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Brochure
Form ADV Part 2A
Item 1 - Cover Page
Financial Architects, LLC
CRD# 116027
302 Creekstone Ridge
Woodstock, Georgia 30188
(770) 517-8160
www.FinancialArchitectsLLC.com
February 3rd, 2026
This brochure provides information about the qualifications and business practices of Financial
Architects, LLC. If you have any questions about the contents of this brochure, please contact us at
(770) 517-8160 or info@FinancialArchitectsLLC.com. The information in this brochure has not
been approved or verified by the United States Securities and Exchange Commission or by any state
authority.
Financial Architects, LLC is an investment advisory firm registered with the appropriate regulatory
authority. Registration does not imply a certain level of skill or training. Additional information
about FA also is available on the SEC’s website at www.AdviserInfo.sec.gov.
Item 2 - Material Changes
There have been no material changes made to our brochure since our last annual update was filed
on February 10th, 2025. Our Brochure is available to clients at any time upon request.
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Item 3 - Table of Contents
Page
Item 1 - Cover Page ........................................................................................................................................... 1
Item 2 - Material Changes ................................................................................................................................. 1
Item 3 - Table of Contents ............................................................................................................................... 2
Item 4 - Advisory Business ............................................................................................................................... 3
Item 5 - Fees and Compensation .................................................................................................................... 6
Item 6 - Performance-Based Fees and Side-By-Side Management ............................................................ 7
Item 7 - Types of Clients .................................................................................................................................. 7
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss .................................................... 7
Item 9 - Disciplinary Information ................................................................................................................. 12
Item 10 - Other Financial Industry Activities and Affiliations ................................................................. 12
Item 11 - Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading .... 12
Item 12 - Brokerage Practices ........................................................................................................................ 13
Item 13 - Review of Accounts ....................................................................................................................... 15
Item 14 - Client Referrals and Other Compensation ................................................................................. 15
Item 15 – Custody ........................................................................................................................................... 15
Item 16 - Investment Discretion ................................................................................................................... 16
Item 17 - Voting Client Securities ................................................................................................................. 16
Item 18 - Financial Information .................................................................................................................... 16
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Item 4 - Advisory Business
General Information
Financial Architects, LLC (“FA”) was formed in 2005, and provides financial planning, portfolio
management, and general consulting services to its clients.
David E. Hultstrom and Anitha G. Rao are the principal owners of FA. Please see Brochure
Supplements, Exhibit A, for more information on the principal owners who formulate investment
advice and have direct contact with clients, or have discretionary authority over client accounts.
As of December 31st, 2025, FA managed $199,150,091.00 on a discretionary basis, and no assets on
a non-discretionary basis.
Services Provided
At the outset of each client relationship, FA spends time with the client, asking questions, discussing
the client’s investment experience and financial circumstances, and broadly identifying major goals
of the client.
Clients may elect to retain FA to prepare a full financial plan. This written report is presented to the
client for consideration. In many cases, clients subsequently retain FA to manage the investment
portfolio on an ongoing basis.
For those financial planning clients making this election, and for other clients who do not need
financial planning but retain FA for portfolio management services, based on all the information
initially gathered, FA generally develops with each client:
• a financial outline for the client based on the client’s financial circumstances and goals, and
•
the client’s risk tolerance level (the “Financial Profile” or “Profile”); and
the client’s investment objectives and guidelines (the “Investment Plan” or “Plan”).
The Financial Profile is a reflection of the client’s current financial picture and a look to the future
goals of the client. The Investment Plan outlines the types of investments FA will make on behalf of
the client to meet those goals. The Profile and the Plan are discussed regularly with each client, but
are not necessarily written documents.
Finally, where FA provides only general consulting services, FA will work with the client to prepare
an appropriate summary of the specific project(s) to the extent necessary or advisable under the
circumstances.
Financial Planning
One of the services offered by FA is financial planning, described below. This service may be
provided as a stand-alone service, or may be coupled with ongoing portfolio management.
Financial planning generally includes advice that addresses one or more areas of a client’s financial
situation, such as estate planning, risk management, budgeting and cash flow controls, retirement
planning, education funding, and investment portfolio design. Depending on a client’s particular
situation, financial planning may include some or all of the following:
• Gathering factual information concerning the client’s personal and financial situation;
• Assisting the client in establishing financial goals and objectives;
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• Analyzing the client’s present situation and anticipated future activities in light of the client’s
•
financial goals and objectives;
Identifying problems foreseen in the accomplishment of these financial goals and objectives
and offering alternative solutions to the problems;
• Making recommendations to help achieve retirement plan goals and objectives;
• Designing an investment portfolio to help meet the goals and objectives of the client;
• Evaluating estate planning;
• Assessing risk and reviewing basic life, health, and disability insurance needs; or
• Reviewing goals and objectives and measuring progress toward these goals.
Once financial planning advice is given, the client may choose to have FA implement the client’s
financial plan and manage the investment portfolio on an ongoing basis. However, the client is
under no obligation to act upon any of the recommendations made by FA under a financial planning
engagement and/or engage the services of any recommended professional. If the client engages any
professional (i.e. attorney, accountant, insurance agent, etc.), recommended or otherwise, and a
dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively
from the engaged professional. At all times, the engaged licensed professional[s] (i.e. attorney,
accountant, insurance agent, etc.), and not FA, shall be responsible for the quality and competency
of the services provided.
Portfolio Management
Under most circumstances, clients wishing to engage FA for portfolio management services must
initially hire FA to prepare a financial plan (see previous section). FA may make limited exceptions
to this requirement at its sole discretion. Portfolio management services provide implementation of
the Investment Plan, which is incorporated within the Financial Blueprint and developed for the
client during the planning process. The Investment Plan will be updated from time to time when
requested by the client, or when determined to be necessary or advisable by FA based on updates to
the client’s financial or other circumstances.
To implement the client’s Investment Plan, FA will manage the client’s investment portfolio on a
discretionary basis. As a discretionary investment advisor, FA will have the authority to supervise
and direct the portfolio without prior consultation with the client.
