may be available from other registered investment advisers for lower fees. 6  Additional Fees And Expenses The Program Fee covers the investment advisory services rendered by FAP and the Investment Manager. The Program Fee, subject to the exceptions listed below, also covers charges applicable to securities transactions effected for the Account by the Investment Manager through NBC Securities, Inc. (“NBCS”) and RBC Wealth Management. The Program Fee does not cover, and Client will be additionally responsible and charged for: • Interest on debit account balances, where applicable; • Investment Access Account fees, where applicable; • IRA custodial fees, qualified retirement plan account fees and other account maintenance fees; • Usual and customary transaction charges on the liquidation of assets not eligible for the ProAm Program; • Management and other fees on the ETF securities purchased in the account; • Margin interest, if applicable; and • Check reordering cost and fees, where applicable. The Program Fee does not include mark-ups and mark-downs, dealer spreads or other costs associated with the purchase or sale of securities, interest, taxes, or other costs, such as national securities exchange fees, charges for transactions not executed through the Qualified Custodian. The wrap program fees that you pay to our firm for portfolio management services are separate and distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in each fund's prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses. To fully understand the total cost you will incur, you should review all the fees charged by mutual funds, exchange traded funds, our firm, and others. If you have any questions about fees that your account might be responsible for, please contact us. Brokerage Practices For clients engaging our firm for portfolio management services, clients must open one or more custodial accounts in their own name at an independent custodian. We consider several factors in recommending a broker-dealer/custodian to a client. Factors that we consider when recommending a broker- dealer/custodian may include ease of use, reputation, service execution, pricing and financial strength. We may also take into consideration the availability of the research and/or services received or offered by the broker-dealer/custodian. While you are free to choose any broker-dealer/custodian or other service provider, we require that you establish an account with a brokerage / custodial firm with whom we have an existing relationship. Not all advisers require their clients to direct brokerage. For clients in need of brokerage and custodial services, we generally recommend the use of NBC Securities, Inc. and RBC Wealth Management, respectively. As a registered investment adviser, we have access to the institutional platform of your account custodian. As such, we will also have access to research products and services from your account custodian and/or other brokerage firm. These products may include financial publications, information about particular companies and industries, research software, and other products or services that provide lawful and appropriate assistance to our firm in the performance of our investment decision- making responsibilities. Such research products and services are provided to all investment advisers that utilize the institutional services platforms of these firms, and are not considered to be paid for with soft dollars. However, you should be aware that the commissions charged by a particular broker for a particular transaction or set of transactions may be greater than the amounts another broker who did not provide research services or products might charge. 7  Research and Other Soft Dollar Benefits We do not have any soft dollar arrangements. Brokerage for Client Referrals We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. Trade Errors In the event a trading error occurs in your account, our policy is to restore your account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Aggregated Trades We may combine multiple orders for shares of the same securities purchased for discretionary advisory accounts we manage (this practice is commonly referred to as "aggregated trading"). We will then distribute a portion of the shares to participating accounts in a fair and equitable manner. Generally, participating accounts will pay a fixed transaction cost regardless of the number of shares transacted. In certain cases, each participating account pays an average price per share for all transactions and pays a proportionate share of all transaction costs on any given day. In the event an order is only partially filled, the shares will be allocated to participating accounts in a fair and equitable manner, typically in proportion to the size of each client’s order. Accounts owned by our firm or persons associated with our firm may participate in aggregated trading with your accounts; however, they will not be given preferential treatment. We do not aggregate trades for non-discretionary accounts. Accordingly, non-discretionary accounts may pay different costs than discretionary accounts pay. If you enter into non-discretionary arrangements with our firm, we may not be able to buy and sell the same quantities of securities for you and you may pay higher commissions, fees, and/or transaction costs than clients who enter into discretionary arrangements with our firm. Assets Under Management As of December 31, 2024, we provide continuous management services for $325,063,700 in client assets on a discretionary basis. Item 5 Account Requirements and Types of Clients We typically offer investment advisory services to individuals, high net worth individuals, charitable organizations, corporations or other businesses. In general, we require a minimum of $100,000 to open and maintain an advisory account. At our discretion, we may waive this minimum account size. For example, we may waive the minimum if you appear to have significant potential for increasing your assets under our management. We may also combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts to meet the stated minimum. For clients where alternative investments are included in their allocation, we require a minimum account size of $50,000 for each strategy selected. 8  Item 6 Portfolio Manager Selection and Evaluation We are the sponsor and portfolio manager for the Program. We also use unaffiliated third-party manager(s) to manage your investment portfolio. Typically, we use NBC Asset Management. We conduct extensive due diligence on any third-party manager that we use to help manage your account(s) to help ensure that the investment strategies remained allied with your designated investment objectives. We review each third-party manager (Manager) before selecting them to be included in our program to manage client assets. We also conduct an annual review to ensure that the manager is still suitable for our programs. Each Manager is evaluated on the basis of information provided by the Manager including descriptions of its investment process, asset allocation strategies employed, sample portfolios to review securities selections, and the Manager’s Form ADV Disclosure Brochure, among other items. We attempt to verify the information provided by comparing it to other data from publicly available data collection sources. We do not require that Managers adhere to GIPS/CFA Institute standards. Managers may provide information that does not entirely conform to these requirements. Each Manager we recommend is screened and selected using a number of criteria, including but not limited to: • Manager or management team tenure and experience; • Performance within peer group; • Portfolio turnover; • Expenses and costs of Manager; • Meetings and availability with manager of Manager; and • Participation in educational forums and conference calls offered by the Manager. Factors influencing a Manager change might include the following: • Performance; • Change of ownership; • Strategic or tactical change away from a particular sector or asset class; and • Costs. Please refer to Services, Fees, and Compensation for additional disclosures on costs associated with your participation in the Program. Performance-Based Fees and Side-by-Side Management We do not accept performance-based fees or participate in side-by-side management. Performance- based fees are fees that are based on a share of capital gains or capital appreciation of a client's account. Side-by-side management refers to the practice of managing accounts that are charged performance- based fees while at the same time managing accounts that are not charged performance-based fees. Our fees are calculated as described above, and are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in your advisory account. Our Methods of Analysis and Investment Strategies We may use one or more of the following methods of analysis or investment strategies when providing investment advice to you: 9  Charting Analysis - involves the gathering and processing of price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data is used to detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known 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. Technical Analysis - involves studying past price patterns, trends and interrelationships in the financial markets to assess risk-adjusted performance and predict the direction of both the overall market and specific securities. Risk: The risk of market timing based on technical analysis is that our analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known 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. 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 and its industry. The resulting data is used to measure the true value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that 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. Cyclical Analysis - a type of technical analysis that involves evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and may have many fluctuations between long-term expansions and contractions. Risk: 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. Modern Portfolio Theory - a theory of investment which attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk that is common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long- term which may not be the case. There is also the risk that the segment of the market that you are invested in or perhaps just your particular investment will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" 10  assets that may be better utilized in the short-term in other investments. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short-term which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. There are many factors that can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a smaller impact over longer periods of times. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the expiration date of the option. When an investor sells a call option, he or she must deliver to the buyer a specified number of shares if the buyer exercises the option. When an investor sells a put option, he or she must pay the strike price per share if the buyer exercises the option, and will receive the specified number of shares. The option writer/seller receives a premium (the market price of the option at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Trading - We may use frequent trading (in general, selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and tolerance for risk. This may include buying and selling securities frequently in an effort to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, particularly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending upon each client's specific financial situation. As such, we determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs and other various suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is important that you notify us immediately with respect to any material changes to your financial circumstances, including for example, a change in your current or expected income level, tax circumstances, or employment status. Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless we specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the management of your assets. Regardless of your account size or any other factors, we strongly recommend that you consult with a tax professional regarding the investing of your assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Your custodian will default to the First-In First-Out ("FIFO") accounting method for calculating the cost basis of your investments. You are responsible for contacting your tax advisor to determine if this accounting method is the right choice for you. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately and we will alert your account custodian of 11  your individually selected accounting method. Decisions about cost basis accounting methods will need to be made before trades settle, as the cost basis method cannot be changed after settlement. Risk of Loss Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past performance is in no way an indication of future performance. Other Risk Considerations When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of any potential loses. The following risks may not be all-inclusive, but should be considered carefully by a prospective client before retaining our services. Liquidity Risk: The risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price or it may not be possible to sell the investment at all. Credit Risk: Credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond issuing entity can experience a credit event that could impair or erase the value of an issuer’s securities held by a client. Inflation and Interest Rate Risk: Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client’s future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many types of fixed income investments to decline. Horizon and Longevity Risk: The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments that you were expecting to hold for the long term. If you must sell at a time that the markets are down, you may lose money. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for people who are retired, or are nearing retirement. Recommendation of Particular Types of Securities We offer advice on equity securities, exchange traded funds, Mutual Fund Shares and Real Estate Investment Trust ("REIT"). We may also recommend other types of securities since each client may have different needs and/or risk tolerances. Each type of security has its own unique set of risks associated with it and it would not be possible to list here all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with it. Equity Securities (Stocks): There are numerous ways of measuring the risk of equity securities (also known simply as "equities" or "stock"). In very broad terms, the value of a stock depends on the financial health of the company issuing it. However, stock prices can be affected by many other factors including, but not limited to the class of stock (for example, preferred or common); the health of the market sector of the issuing company; and the overall health of the economy. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap") are but the mere size of an issuer is not, by itself, an indicator of the safety of the investment. 12  Mutual Funds and Exchange Traded Funds (ETFs): Mutual funds and exchange traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no load" and charge no fee to buy into, or sell out of, the fund, other types of mutual funds do charge such fees which can also reduce returns. Mutual funds can also be "closed end" or "open end". So-called "open end" mutual funds continue to allow in new investors indefinitely whereas "closed end" funds have a fixed number of shares to sell which can limit their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF’s performance to match that of its Underlying Index or other benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks on a daily basis, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index, but which are expected to yield similar performance. Real Estate Investment Trust ("REIT"): A real estate investment trust ("REIT") is a corporate entity which invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong or the REIT must either dip into reserves, borrow to pay dividends, or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding, and getting, harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, which will lead to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. Conflicting advice may be given to different clients regarding the same security or investment as our investment strategies and advice may vary depending upon each client's specific financial situation. Proxy Voting We will not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice regarding corporate actions and the exercise of your proxy voting rights. If you own shares of applicable securities, you are responsible for exercising your right to vote as a shareholder. 