Notwithstanding the foregoing, clients may impose certain written restrictions on FA in the
management of their investment portfolios, such as prohibiting the inclusion of certain types of
investments in an investment portfolio or prohibiting the sale of certain investments held in the
account at the commencement of the relationship. Each client should note, however, that
restrictions imposed by a client may adversely affect the composition and performance of the
client’s investment portfolio. Each client should also note that his or her investment portfolio is
treated individually by giving consideration to each purchase or sale for the client’s account. For
these and other reasons, performance of client investment portfolios within the same investment
objectives, goals and/or risk tolerance may differ and clients should not expect that the composition
or performance of their investment portfolios would necessarily be consistent with similar clients of
FA.
General Consulting
In addition to the foregoing services, FA may provide general consulting services to clients. These
services are generally provided on a project basis, and may include, without limitation, providing
expert witness testimony, serving on or advising third-party investment committees, analysis of
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investment portfolios as well as other matters specific to the client as and when requested by the
client and agreed to by FA. The scope and fees for consulting services will be negotiated with each
client at the time of engagement for the applicable project.
General Disclosures
Retirement Rollovers-Conflict of Interest: A client or prospective client leaving an employer
typically has four options regarding an existing retirement plan (and may engage in a combination of
these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the
assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an
Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending
upon the client’s age, result in adverse tax consequences). If FA provides a recommendation as to
whether a client should or should not engage in a rollover, FA is acting as an ERISA fiduciary by
making such recommendation. Furthermore, if FA recommends that a client roll over their
retirement plan assets into an account to be managed by FA, such a recommendation creates a
conflict of interest if FA will earn new (or increase its current) compensation as a result of the
rollover.
Socially Responsible Investing Limitations. Socially Responsible Investing involves the incorporation
of Environmental, Social and Governance considerations into the investment due diligence process
(“ESG). There are potential limitations associated with allocating a portion of an investment
portfolio in ESG securities (i.e., securities that have a mandate to avoid, when possible, investments
in such products as alcohol, tobacco, firearms, oil drilling, gambling, etc.). The number of these
securities may be limited when compared to those that do not maintain such a mandate. ESG
securities could underperform broad market indices. Investors must accept these limitations,
including potential for underperformance. Correspondingly, the number of ESG mutual funds and
exchange traded funds are few when compared to those that do not maintain such a mandate. As
with any type of investment (including any investment and/or investment strategies recommended
and/or undertaken by FA), there can be no assurance that investment in ESG securities or funds
will be profitable, or prove successful.
Cash Positions. FA continues to treat cash as part of the fixed income asset class. As such, unless
determined to the contrary by FA, all cash positions (money markets, etc.) shall continue to be
included as part of assets under management for purposes of calculating FA’s advisory fee. At any
specific point in time, depending upon perceived or anticipated market conditions/events (there
being no guarantee that such anticipated market conditions/events will occur), FA may maintain
cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts
could miss market advances. Depending upon current yields, at any point in time, FA’s advisory fee
could exceed the interest paid by the client’s money market fund.
Use of Mutual Funds: While FA may recommend allocating investment assets to mutual funds that
are not available directly to the public, FA may also recommend that clients allocate investment
assets to publicly-available mutual funds that the client could obtain without engaging FA as an
investment adviser. Other mutual funds, such as those issued by Dimensional Fund Advisors
(“DFA”), are generally only available through selected registered investment advisers. FA may
allocate client investment assets to DFA mutual funds. Therefore, upon the termination of FA’s
services to a client, restrictions regarding transferability and/or additional purchases of, or
reallocation among DFA funds will apply.
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Client Obligations: In performing its services, FA shall not be required to verify any information
received from the client or from the client’s other designated professionals, and is expressly
authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to
promptly notify FA if there is ever any change in their financial situation or investment objectives
for the purpose of reviewing, evaluating or revising FA’s previous recommendations and/or
services.
Item 5 - Fees and Compensation
General Fee Information
Fees paid to FA are exclusive of all custodial and transaction costs paid to the client’s custodian,
brokers or other third-party consultants. Please see Item 12 – Brokerage Practices for additional
information. Fees paid to FA are also separate and distinct from the fees and expenses charged by
mutual funds, ETFs (exchange traded funds) or other investment pools to their shareholders
(generally including a management fee and fund expenses, as described in each fund’s prospectus or
offering materials). The client should review all fees charged by funds, brokers, FA, and others to
fully understand the total amount of fees paid by the client for investment and financial-related
services.
Financial Planning Fees
An estimate of the time required to develop a financial plan for each client is made at the initial
meeting with one half of the estimated fees assessed and payable at the beginning of the engagement
with the remainder due upon delivery of the financial plan.
The comprehensive financial planning engagement is typically $6,000, but these services may be
more (or occasionally less) depending on the complexity and scope of the services to be provided. If
the engagement is terminated prior to the completion of the plan, any prepaid, unearned fees will be
promptly refunded, and any earned unpaid fees will be due and payable.
Portfolio Management Fees
The annual portfolio management fee schedule, based on a percentage of assets under management,
is as follows:
Assets Under Management
First $2,000,000
Thereafter
Annual Fee
1.00%
0.50%
Accordingly, as an example, if an account is valued at $2,500,000, the first $2,000,000 would be
charged 1.00% annually, while the balance of $500,000 would be assessed a fee of 0.50% per year.
FA generally requires a minimum asset level of $2,000,000 for its portfolio management services.
However, FA retains the right to reduce is minimum asset requirement, at its sole discretion.
Portfolio management fees are generally payable quarterly, in arrears. If management begins after the
start of a quarter, fees will be prorated accordingly. Portfolio management fees will not be prorated
for capital contributions or withdrawals made during the applicable calendar quarter. In determining
market value, FA’s includes accrued interest and accrued dividends. With client authorization and
unless other arrangements are made, fees are normally debited directly from client account(s).
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Either FA or the client may terminate their Investment Management Agreement at any time, subject
to any written notice requirements in the agreement. In the event of termination, any paid but
unearned fees will be promptly refunded to the client based on the number of days that the account
was managed, and any fees due to FA from the client will be invoiced or deducted from the client’s
account prior to termination.
General Consulting Fees
When FA provides general consulting services to clients, these services are generally separate from
FA’s financial planning and portfolio management services. Fees for general consulting are
negotiated at the time of the engagement for such services, and are normally based on an hourly fee
of $500 or a flat fee, depending on the nature of the engagement.
Item 6 - Performance-Based Fees and Side-By-Side Management
FA does not have any performance-based fee arrangements. “Side by Side Management” refers to a
situation in which the same firm manages accounts that are billed based on a percentage of assets
under management and at the same time manages other accounts for which fees are assessed on a
performance fee basis. Because FA has no performance-based fee accounts, it has no side-by-side
management.
Item 7 - Types of Clients
FA serves individuals, trusts, estates, and charitable organizations.
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
FA’s approach is driven by academic (as opposed to Wall Street) research and therefore is grounded
in what we believe is optimal and prudent rather than oriented toward the fads and fashions of the
moment or what will sell well to the public. We think that when Wall Street builds a better
mousetrap, investors are generally the mouse. Our approach is long-term, strategic, and based on
well-established financial theory, empirical data, experience, and judgment. Specifically:
• With a few caveats (see next two points), we accept that markets are efficient. This means
that individual securities are generally priced correctly ex ante and incurring additional costs
in the hopes of finding a mispricing is wasteful though of course apparent mispricings will
seem obvious ex post. In short, active management does not consistently add value through
security selection or market timing thus we will invest almost exclusively through index
funds and other passively managed vehicles.
• Notwithstanding the overall validity of market efficiency described above, there are a few
anomalies that appear to be both pervasive (they exist in most markets) and persistent (they
exist most of the time). The most significant of these anomalies are value and momentum,
but there is some evidence of others as well. We will tilt portfolios toward factors such as
value and momentum that appear to reward investors over time.
•
It also appears that while stocks of smaller companies don’t outperform (after adjusting for
risk) larger companies, it does appear that factor tilts such as value and momentum may be
larger in smaller companies. Thus, we will tilt portfolios toward smaller companies.
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• The aforementioned tilts to various factors can, and almost certainly will, give rise to
tracking error. What this means is that your portfolio will not exactly track vanilla
indexes such as the S&P 500. Over time we expect the performance of your portfolio to
exceed widely followed benchmarks, but of course it is not guaranteed and it can sometimes
take a while for this to happen.
• Both diversification and cost control are crucial. Thus, we will use mutual funds or
exchange traded funds (ETFs) to gain exposure to various asset classes due to their broad
holdings, low costs, and low turnover (which also reduces costs).
• Diversification between risky asset classes (domestic stocks and foreign stocks for example)
is beneficial in prosperous times to ensure exposure to whatever area is currently doing well.
During market turmoil however, the benefit of diversification between these risky asset
classes largely vanishes as they all decline together. Diversification still works however, but it
is the diversification of also holding safe assets (investment grade bonds) in a portfolio. If
everything in your portfolio is going up, you aren’t diversified.
• From peak to trough, U.S. stocks declined in nominal dollars by between 45 and 55 percent
in 1973-1974, 2000-2002, and 2007-2008. Therefore, during poor markets, investors
should expect the risky portion of their portfolios to decline by approximately half.
For example, an investor with a $1,000,000 portfolio that is 60% stocks and 40% bonds
should experience a decline to $700,000 periodically. This is the necessary pain to achieve the
higher returns that are expected from risky assets. If stocks did not occasionally experience
losses, they would cease to be priced attractively enough to earn superior returns. It is our
job to make sure client portfolios are positioned at an appropriate level of risk and that our
clients do not increase their risk-taking when things look rosy (e.g. 2006) and do not
decrease their risk exposure when the outlook is frightening (e.g. 2008).
• Foreign investments will be used for additional diversification. Thus, for international
exposure we will invest in smaller companies and/or emerging markets companies
rather than in large companies in developed countries since they offer much greater
diversification benefit to an investor who already owns large U.S. companies.
• For additional diversification, a portion of the portfolio may be invested in “alternative”
investments such as, but not limited to, REITs (Real Estate Investment Trusts), high yield
bonds (aka junk bonds), MLPs (Master Limited Partnerships), and hedge fund like
investments (though with much lower cost, greater transparency, and greater liquidity).
While it would be imprudent to place a large percentage of a portfolio in these types of
investments, in smaller proportions they can improve the risk/return profile. Dose
determines toxicity.
• Depending on the specific inflation exposure of each client outside of their portfolio, some
or all of the bond allocation may be to TIPS (Treasury Inflation Protected Securities).
• While we review portfolios and the market environment frequently, we make changes very
infrequently. Turnover has costs and generally doesn’t add value (though it does make
everyone feel better to “do something” rather than simply stay the course). As Warren
Buffett has said, “Much success can be attributed to inactivity. Most investors cannot resist
the temptation to constantly buy and sell.” He also stated, “Lethargy, bordering on sloth,
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should remain the cornerstone of an investment style.” Once a client’s portfolio is invested
appropriately, we will not do much trading aside from opportunistic tax loss harvesting.
This is a sign of prudence and patience, not inattention. We do not trade simply to appear
busy.
•
If we manage multiple household accounts for you, we will manage them as part of one
portfolio to increase trading efficiency, tax efficiency, etc. Thus, when viewed in isolation,
individual accounts may have what appears to be an “odd” investment allocation, but
it is appropriate when viewed in the context of your overall portfolio and life circumstances.