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 any electronic solicitations to vote proxies. 13  Item 7 Client Information Provided to Portfolio Managers In order to provide the Program services, we will share your private information with your account custodian and selected third-party manager, as needed. We will only share the information necessary in order to carry out our obligations to you in servicing your account. We share your personal account data in accordance with our privacy policy as described below. Privacy Notice requirements, we have instituted policies and procedures to ensure that we keep your personal information private and secure. We do not disclose any non-public personal information about you to any non-affiliated third parties, except as permitted by law. In the course of servicing your account, we may share some information with our service providers, such as transfer agents, custodians, broker-dealers, accountants, consultants, and attorneys. We restrict internal access to non-public personal information about you to employees, who need that information in order to provide products or services to you. We maintain physical and procedural safeguards that comply with regulatory standards to guard your non-public personal information and to ensure our integrity and confidentiality. We will not sell information about you or your accounts to anyone. We do not share your information unless it is required to process a transaction, at your request, or required by law. You will receive a copy of our privacy notice prior to or at the time you sign an advisory agreement with our firm. Thereafter, we will deliver a copy of the current privacy policy notice to you on an annual basis. Contact our main office at the telephone number on the cover page of this Disclosure Brochure if you have any questions regarding this policy. If you decide to close your account(s) we will adhere to our privacy policies, which may be amended from time to time. If we make any substantive changes in our privacy policy that would further permit or require disclosures of your private information, we will provide written notice to you. Where the change is based on permitted disclosures, you will be given an opportunity to direct us as to whether such disclosure is acceptable. Where the change is based on required disclosures, you will only receive written notice of the change. You may not opt out of the required disclosures. If you have questions about our privacy policies, please contact our main office at the telephone number on the cover page of this Disclosure Brochure and ask to speak to the Chief Compliance Officer. Item 8 Client Contact with Portfolio Managers Without restriction, you should contact our firm or your advisory representative directly with any questions regarding your Program account(s). You should contact your advisory representative with respect to changes in your investment objectives, risk tolerance, or requested restrictions placed on the management of your Program assets. Item 9 Additional Information Affiliation and Other Business Activities Financial Advisory Partners, LLC (“FAP”) is affiliated under common control and ownership with NBC 14  Securities, Inc. (“NBC”), a securities broker-dealer and investment adviser registered with the Securities and Exchange Commission. FAP and NBC are each owned by NBC Holdings, LLC. Some financial professionals of FAP are dually associated with NBC as Registered Representatives and/or Investment Adviser Representatives. In these outside capacities, these individuals will receive advisory fees, brokerage commission-based compensation, including 12b-1 fees for the sale of investment company products., or both, depending on the services provided through their respective outside capacities. Advisory fees charged by FAP are separate and distinct from any advisory or brokerage-related fees these individuals may receive through NBC. Fees earned through FAP relate solely to advisory services offered under FAP’s investment advisory programs. Clients who engage NBC for separate services will receive NBC’s Form ADV 2A and/or applicable disclosure documents and will enter into a separate client agreement describing the services provided and the associated fees, among other important disclosures. As noted above, our firm’s financial professionals are registered representatives and will receive commission-based compensation. These financial professionals may also be licensed insurance agents. Compensation earned in these separate capacities is separate and in addition to our advisory fees. The sale of insurance instruments and other commissionable products offered by these persons are intended to complement our advisory services. However, these practices present a conflict of interest because these individuals have a financial incentive to effect securities transactions on your behalf and/or sell insurance products to you. We only assist you in these outside capacities where we in good faith believe that it is appropriate for the client’s particular needs and circumstances. Clients who choose to purchase insurance services may use the insurance brokerage firm and agent of their choice and are under no obligation to use a financial professional associated with our firm. Where fixed annuities are sold, clients should also note that the annuity sales result in substantial up- front commissions and ongoing trails based on the annuity’s total value. In addition, many annuities contain surrender charges and/or restrictions on access to your funds. Payments and withdrawals can have tax consequences. Optional lifetime income benefit riders are used to calculate lifetime payments only and are not available for cash surrender or in a death benefit unless specified in the annuity contract. In some annuity products, fees can apply when using an income rider. Annuity guarantees are based on the financial strength and claims-paying ability of the issuing insurance company. We urge our clients to read all insurance contract disclosures carefully before making a purchase decision. Rates and returns mentioned on any program presented are subject to change without notice. Insurance products are subject to fees and additional expenses. Northstar Bank, a state-chartered Michigan bank, has a minority ownership interest in our firm, but does not have control of our firm's day-to-day operations or advisory practice. From time to time and if appropriate, we may refer advisory clients to Northstar Bank, or a bank affiliated with Northstar Bank, for banking and/or lending services. There is no referral and/or compensation arrangements. Northstar Bank (and/or its affiliates) may indirectly benefit from the referral. Clients may choose any banking institution to work with and are under no obligation to use Northstar Bank nor any of its affiliates. Any material conflicts of interest between you and our firm, or our employees are disclosed in this Brochure. If at any time, additional material conflicts of interest develop, we will provide you with written notification of the material conflicts of interest or an updated Brochure. 15  Disciplinary Information We are required to disclose the facts of any legal or disciplinary events that are material to a client's evaluation of our advisory business or the integrity of our management. While not applicable to the material items delineated in the Form ADV instructions, Alexander van den Berg, an owner and investment adviser representative of our firm, was involved in a FINRA arbitration dispute in 2007 alleging excessive trading in a client's brokerage account. The arbitration claim was settled in 2008 with $15,000 paid by Alexander van den Berg's employer. No monetary compensation was paid directly by Alexander van den Berg. In 2019, the former client that filed the arbitration claim, Alexander van den Berg's former stepmother, signed a notarized attestation whereby she stated that the claim was unfounded and that Alexander van den Berg's conduct was professional and ethical at all times during their professional relationship. This FINRA arbitration was resolved and Alexander van den Berg has no outstanding issues. The details on this matter can be found by visiting the following link to the IAPD: www.adviserinfo.sec.gov. Description of Our Code of Ethics We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code of Ethics includes guidelines for professional standards of conduct for persons associated with our firm. Our goal is to protect your interests at all times and to demonstrate our commitment to our fiduciary duties of honesty, good faith, and fair dealing with you. All persons associated with our firm are expected to adhere strictly to these guidelines. Persons associated with our firm are also required to report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about you or your account holdings by persons associated with our firm. Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the telephone number on the cover page of this Brochure. Participation or Interest in Client Transactions Neither our firm nor any persons associated with our firm has any material financial interest in client transactions beyond the provision of investment advisory services as disclosed in this Brochure. Personal Trading Practices Our firm or persons associated with our firm may buy or sell the same securities that we recommend to you or securities in which you are already invested. A conflict of interest exists in such cases because we have the ability to trade ahead of you and potentially receive more favorable prices than you will receive. To mitigate this conflict of interest, it is our policy that neither our firm nor persons associated with our firm shall have priority over your account in the purchase or sale of securities. Aggregated Trading Our firm or persons associated with our firm may buy or sell securities for you at the same time we or persons associated with our firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we have the ability to trade ahead of you and potentially receive more favorable prices than you will receive. In efforts to mitigate this conflict of interest, it is our policy that neither our firm nor persons associated with our firm shall have priority over your account in the purchase or sale of securities. 16  Review of Accounts The investment adviser representative assigned to your account will monitor your accounts on an ongoing basis and will conduct internal account reviews on a periodic basis (at least annually) and upon your request to ensure that the advisory services provided to you are consistent with your stated investment needs and objectives. Additional reviews may be conducted based on various circumstances, including, but not limited to: contributions and withdrawals; year-end tax planning; market moving events; security specific events; and/or, changes in your risk/return objectives. We may provide you with additional or regular written reports in conjunction with account reviews. Reports we provide to you may contain relevant account and/or market-related information such as an inventory of account holdings and account performance, etc. You will receive trade confirmations and monthly or quarterly statements from your account custodian(s). Client Referrals and Other Compensation As disclosed under the Fees and Compensation section in this Brochure, investment adviser representatives of our firm may also be registered representatives with NBC Securities, Inc and/or licensed insurance agents. For information on these outside capacities and the associated conflicts of interest, please refer to Item 5 (Fees and Compensation section) of this Brochure for more information. We directly compensate non-employee (outside) consultants, individuals, and/or entities (solicitors) for client referrals. In order to receive a cash referral fee from us, solicitors must comply with the requirements of the jurisdictions in which they operate. If you were referred to us by a solicitor, you should have received a copy of this brochure along with the solicitor's disclosure statement at the time of the referral. If you become a client, the solicitor that referred you to us will receive a percentage of the advisory fee you pay us for as long as you are our client, or until such time as our agreement with the solicitor expires. You will not pay additional fees because of this referral arrangement. Referral fees paid to a solicitor are contingent upon your entering into an advisory agreement with us. Therefore, a solicitor has a financial incentive to recommend us to you for advisory services. This creates a conflict of interest; however, you are not obligated to retain us for advisory services. Comparable services and/or lower fees may be available through other firms. Class Action Lawsuits We do not determine if securities held by you are the subject of a class action lawsuit or whether you are eligible to participate in class action settlements or litigation nor do we initiate or participate in litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or negligence by issuers of securities held by you. Financial Information Our firm does not have any financial condition or impairment that would prevent us from meeting our contractual commitments to you, and we have never filed for bankruptcy. We do not take physical custody of client funds or securities, or serve as trustee or signatory for client accounts, and we do not require the prepayment of more than $1,200 in fees six or more months in advance of services rendered. Therefore, we are not required to include a financial statement with this Brochure. IRA Rollover Considerations In conjunction with the advisory services offered, we may provide recommendations related to the rollover of funds from an employer sponsored retirement plan. A plan participant leaving employment has several options with respect to their employer sponsored retirement plans. Each choice offers advantages and disadvantages, depending on desired investment options and services, fees and expenses, withdrawal options, required minimum distributions, tax treatment, and the investor's unique financial needs and different retirement plans. The complexity of these choices may lead an investor to seek assistance from us. 17  When our firm or our Associated Person(s) recommends an investor roll over plan assets into an Individual Retirement Account (“IRA”), we and our Associated Person(s) may earn an asset-based fee as a result. In most cases, we do not receive an asset-based fee if assets are retained in the plan. Often, account fees and expenses will increase because fees will apply to assets rolled over to an IRA and ongoing services will be extended to these assets. Thus, while there is arguably an economic incentive to encourage an investor to roll over plan assets into an IRA, we cannot and do not place our interests ahead of yours. A rollover may also result in the assessment of other levels of fees and expenses, including, but not limited to, investment-related expenses imposed by other service providers and mutual fund managers not affiliated with us, as well as other fees and expenses charged by the custodian, third-party administrator, and/or record-keeper. We make no representations or warranties relating to any costs or expenses associated with the services provided by any third parties, and you understand that these fees are in addition to the fee paid to us for the rollover advice. In cases where we provide you with rollover advice as defined by the Department of Labor, which may also include setting up and/or completing the rollover transaction, we do not serve as a custodian, and we do not provide legal or tax advice to you. In addition, we do not have any responsibilities or potential liabilities in connection with assets not related to the rollover and investments that are not managed by us. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests. In accordance with various rules and regulations, we must act in your best interest and we must not put our interests ahead of your interests. Additionally, we must: meet a professional standard of care when making investment recommendations (give prudent advice); never put our financial interests ahead of yours when making recommendations (give loyal advice); avoid misleading statements about conflicts of interest, fees, and investments; follow polices, and procedures designed to ensure that we give advice that is in your best interest; charge no more than is reasonable for our services; and give you basic information about any conflicts of interest. We rely on all information you provide to us, whether financial or otherwise, without independent verification. We request that you promptly notify us in writing of any material change in the financial and other information provided to us, and to promptly provide any such additional information as may be reasonably requested by us. Due to the volatile and unpredictable nature of financial markets, we do not guarantee any future performance, any specific level of performance, or the success of any recommendations or strategies that we may take or recommend for you, or the success of our overall recommendations. Investment recommendations are subject to various market, currency, economic, political, and business risks, and that investment decisions will not always be profitable. It is important that you understand the differences between these types of accounts and decide whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment adviser representative, or call our main number as listed on the cover page of this Brochure. 18 