Borrowing Against Assets/Risks. A client who has a need to borrow money could determine to do
so by using:
• Margin-The account custodian or broker-dealer lends money to the client. The custodian
charges the client interest for the right to borrow money, and uses the assets in the client’s
brokerage account as collateral; and,
• Pledged Assets Loan- In consideration for a lender (i.e., a bank, etc.) to make a loan to the
client, the client pledges its investment assets held at the account custodian as collateral;
These above-described collateralized loans are generally utilized because they typically provide
more favorable interest rates than standard commercial loans. These types of collateralized
loans can assist with a pending home purchase, permit the retirement of more expensive debt,
or enable borrowing in lieu of liquidating existing account positions and incurring capital gains
taxes. However, such loans are not without potential material risk to the client’s investment
assets. The lender (i.e. custodian, bank, etc.) will have recourse against the client’s investment
assets in the event of loan default or if the assets fall below a certain level. For this reason, FA
does not recommend such borrowing unless it is for specific short-term purposes (i.e. a bridge
loan to purchase a new residence). FA does not recommend such borrowing for investment
purposes (i.e. to invest borrowed funds in the market). Regardless, if the client was to
determine to utilize margin or a pledged assets loan, the following economic benefits would
inure to FA.
• by taking the loan rather than liquidating assets in the client’s account, FA continues to earn a
fee on such Account assets; and,
•
if the client invests any portion of the loan proceeds in an account to be managed by FA, FA
will receive an advisory fee on the invested amount; and,
•
if FA’s advisory fee is based upon the higher margined account value, FA will earn a
correspondingly higher advisory fee. This could provide FA with a disincentive to encourage
the client to discontinue the use of margin.
The client must accept the above risks and potential corresponding consequences associated with the
use of margin or a pledged-assets loans.
Investment Strategies:
FA’s strategic approach is to invest each portfolio in accordance with the Plan that has been
developed specifically for each client. This means that the following strategies may be used in
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varying combinations over time for a given client, depending upon the client’s individual
circumstances.
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.
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.
FA may allocate investment management assets of its client accounts, on a discretionary basis,
among one or more of its asset allocation models. FA’s asset allocation model administration has
been designed to comply with the requirements of Rule 3a-4 of the Investment Company Act of
1940. Rule 3a-4 provides similarly managed investment programs with a non-exclusive safe harbor
from the definition of an investment company. In accordance with Rule 3a-4, the following
disclosure is applicable to FA’s management of client assets asset allocation models:
1. Initial Interview – at the opening of the account, FA, through its designated representatives,
shall obtain from the client information sufficient to determine the client’s financial situation
and investment objectives;
2. Individual Treatment – the account is managed on the basis of the client’s financial situation
and investment objectives;
3. Quarterly Notice – at least quarterly FA shall notify the client to advise FA whether the
client’s financial situation or investment objectives have changed, or if the client wants to
impose and/or modify any reasonable restrictions on the management of the account;
4. Annual Contact – at least annually, FA shall contact the client to determine whether the
client’s financial situation or investment objectives have changed, or if the client wants to
impose and/or modify any reasonable restrictions on the management of the account;
5. Consultation Available – FA shall be reasonably available to consult with the client related to
the status of the account;
6. Quarterly Report – the client shall be provided with a quarterly report for the account for
the preceding period;
7. Ability to Impose Restrictions – the client shall have the ability to impose reasonable
restrictions on the management of the account, including the ability to instruct FA not to
purchase certain securities;
8. No Pooling – the client’s beneficial interest in a security does not represent an undivided
interest in all the securities held by the custodian, but rather represents a direct and beneficial
interest in the securities which comprise the account;
9. Separate Account – a separate account is maintained for the client with the Custodian;
10. Ownership – each client retains indicia of ownership of the account (e.g. right to withdraw
securities or cash, exercise or delegate proxy voting, and receive transaction confirmations).
FA believes that its annual wealth management fee is reasonable in relation to: (1) the advisory
services provided under its service agreement; and (2) the fees charged by other investment advisers
offering similar services/programs. However, FA’s annual investment advisory fee may be higher
than that charged by other investment advisers offering similar services/programs. In addition to
FA’s annual wealth management fee, the client will also incur charges imposed directly at the mutual
and exchange traded fund level (e.g., management fees and other fund expenses). FA’s investment
programs may involve above-average portfolio turnover which could negatively impact upon the net
after-tax gain experienced by an individual client in a taxable account.
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Risk of Loss
While FA seeks to diversify clients’ investment portfolios across various asset classes consistent with
their Investment Plans in an effort to reduce risk of loss, all investment portfolios are subject to
risks. Accordingly, there can be no assurance that client investment portfolios will be able to fully
meet their investment objectives and goals, or that investments will not lose money. Investing in
securities involves a risk of loss that clients should be prepared to bear.
Below is a description of several of the principal risks that client investment portfolios face.
Management Risks. While FA manages client investment portfolios based on FA’s experience,
research and proprietary methods, the value of client investment portfolios will change daily
based on the performance of the underlying securities in which they are invested.
Accordingly, client investment portfolios are subject to the risk that FA allocates client assets
to individual securities and/or asset classes that are adversely affected by unanticipated
market movements, and the risk that FA’s specific investment choices could underperform
their relevant indexes.
Risks of Investments in Mutual Funds, ETFs, and Other Investment Pools. As described above, FA
may invest client portfolios in mutual funds, ETFs, and other investment pools (“pooled
investment funds”). Investments in pooled investment funds in general may be less risky
than investing in individual securities because of their diversified portfolios; however, these
investments are still subject to risks associated with the markets in which they invest. In
addition, pooled investment funds’ success will be related to the skills of their particular
managers and their performance in managing their funds. Pooled investment funds are also
subject to risks due to regulatory restrictions applicable to registered investment companies
under the Investment Company Act of 1940.
Equity Market Risks. FA will generally invest portions of client assets directly into equity
investments, primarily through ETFs, or into other pooled investment funds that invest in
the stock market. As noted above, while pooled investments have diversified portfolios that
may make them less risky than investments in individual securities, funds that invest in
stocks and other equity securities are nevertheless subject to the risks of the stock market.
These risks include, without limitation, the risks that stock values will decline due to daily
fluctuations in the markets, and that stock values will decline over longer periods (e.g., bear
markets) due to general market declines in the stock prices for all companies, regardless of
any individual security’s prospects.