Financial Advisory Partners, LLC 1201 S. Orlando Avenue; Suite 350 Winter Park, FL 32789 Telephone: 407-478-6314 Fax: 407-478-6314 January 21, 2026 PART 2A BROCHURE This Brochure provides information about the qualifications and business practices of Financial Advisory Partners, LLC. If you have any questions about the contents of this Brochure, please contact us at 407-461-7240. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Financial Advisory Partners, LLC is available on the SEC's website at www.adviserinfo.sec.gov. Financial Advisory Partners, LLC is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. 1  Item 2 Summary of 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 last annual updating amendment, dated March 18, 2025, we have the following material changes to our Form ADV Part 2. We have updated this Brochure to disclose an update to our firm’s ownership structure resulting from planned business continuity and succession plans. There have been no changes to our firm’s day-to-today business operations. Please refer to Item 4 of this Brochure for more information. Please contact us if you have any questions about these changes. 2  Item 3 Table of Contents Item 2 Summary of Material Changes .................................................................................................. 2 Item 3 Table of Contents ...................................................................................................................... 3 Item 4 Advisory Business ..................................................................................................................... 4 Item 5 Fees and Compensation ........................................................................................................... 5 Item 6 Performance-Based Fees and Side-By-Side Management ...................................................... 6 Item 7 Types of Clients ......................................................................................................................... 6 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................................. 7 Item 9 Disciplinary Information ............................................................................................................. 7 Item 10 Other Financial Industry Activities and Affiliations .................................................................. 7 Item 11 Code of Ethics, Participation/Interest in Client Transactions & Personal Trading .................. 8 Item 12 Brokerage Practices ................................................................................................................ 9 Item 13 Review of Accounts ................................................................................................................. 9 Item 14 Client Referrals and Other Compensation .............................................................................. 9 Item 15 Custody ................................................................................................................................. 10 Item 16 Investment Discretion ............................................................................................................ 10 Item 17 Voting Client Securities ......................................................................................................... 10 Item 18 Financial Information ............................................................................................................. 10 Item 19 Requirements for State-Registered Advisers ........................................................................ 11 Item 20 Additional Information ............................................................................................................ 11 3  Item 4 Advisory Business Description of Firm Financial Advisory Partners, LLC is a registered investment adviser based in Winter Park, FL. We are organized as a limited liability company ("LLC") under the laws of the State of Florida. Our firm has been a legal entity since 2008, and our firm has been providing investment advisory services since November 2020. We are primarily owned by Alexander van den Berg and David Sutphin, each with over 35 years in the financial industry. Our firm also has minority owners. NBC Holdings, LLC, Northstar Bank, and Pierre Allard each hold minority ownership interests in our firm. Please refer to Item 10 of this Brochure for more information on our firm’s affiliates. The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this Brochure, the words "we," "our," and "us" refer to Financial Advisory Partners, LLC and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. Portfolio Management Services Financial Advisory Partners provides portfolio management services that consist of ongoing financial advice and discretionary and/or non-discretionary management services where investment advice is tailored to meet your individual circumstances and investment objectives. These services are offered as part of the Financial Advisory Partners Wrap Fee Program. A wrap fee program combines portfolio management, advisory services, and trade execution for a single fee. Financial Advisory Partner is responsible for the research, security selection, and implementation of transaction orders in the Client's account. The transactions in the Client's account will be executed by and custodied through NBC Securities, Inc. (“NBCS”) and RBC Wealth Management, respectively. The Client pays Financial Advisory Partners an all-inclusive Wrap fee. Financial Advisory Partners pays a portion of this fee for trade execution expenses and does not pass this expense back to the client. Detailed information about the Financial Advisory Partners Wrap Fee Program and program fees is provided in the Form ADV Part 2A, Appendix 1 (Wrap Brochure) that is attached to this Form ADV Part 2A Disclosure Brochure. Financial Planning and Consulting Services We provide financial planning and consulting as a stand-alone service where we offer modular, consultative, and/or broad-based services. These services generally involve a variety of advisory services regarding the management of the client's financial resources based upon an analysis of their individual needs. If you retain our firm for these services, we will meet with you to gather information about your financial circumstances and objectives. As required, we will conduct follow-up interviews for the purpose of reviewing and/or collecting additional financial data. Once such information has been reviewed and analyzed, we will provide you with our recommendations designed to help you achieve your stated financial goals and objectives. In addition to modular (project-based) and broad-based services, we also offer ongoing services covering complex financial planning and consulting support that typically includes, but not limited to: ongoing consulting and financial planning; periodic reviews (as-needed or by client request); and updates to your financial plan. financial situation at the time we provide our Our recommendations are based on your recommendations, and on the financial information you provide to our firm. You will always have the right to accept or reject our recommendations. All terms of the engagement, including specific services 4  to be performed, will be evidenced in a written agreement between you and our firm. Types of Investments We offer advice on Equity Securities Exchange Traded Funds ("ETFs"), Mutual Fund Shares and Real Estate Investment Trust ("REIT"). Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. Since our investment strategies and advice are based on each client’s specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment. Assets Under Management As of December 31, 2024, we provide continuous management services for $325,063,700 in client assets on a discretionary basis. Item 5 Fees and Compensation Portfolio Management Services Detailed information about the Financial Advisory Partners Wrap Fee Program and program fees is provided in the Form ADV Part 2A, Appendix 1 (Wrap Brochure) that is attached to this Form ADV Part 2A Disclosure Brochure. Please refer to that portion of this Brochure for further information. Financial Planning and Consulting Services We offer these services on either an hourly basis or fixed fee basis. Our hourly fee is $350 and our fixed fees range up to $10,000. Typically, our hourly fee is billed for general consulting services and our fixed fees are billed for modular (project-based) and/or broad-based financial planning. fee in advance with Our financial planning fees - both hourly and fixed fees - are negotiable depending upon the complexity and scope of the services, your financial situation, and your objectives. Our hourly and fixed fees are generally due upon completion of services rendered. For our fixed fees, however, we may require that you pay 50% of the the remaining portion due upon completion of services rendered. In our discretion, we may negotiate other fee-paying arrangements. All important terms will be evidenced in the agreement that you sign with our firm. We also offer annual, ongoing financial planning and consulting services for a fixed monthly fee ranging up to $10,000. Our fee for ongoing services is customized for each engagement and varies widely based on the complexity of each client's financial circumstances. In limited circumstances, we may negotiate fees above our maximum fees disclosed above where the client requires complex planning and consulting services. Either party may terminate the agreement by providing written notice to the other party. You will incur a pro rata charge for services rendered prior to the termination of the agreement. If you have pre-paid advisory fees that we have not yet earned, you will receive a prorated refund of those fees. Additional Fees and Expenses As part of our investment advisory services to you, we may invest, or recommend that you invest, in mutual funds and exchange traded funds. The fees that you pay to our firm for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in each fund's prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses. You may also incur transaction charges and/or 5  brokerage fees when purchasing or selling securities. These charges and fees are typically imposed by the broker-dealer or custodian through whom your account transactions are executed. We do not share in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or custodian. To fully understand the total cost you will incur, you should review all the fees charged by mutual funds, exchange traded funds, our firm, and others. For information on our brokerage practices, refer to the Brokerage Practices section of this Brochure. Compensation for the Sale of Securities or Other Investment Products Investment Adviser Representatives ("IARs") of our firm may also be registered representatives with NBC Securities, Inc. ("NBC"), a securities broker-dealer, and a member of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation. In this capacity as registered representatives, these IARs will receive commission-based compensation in connection with the purchase and sale of securities, including 12b-1 fees for the sale of investment company products. IARs of our firm may also be licensed as independent insurance agents, and they will earn commission-based compensation for selling insurance products. Compensation earned by these IARs in their separate capacities as registered representatives and/or licensed insurance agents is separate and in addition to our advisory fees. These practices present a conflict of interest because IARs of our firm who are registered representatives and/or licensed insurance agents have a financial incentive to effect securities transactions on your behalf and/or sell insurance products to you. We address this conflict of interest by recommending securities and/or insurance products only where we, in good faith, believe that it is appropriate for the client’s particular needs and circumstances. Clients are under no obligation, contractually or otherwise, to purchase securities and/or insurance products through any person affiliated with our firm. As a fiduciary, it is our firm's obligation to act in our client's best interest. Where fixed annuities are sold, clients should also note that the annuity sales result in substantial up- front commissions and ongoing trails based on the annuity’s total value. In addition, many annuities contain surrender charges and/or restrictions on access to your funds. Payments and withdrawals can have tax consequences. Optional lifetime income benefit riders are used to calculate lifetime payments only and are not available for cash surrender or in a death benefit unless specified in the annuity contract. In some annuity products, fees can apply when using an income rider. Annuity guarantees are based on the financial strength and claims-paying ability of the issuing insurance company. We urge our clients to read all insurance contract disclosures carefully before making a purchase decision. Rates and returns mentioned on any program presented are subject to change without notice. Insurance products are subject to fees and additional expenses. Item 6 Performance-Based Fees and Side-By-Side Management We do not accept performance-based fees or participate in side-by-side management. Performance- based fees are fees that are based on a share of a capital gains or capital appreciation of a client's account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance- based fees. Our fees are calculated as described in the Fees and Compensation section above, and are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in your advisory account. Item 7 Types of Clients We typically offer investment advisory services to individuals, high net worth individuals, charitable organizations, corporations or other businesses. 6  In general, we require a minimum of $100,000 to open and maintain an advisory account. At our discretion, we may waive this minimum account size. For example, we may waive the minimum if you appear to have significant potential for increasing your assets under our management. We may also combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts to meet the stated minimum. investments are included in their allocation, we require a For clients where alternative minimum account size of $50,000 for each strategy selected. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Please refer to Item 6 of our Form ADV Part 2A, Appendix 1 (Wrap Brochure) that is attached to this Form ADV Part 2A Disclosure Brochure for information on our methods of analysis, investment strategies, and related risk of loss disclosures. Item 9 Disciplinary Information We are required to disclose the facts of any legal or disciplinary events that are material to a client's evaluation of our advisory business or the integrity of our management. While not applicable to the material items delineated in the Form ADV instructions, Alexander van den Berg, an owner and investment adviser representative of our firm, was involved in a FINRA arbitration dispute in 2007 alleging excessive trading in a client's brokerage account. The arbitration claim was settled in 2008 with $15,000 paid by Alexander van den Berg's employer. No monetary compensation was paid directly by Alexander van den Berg. In 2019, the former client that filed the arbitration claim, Alexander van den Berg's former stepmother, signed a notarized attestation whereby she stated that the claim was unfounded and that Alexander van den Berg's conduct was professional and ethical at all times during their professional relationship. This FINRA arbitration was resolved and Alexander van den Berg has no outstanding issues. The details on this matter can be found by visiting the following link to the IAPD: www.adviserinfo.sec.gov. Item 10 Other Financial Industry Activities and Affiliations Any material conflicts of interest between you and our firm, or our employees are disclosed in this Brochure. If at any time, additional material conflicts of interest develop, we will provide you with written notification of the material conflicts of interest or an updated Brochure. Affiliation and Other Business Activities Financial Advisory Partners, LLC (“FAP”) is affiliated under common control and ownership with NBC Securities, Inc. (“NBC”), a securities broker-dealer and investment adviser registered with the Securities and Exchange Commission. FAP and NBC are each owned by NBC Holdings, LLC. Some financial professionals of FAP are dually associated with NBC