Fixed Income Risks. FA may invest portions of client assets directly into fixed income
instruments, such as bonds and notes, or may invest in pooled investment funds that invest
in bonds and notes. While investing in fixed income instruments, either directly or through
pooled investment funds, is generally less volatile than investing in stock (equity) markets,
fixed income investments nevertheless are subject to risks. These risks include, without
limitation, interest rate risks (risks that changes in interest rates will devalue the investments),
credit risks (risks of default by borrowers), or maturity risk (risks that bonds or notes will
change value from the time of issuance to maturity).
Foreign Securities Risks. FA may invest portions of client assets into pooled investment funds
that invest internationally. While foreign investments are important to the diversification of
client investment portfolios, they carry risks that may be different from U.S. investments.
For example, foreign investments may not be subject to uniform audit, financial reporting or
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disclosure standards, practices or requirements comparable to those found in the U.S.
Foreign investments are also subject to foreign withholding taxes and the risk of adverse
changes in investment or exchange control regulations. Finally, foreign investments may
involve currency risk, which is the risk that the value of the foreign security will decrease due
to changes in the relative value of the U.S. dollar and the security’s underlying foreign
currency.
Item 9 - Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to a client’s evaluation of FA or the integrity of FA’s
management. FA has no disciplinary events to report.
Item 10 - Other Financial Industry Activities and Affiliations
David Hultstrom, President of FA, in addition to his portfolio management and financial planning
work with FA, occasionally teaches classes for other financial professionals, is a guest speaker at
seminars and conferences, and is engaged as a consultant by other advisory firms. Previously, he has
served as an arbitrator for FINRA, as an expert witness in legal cases, as an adjunct professor at
local universities, and has taught review courses to advisors preparing for the Certified Financial
Planner™ exam. He may engage in these activities in the future as well. All such services are
incidental to FA’s primary business. Mr. Hultstrom may devote as much as 5% of his time to these
activities.
Item 11 - Code of Ethics, Participation or Interest in Client Transactions, and Personal
Trading
Code of Ethics and Personal Trading
FA has adopted a Code of Ethics (“the Code”), the full text of which is available to you upon
request. FA’s Code has several goals. First, the Code is designed to assist FA in complying with
applicable laws and regulations governing its investment advisory business. Under the Investment
Advisers Act of 1940, FA owes fiduciary duties to its clients. Pursuant to these fiduciary duties, the
Code requires persons associated with FA (managers, officers and employees) to act with honesty,
good faith and fair dealing in working with clients. In addition, the Code prohibits such associated
persons from trading or otherwise acting on insider information.
Next, the Code sets forth guidelines for professional standards for FA’s associated persons. Under
the Code’s Professional Standards, FA expects its associated persons to put the interests of its
clients first, ahead of personal interests. In this regard, FA associated persons are not to take
inappropriate advantage of their positions in relation to FA clients.
Third, the Code sets forth policies and procedures to monitor and review the personal trading
activities of associated persons. From time to time FA’s associated persons may invest in the same
securities recommended to clients. Under its Code, FA has adopted procedures designed to reduce
or eliminate conflicts of interest that this could potentially cause. The Code’s personal trading
policies include procedures for limitations on personal securities transactions of associated persons,
reporting and review of such trading. These policies are designed to discourage and prohibit
personal trading that would disadvantage clients.
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Participation or Interest in Client Transactions
Because client accounts are primarily invested in mutual funds and ETFs, there is little opportunity
for a conflict of interest between personal trades by FA associated persons and trades in client
accounts, even when such accounts invest in the same securities. However, in the event of other
identified potential trading conflicts of interest, FA’s goal is to place client interests first.
Consistent with the foregoing, FA maintains policies regarding participation in initial public
offerings (“IPOs”) and private placements to comply with applicable laws and avoid conflicts with
client transactions. If a FA associated person wishes to participate in an IPO or invest in a private
placement, he or she must submit a pre-clearance request and obtain the approval of the Chief
Compliance Officer.
Finally, if associated persons trade with client accounts (e.g., in a bundled or aggregated trade), and
the trade is not filled in its entirety, the associated person’s shares will be removed from the block,
and the balance of shares will be allocated among client accounts in accordance with FA’s written
policy.
Item 12 - Brokerage Practices
In the event that the client requests, FA may recommend a broker-dealer/custodian for execution
and/or custodial services. FA generally recommends that investment management accounts be
maintained at Charles Schwab & Co. Inc. (“Schwab”). Factors that FA considers in recommending
Schwab (or any other broker-dealer/custodian to clients) include their historical relationship with
FA, financial strength, reputation, execution capabilities, pricing, research, and service. Although the
commissions and/or transaction fees you pay shall comply with the FA’s duty to seek best
execution, a client may pay a commission that is higher than another qualified broker-dealer might
charge to effect the same transaction where FA determines, in good faith, that the
commission/transaction fee is reasonable.
Best Execution and Benefits of Brokerage Selection
When using our recommended broker-dealer for execution of orders in client accounts, FA seeks
“best execution” for client trades, which is a combination of a number of factors, including, without
limitation, quality of execution, services provided, and commission rates. Therefore, FA may use or
recommend the use of brokers who do not charge the lowest available commission in the
recognition of research and securities transaction services, or quality of execution. Research services
received with transactions may include proprietary or third-party research (or any combination), and
may be used in servicing any or all of FA’s clients. Therefore, research services received may not be
used for the account for which the particular transaction was effected.
FA recommends that clients establish brokerage accounts with Charles Schwab & Co., Inc.
(“Schwab”), a FINRA registered broker-dealer, member SIPC, as the qualified custodian to maintain
custody of clients’ assets. FA will also effect trades for client accounts at Schwab, or may in some
instances, consistent with FA’s duty of best execution and specific agreement with each client, elect
to execute trades elsewhere. Although FA may recommend that clients establish accounts at Schwab,
it is ultimately the client’s decision to custody assets with Schwab. FA is independently owned and
operated and is not affiliated with Schwab.
Schwab Advisor Services provides FA with access to its institutional trading, custody, reporting, and
related services, which are typically not available to Schwab retail investors. Schwab also makes
available various support services. Some of those services help FA manage or administer our clients’
Page 13
accounts while others help FA manage and grow our business. These services are not soft dollar
arrangements, but are part of the institutional platform offered by Schwab. These services generally
are available to independent investment advisors on an unsolicited basis, at no charge to them.
Schwab’s brokerage services include the execution of securities transactions, custody, research, and
access to mutual funds and other investments that are otherwise generally available only to
institutional investors or would require a significantly higher minimum initial investment.
For FA client accounts maintained in its custody, Schwab generally does not charge separately for
custody services but is compensated by account holders through commissions and other
transaction-related or asset-based fees for securities trades that are executed through Schwab or that
settle into Schwab accounts. Schwab Advisor Services also makes available to FA other products
and services that benefit FA but may not directly benefit its clients’ accounts. Many of these
products and services may be used to service all or some substantial number of FA accounts,
including accounts not maintained at Schwab.
Schwab’s products and services that assist FA in managing and administering clients’ accounts
include software and other technology that (i) provide access to client account data (such as trade
confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade
orders for multiple client accounts; (iii) provide pricing and other market data; (iv) facilitate payment
of FA’s fees from its clients’ accounts; and (v) assist with back-office functions, recordkeeping, and
client reporting.
Schwab Advisor Services also offers other services intended to help FA manage and further develop
its business enterprise. These services may include: (i) technology, compliance, legal, and business
consulting; (ii) publications and conferences on practice management and business succession; and
(iii) access to employee benefits providers, human capital consultants, and insurance providers.
Schwab may make available, arrange, and/or pay third-party vendors for the types of services
rendered to FA. Schwab Advisor Services may discount or waive fees it would otherwise charge for
some of these services or pay all or a part of the fees of a third-party providing these services to FA.
Schwab Advisor Services may also provide other benefits such as educational events or occasional
business entertainment of FA personnel. In evaluating whether to recommend that clients custody
their assets at Schwab, FA may take into account the availability of some of the foregoing products
and services and other arrangements as part of the total mix of factors it considers and not solely on
the nature, cost, or quality of custody and brokerage services provided by Schwab, which may create
a potential conflict of interest.
Directed Brokerage
As noted above, FA recommends clients receiving portfolio management services custody their
assets with Schwab. We believe that the use of Schwab as broker to execute transactions is in the
best interest of our clients as Schwab provides competitive execution services and commission rates
as well as knowledgeable and responsive support staff as described above. However, clients should
be aware that other broker-dealers may charge less for similar services. FA will periodically evaluate
the execution, performance, and reliability of Schwab to help ensure quality executions. Nonetheless,
it is your sole decision to determine whether you wish to open a brokerage account with Schwab.
Aggregated Trade Policy
FA typically directs trading in individual client accounts as and when trades are appropriate based on
the client’s Investment Plan, without regard to activity in other client accounts. However, from time
to time, FA may aggregate trades together for multiple client accounts, most often when these
accounts are being directed to sell the same securities. If such an aggregated trade is not completely
Page 14
filled, FA will allocate shares received (in an aggregated purchase) or sold (in an aggregated sale)
across participating accounts on a pro rata or other fair basis; provided, however, that any
participating accounts that are owned by FA or its officers, directors, or employees will be excluded
first.
Item 13 - Review of Accounts
Managed portfolios are reviewed at least quarterly, but may be reviewed more often if requested by
the client, upon receipt of information material to the management of the portfolio, or at any time
such review is deemed necessary or advisable by FA. These factors generally include but are not
limited to, the following: change in general client circumstances (marriage, divorce, retirement); or
economic, political, or market conditions. All client accounts are reviewed by a qualified investment
adviser representative, who holds at least a CFP® designation. FA utilizes dedicated financial
software to assist with the portfolio review.
For those clients to whom FA provides separate financial planning and/or consulting services,
reviews are conducted on an as needed or agreed upon basis. Such reviews are conducted by a
qualified investment adviser representative, who holds at least a CFP® designation.
Account custodians are responsible for providing monthly or quarterly account statements which
reflect the positions (and current pricing) in each account as well as transactions in each account,
including fees paid from an account. Account custodians also provide prompt confirmation of all
trading activity and year-end tax statements, such as 1099 forms. In addition, FA provides at least a
quarterly report for each managed portfolio. This written report normally includes a summary of
portfolio holdings and performance results. Additional reports are available at the request of the
client.
Item 14 - Client Referrals and Other Compensation
As noted above, FA receives an economic benefit from Schwab in the form of support products and
services it makes available to FA and other independent investment advisors that have their clients
maintain accounts at Schwab. These products and services, how they benefit our firm, and the
related conflicts of interest are described in Item 12 - Brokerage Practices. The availability of
Schwab’s products and services to FA is based solely on our participation in the program, and not
on the provision of any particular investment advice. Neither Schwab nor any other party is paid to
refer clients to FA.
Item 15 – Custody
Schwab is currently the custodian of all client accounts at FA. From time to time however, clients
may select an alternate broker to hold accounts in custody. In any case, it is the custodian’s
responsibility to provide clients with confirmations of trading activity, tax forms, and at least
quarterly account statements. Clients are advised to review this information carefully, and to notify
FA of any questions or concerns. Clients are also asked to promptly notify FA if the custodian fails
to provide statements on each account held.
From time to time and in accordance with FA’s agreement with clients, FA will provide additional
reports. The account balances reflected on these reports should be compared to the balances shown
on the brokerage statements to ensure accuracy. At times there may be small differences due to the
timing of dividend reporting, pending trades, or other similar issues.
Page 15
Item 16 - Investment Discretion
As described above under Item 4 - Advisory Business, FA manages portfolios on a discretionary
basis. This means that after an Investment Plan is developed for the client’s investment portfolio,
FA will execute that plan without specific consent from the client for each transaction. For
discretionary accounts, a Limited Power of Attorney (“LPOA”) is executed by the client, giving FA
the authority to carry out various activities in the account, generally including the following: trade
execution, the ability to request checks on behalf of the client, and the withdrawal of advisory fees
directly from the account. The client may limit the terms of the LPOA to the extent consistent with
the client’s investment advisory agreement with FA and the requirements of the client’s custodian.