as Registered Representatives and/or Investment Adviser Representatives. In these outside capacities, these individuals will receive advisory fees, brokerage commission-based compensation, including 12b-1 fees for the sale of investment company products., or both, depending on the services provided through their respective outside capacities. Advisory fees charged by FAP are separate and distinct from any advisory or brokerage-related fees these individuals may receive through NBC. Fees earned through FAP relate solely to advisory 7  services offered under FAP’s investment advisory programs. Clients who engage NBC for separate services will receive NBC’s Form ADV 2A and/or applicable disclosure documents and will enter into a separate client agreement describing the services provided and the associated fees, among other important disclosures. As noted above, our firm’s financial professionals are registered representatives and will receive commission-based compensation. These financial professionals may also be licensed insurance agents. Compensation earned in these separate capacities is separate and in addition to our advisory fees. The sale of insurance instruments and other commissionable products offered by these persons are intended to complement our advisory services. However, these practices present a conflict of interest because these individuals have a financial incentive to effect securities transactions on your behalf and/or sell insurance products to you. We only assist you in these outside capacities where we in good faith believe that it is appropriate for the client’s particular needs and circumstances. Clients who choose to purchase insurance services may use the insurance brokerage firm and agent of their choice and are under no obligation to use a financial professional associated with our firm. Affiliation Northstar Bank, a state-chartered Michigan bank, has a minority ownership interest in our firm, but does not have control of our firm's day-to-day operations or advisory practice. From time to time and if appropriate, we may refer advisory clients to Northstar Bank, or a bank affiliated with Northstar Bank, for banking and/or lending services. There is no referral and/or compensation arrangements. Northstar Bank (and/or its affiliates) may indirectly benefit from the referral. Clients may choose any banking institution to work with and are under no obligation to use Northstar Bank nor any of its affiliates. Recommendation of Other Advisers We will generally select a third-party manager based on your needs and investment objectives to help manage your account. Please refer to Items 4 & 5 of this Brochure for more information. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Description of Our Code of Ethics We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code of Ethics includes guidelines for professional standards of conduct for persons associated with our firm. Our goal is to protect your interests at all times and to demonstrate our commitment to our fiduciary duties of honesty, good faith, and fair dealing with you. All persons associated with our firm are expected to adhere strictly to these guidelines. Persons associated with our firm are also required to report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about you or your account holdings by persons associated with our firm. Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the telephone number on the cover page of this Brochure. Participation or Interest in Client Transactions Neither our firm nor any persons associated with our firm has any material financial interest in client transactions beyond the provision of investment advisory services as disclosed in this Brochure. Personal Trading Practices Our firm or persons associated with our firm may buy or sell the same securities that we recommend to 8  you or securities in which you are already invested. A conflict of interest exists in such cases because we have the ability to trade ahead of you and potentially receive more favorable prices than you will receive. To mitigate this conflict of interest, it is our policy that neither our firm nor persons associated with our firm shall have priority over your account in the purchase or sale of securities. Aggregated Trading Our firm or persons associated with our firm may buy or sell securities for you at the same time we or persons associated with our firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). Please refer to Item 12 (Brokerage Practices section) in this Brochure for information on our aggregated trading practices. A conflict of interest exists in such cases because we have the ability to trade ahead of you and potentially receive more favorable prices than you will receive. In efforts to mitigate this conflict of interest, it is our policy that neither our firm nor persons associated with our firm shall have priority over your account in the purchase or sale of securities. Item 12 Brokerage Practices Please refer to Item 4 of our Form ADV Part 2A, Appendix 1 (Wrap Brochure) that is attached to this Form ADV Part 2A Disclosure Brochure for information on our firm’s brokerage practices. Item 13 Review of Accounts The investment adviser representative assigned to your account will monitor your accounts on an ongoing basis and will conduct internal account reviews on a periodic basis (at least annually) and upon your request to ensure that the advisory services provided to you are consistent with your stated investment needs and objectives. Additional reviews may be conducted based on various circumstances, including, but not limited to: contributions and withdrawals; year-end tax planning; market moving events; security specific events; and/or, changes in your risk/return objectives. We may provide you with additional or regular written reports in conjunction with account reviews. Reports we provide to you may contain relevant account and/or market-related information such as an inventory of account holdings and account performance, etc. You will receive trade confirmations and monthly or quarterly statements from your account custodian(s). Item 14 Client Referrals and Other Compensation As disclosed under the Fees and Compensation section in this Brochure, investment adviser representatives of our firm may also be registered representatives with NBC Securities, Inc and/or licensed insurance agents. For information on these outside capacities and the associated conflicts of interest, please refer to Item 5 (Fees and Compensation section) of this Brochure for more information. We directly compensate outside consultants, individuals, and/or entities (Promoters – formerly referred to as Solicitors) for client referrals. In order to receive a cash referral fee from us, solicitors must comply with the requirements of the jurisdictions in which they operate. If you were referred to us by a solicitor, you should have received a copy of this brochure along with the solicitor's disclosure statement at the time of the referral. If you become a client, the solicitor that referred you to us will receive a percentage of the advisory fee you pay us for as long as you are our client, or until such time as our agreement with the solicitor expires. You will not pay additional fees because of this referral arrangement. Referral fees paid to a solicitor are contingent upon your entering into an advisory 9  agreement with us. Therefore, a solicitor has a financial incentive to recommend us to you for advisory services. This creates a conflict of interest; however, you are not obligated to retain us for advisory services. Comparable services and/or lower fees may be available through other firms. Item 15 Custody As paying agent for our firm, your independent custodian will directly debit your account(s) for the payment of our advisory fees. This ability to deduct our advisory fees from your accounts causes our firm to exercise limited custody over your funds or securities. We do not have physical custody of any of your funds and/or securities as your funds and securities will be held with a bank, broker-dealer, or other qualified custodian. You will receive account statements from the qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will indicate the amount of our advisory fees deducted from your account(s) each billing period. You should carefully review account statements for accuracy, and contact us immediately if you have any questions. Item 16 Investment Discretion If you engage our firm for discretionary portfolio management services, we require you to grant our firm discretionary authority that will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. This discretionary authority will also provide our firm with authorization to delegate discretionary management services to other unaffiliated third-party managers selected by our firm based on your investment objectives and/or determined portfolio strategy. Discretionary authority is granted by the advisory agreement you sign with our firm. In our sole discretion, we may accept instructions from you that limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account). Such requests must be presented to our firm in writing. If you enter into non-discretionary arrangements with our firm, we will obtain your approval prior to the execution of any transactions for your account(s). You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. Item 17 Voting Client Securities We will not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice regarding corporate actions and the exercise of your proxy voting rights. If you own shares of applicable securities, you are responsible for exercising your right to vote as a shareholder. 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 any electronic solicitations to vote proxies. Item 18 Financial Information The following are disclosures required by the Form ADV Instructions: Our firm does not have any financial condition or impairment that would prevent us from meeting our contractual commitments to you. We do not take physical custody of client funds or securities, or serve as trustee or signatory for client accounts, and we do not require the prepayment of more than $1,200 10  in fees six or more months in advance. Therefore, we are not required to include a financial statement with this Brochure. We have not filed a bankruptcy petition at any time in the past ten years. Item 19 Requirements for State-Registered Advisers We are a federally registered investment adviser; therefore, we are not required to respond to this item. Item 20 Additional Information Your Privacy We view protecting your private information as a top priority. Pursuant to applicable privacy requirements, we have instituted policies and procedures to ensure that we keep your personal information private and secure. We do not disclose any non-public personal information about you to any non-affiliated third parties, except as permitted by law. In the course of servicing your account, we may share some information with our service providers, such as transfer agents, custodians, broker-dealers, accountants, consultants, and attorneys. We restrict internal access to non-public personal information about you to employees, who need that information in order to provide products or services to you. We maintain physical and procedural safeguards that comply with regulatory standards to guard your non-public personal information and to ensure our integrity and confidentiality. We will not sell information about you or your accounts to anyone. We do not share your information unless it is required to process a transaction, at your request, or required by law. You will receive a copy of our privacy notice prior to or at the time you sign an advisory agreement with our firm. Thereafter, we will deliver a copy of the current privacy policy notice to you on an annual basis. Contact our main office at the telephone number on the cover page of this Disclosure Brochure if you have any questions regarding this policy. If you decide to close your account(s) we will adhere to our privacy policies, which may be amended from time to time. If we make any substantive changes in our privacy policy that would further permit or require disclosures of your private information, we will provide written notice to you. Where the change is based on permitted disclosures, you will be given an opportunity to direct us as to whether such disclosure is acceptable. Where the change is based on required disclosures, you will only receive written notice of the change. You may not opt out of the required disclosures. If you have questions about our privacy policies, please contact our main office at the telephone number on the cover page of this Disclosure Brochure and ask to speak to the Chief Compliance Officer. Class Action Lawsuits We do not determine if securities held by you are the subject of a class action lawsuit. Moreover, we do not determine whether you are eligible to participate in class action settlements or litigation, nor do we initiate or participate in litigation to recover damages on your behalf. IRA Rollover Disclosures In conjunction with the advisory services offered, we may provide recommendations related to the 11  rollover of funds from an employer sponsored retirement plan. A plan participant leaving employment has several options with respect to their employer sponsored retirement plans. Each choice offers advantages and disadvantages, depending on desired investment options and services, fees and expenses, withdrawal options, required minimum distributions, tax treatment, and the investor's unique financial needs and different retirement plans. The complexity of these choices may lead an investor to seek assistance from us. When our firm or our Associated Person(s) recommends an investor roll over plan assets into an Individual Retirement Account (“IRA”), we and our Associated Person(s) may earn an asset-based fee as a result. In most cases, we do not receive an asset-based fee if assets are retained in the plan. Often, account fees and expenses will increase because fees will apply to assets rolled over to an IRA and ongoing services will be extended to these assets. Thus, while there is arguably an economic incentive to encourage an investor to roll over plan assets into an IRA, we cannot and do not place our interests ahead of yours. A rollover may also result in the assessment of other levels of fees and expenses, including, but not limited to, investment-related expenses imposed by other service providers and mutual fund managers not affiliated with us, as well as other fees and expenses charged by the custodian, third-party administrator, and/or record-keeper. We make no representations or warranties relating to any costs or expenses associated with the services provided by any third parties, and you understand that these fees are in addition to the fee paid to us for the rollover advice. In cases where we provide you with rollover advice as defined by the Department of Labor, which may also include setting up and/or completing the rollover transaction, we do not serve as a custodian, and we do not provide legal or tax advice to you. In addition, we do not have any responsibilities or potential liabilities in connection with assets not related to the rollover and investments that are not managed by us. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests. In accordance with various rules and regulations, we must act in your best interest and we must not put our interests ahead of your interests. Additionally, we must: meet a professional standard of care when making investment recommendations (give prudent advice); never put our financial interests ahead of yours when making recommendations (give loyal advice); avoid misleading statements about conflicts of interest, fees, and investments; follow polices, and procedures designed to ensure that we give advice that is in your best interest; charge no more than is reasonable for our services; and give you basic information about any conflicts of interest. We rely on all information you provide to us, whether financial or otherwise, without independent verification. We request that you promptly notify us in writing of any material change in the financial and other information provided to us, and to promptly provide any such additional information as may be reasonably requested by us. Due to the volatile and unpredictable nature of financial markets, we do not guarantee any future performance, any specific level of performance, or the success of any recommendations or strategies that we may take or recommend for you, or the success of our overall recommendations. Investment recommendations are subject to various market, currency, economic, political, and business risks, and that investment decisions will not always be profitable. 12  It is important that you understand the differences between these types of accounts and decide whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment adviser representative, or call our main number as listed on the cover page of this Brochure. 13