The discretionary relationship is further described in the agreement between FA and the client.
Item 17 - Voting Client Securities
As a policy and in accordance with FA’s client agreement, FA does not vote proxies related to
securities held in client accounts. The custodian of the account will normally provide proxy materials
directly to the client. Clients may contact FA with questions relating to proxy procedures and
proposals; however, FA generally does not research specific proxy proposals.
Item 18 - Financial Information
FA does not require nor solicit prepayment of more than $1,200 in fees per client six months or
more in advance, and therefore has no disclosure required for this item.
Page 16
Brochure Supplement Form ADV Part 2B
Item 1 - Cover Page
David E. Hultstrom, CFA, CFP®, ChFC®, CAIA, CPWA®, CIMA®
CRD# 1968772 of Financial Architects, LLC
302 Creekstone Ridge
Woodstock, Georgia 30188
(770) 517-8160
www.FinancialArchitectsLLC.com
February 3rd, 2026
This brochure supplement provides information about David E. Hultstrom, and supplements the
Financial Architects, LLC (“FA”) brochure. You should have received a copy of that brochure.
Please contact FA at (770) 517-8160 if you did not receive FA’s brochure, or if you have any
questions about the contents of this supplement.
Additional information about David is available on the SEC’s website at www.AdviserInfo.sec.gov.
Item 2 - Educational Background and Business Experience
David E. Hultstrom (born 1967) has served as the President and Portfolio Manager of FA since
founding the firm in 2002 and Chief Compliance Officer for 2022. He has been employed by
American Financial Advisors as Chief Investment Officer, and his previous positions include
Director of Training with Financeware, a financial planning software firm, and serving as Vice
President of Wheat First Butcher Singer (and its successors).
David holds a B.S. in Business Administration with a minor in Computer Science from Pensacola
Christian College. He also received an MBA from the University of West Florida.
David has earned the Chartered Financial Analyst®1 designation and is a CERTIFIED FINANCIAL
PLANNER™ professional2. David is also a Chartered Financial Consultant®3, Chartered Alternative
Investment Analyst4, Certified Private Wealth Advisor®5, and Certified Investment Management
Analyst®6.
1The Chartered Financial Analyst (“CFA”) designation is a professional designation given by the
CFA Institute that measures the competence and integrity of financial analysts. The CFA Program is
a graduate-level self-study program that combines a broad-based curriculum of investment principles
with professional conduct requirements. Candidates are required to pass three levels of examinations
covering areas such as accounting, economics, ethics, money management, and security analysis.
Before a candidate is eligible to become a CFA charter holder, he/she must meet minimum
experience requirements in the area of investment/financial practice. To enroll in the program, a
candidate must hold a bachelor’s degree.
2Certified Financial Planner Board of Standards, Inc. (“CFP Board”) owns the CFP® certification
mark, the CERTIFIED FINANCIAL PLANNER™ certification mark, and the CFP® certification
mark (with flame design) logo in the United States (these marks are collectively referred to as the
Page 17
“CFP® marks”). The CFP Board authorizes use of the CFP® marks by individuals who successfully
complete the CFP Board’s initial and ongoing certification requirements.
The CFP® certification is a voluntary certification; no federal or state law or regulation requires
financial planners to hold CFP® certification. It is recognized in the United States and a number of
other countries for its (1) high standard of professional education; (2) stringent code of conduct and
standards of practice; and (3) ethical requirements that govern professional engagements with
clients. Currently, more than 92,000 individuals have obtained CFP® certification.
To attain the right to use the CFP® marks, an individual must currently satisfactorily fulfill the
following requirements:
• Education – Complete a college-level course of study addressing the financial planning
subject areas that CFP Board’s studies have determined as necessary for the competent and
professional delivery of financial planning services or an accepted equivalent, including
completion of a financial plan development capstone course, and attain a Bachelor’s Degree
from an accredited college or university. CFP Board’s financial planning subject areas
include professional conduct and regulation, general principles of financial planning,
education planning, risk management and insurance planning, investment planning, income
tax planning, retirement savings and income planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The examination,
administered in 6 hours, includes case studies and client scenarios designed to test one’s
ability to correctly diagnose financial planning issues and apply one’s knowledge of financial
planning to real world circumstances;
• Experience – CFP Board requires 6,000 hours of experience through the Standard Pathway,
or 4,000 hours of experience through the Apprenticeship Pathway that meets additional
requirements; and
• Ethics – Agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct, which put
clients’ interest first; acknowledge CFP Board’s right to enforce them through its Disciplinary
Rules and Procedures; comply with the Financial Planning Practice Standards which determine what
clients should reasonably expect from the financial planning engagement and complete a
CFP® Certification Application which requires disclosure of an individual’s background,
including involvement in any criminal, civil, governmental, or self-regulatory agency
proceeding or inquiry, bankruptcy, customer complaint, filing, termination/internal reviews
conducted by the individual’s employer or firm.
Individuals who become certified must complete the following ongoing education and ethics
requirements in order to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours accepted by the
CFP Board every two years, including two hours on the Code of Ethics and other parts of the
Standards of Professional Conduct, to maintain competence and keep up with developments in
the financial planning field; and
• Ethics – CFP® professionals agree to adhere to the high standards of ethics and practice
outlined in CFP Board’s Code of Ethics and Standards of Conduct and to acknowledge CFP
Board’s right to enforce them through its Disciplinary Rules and Procedures. The Code of
Ethics and Standards of Conduct require that CFP® professionals provide financial planning
services in the best interests of their clients.
• Certification Application – Properly complete a Certification Application to (i) acknowledge
voluntary adherence to the terms and conditions of certification with CFP Board and (ii)
Page 18
disclose any involvement in criminal and civil proceedings, inquiries or investigations,
bankruptcy filings, internal reviews and customer complaints.
CFP® professionals who fail to comply with the above standards and requirements may be subject to
CFP Board’s enforcement process, which could result in suspension or permanent revocation of
their CFP® certification.
You may verify an individual’s CFP® certification and background through the CFP Board. The
verification function will allow you to verify an individual’s certification status, CFP Board’s
disciplinary history and any bankruptcy disclosures in the past ten years. Additional regulatory
information may also be found through FINRA’s BrokerCheck and the SEC’s Investment Adviser
Public Disclosure databases, which are free tools that may be used to conduct research on the
background and experience of CFP® professionals and those who held CFP® certification at one
time, including with respect to employment history, regulatory actions, and investment-related
licensing information, arbitrations, and complaints.
3The ChFC® is a financial planning designation awarded by the American College. ChFC® candidates
must have at least three years of experience in the financial industry, and have studied and passed an
examination on the fundamentals of financial planning, including income tax, insurance, investment
and estate planning.
4The Chartered Alternative Investment Analyst (“CAIA”) designation, recognized globally, is
administered by the Chartered Alternative Investment Analyst Association. To qualify for the CAIA
designation, finance professionals must complete a self-directed, comprehensive course of study on
risk-return attributes of institutional quality alternative assets; pass all necessary CAIA examination
requirements at global, proctored testing centers; attest annually to the terms of the Member
Agreement; and hold a U.S. bachelor’s degree (or equivalent) plus have at least one year of
professional experience; or have four years of professional experience.
5The Certified Private Wealth Advisor® (CPWA®) designation signifies that an individual has met
initial and on-going experience, ethical, education, and examination requirements for the
professional designation, which is centered on management topics and strategies for high-net-worth
clients. Prerequisites for the CPWA designation are: a Bachelor’s degree from an accredited college
or university or one of the following designations or licenses: CIMA®, CIMC®, CFA®, CFP®, ChFC®
or CPA license; acceptable regulatory history as evidenced by FINRA Form U-4 or other regulatory
requirements; five years of professional client-centered experience in financial services or a related
industry; and two letters of reference from an IWI member, professional supervisor, or currently
licensed professional in financial services or a related industry. CPWA designees must complete a
six-month pre-class educational component and a five-day classroom education program through
The University of Chicago Booth School of Business. CPWA designees are required to adhere to
IWI’s Code of Professional Responsibility and Rules and Guidelines for Use of the Marks. CPWA
designees must report 40 hours of continuing education credits, including two ethics hours, every
two years to maintain the certification. The designation is administered through Investments &
Wealth Institute™.
6The CIMA certification signifies that an individual has met initial and on-going experience, ethical,
education, and examination requirements for investment management consulting, including
advanced investment management theory and application. Prerequisites for the CIMA certification
are three years of financial services experience and an acceptable regulatory history. To obtain the
CIMA certification, candidates must pass an online Qualification Examination, successfully
Page 19
complete a one-week classroom education program provided by a Registered Education Provider at
an AACSB accredited university business school, pass an online Certification Examination, and have
an acceptable regulatory history as evidenced by FINRA Form U-4 or other regulatory
requirements. CIMA designees are required to adhere to IWI’s Code of Professional Responsibility,
Standards of Practice, and Rules and Guidelines for Use of the Marks. CIMA designees must report 40 hours
of continuing education credits, including two ethics hours, every two years to maintain the
certification. The designation is administered through Investments & Wealth Institute (IWI).
The CIMA certification has earned ANSI® (American National Standards Institute) accreditation
under the personnel certification program. ANSI is a private non-profit organization that facilitates
standardization and conformity assessment activities in the United States. CIMA is the first financial
services credential to meet this international standard for personnel certification.
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, David has no such disciplinary
information to report.
Item 4 - Other Business Activities
Please see ADV Part 2A - Item 10 – Financial Industry Activities and Affiliations for
information regarding David’s other financial industry activities provided through FA.
Item 5 - Additional Compensation
David receives no compensation from anyone other than clients for providing advisory services.
Item 6 - Supervision
As majority owner of FA, David E. Hultstrom supervises all duties and activities of the firm, and is
responsible for all advice provided to clients. Kaitlyn Barnes, in her capacity as Chief Compliance
Officer for FA, has responsibility for monitoring the advice David provides clients. She may be
reached at 770-517-8160 or Kaitlyn@FinancialArchitectsLLC.com.
Page 20
Brochure Supplement Form ADV Part 2B
Item 1 - Cover Page
Anitha G. Rao, CFP®, CIMA®, CPWA®
CRD# 5774635 of Financial Architects, LLC
302 Creekstone Ridge
Woodstock, Georgia 30188
(770) 517-8160
www.FinancialArchitectsLLC.com
February 3rd, 2026
This brochure supplement provides information about Anitha G. Rao, and supplements the
Financial Architects, LLC (“FA”) brochure. You should have received a copy of that brochure.
Please contact FA at (770) 517-8160 if you did not receive FA’s brochure, or if you have any
questions about the contents of this supplement.
Additional information about Anitha is available on the SEC’s website at www.AdviserInfo.sec.gov.
Item 2 - Educational Background and Business Experience
Anitha G. Rao (born 1967) has served as Vice President and Wealth Manager of FA since October
2005. She also served as Chief Compliance Officer from October 2005 to February 2022. She holds
a B.S. in Electrical Engineering from the University of Maryland, College Park. Anitha is also a
CERTIFIED FINANCIAL PLANNER™ professional1, Certified Investment Management
Analyst®2, and has received the Certified Private Wealth Advisor®3 certification.
1Certified Financial Planner Board of Standards, Inc. (“CFP Board”) owns the CFP® certification
mark, the CERTIFIED FINANCIAL PLANNER™ certification mark, and the CFP® certification
mark (with flame design) logo in the United States (these marks are collectively referred to as the
“CFP® marks”). The CFP Board authorizes use of the CFP® marks by individuals who successfully
complete the CFP Board’s initial and ongoing certification requirements.
The CFP® certification is a voluntary certification; no federal or state law or regulation requires
financial planners to hold CFP® certification. It is recognized in the United States and a number of
other countries for its (1) high standard of professional education; (2) stringent code of conduct and
standards of practice; and (3) ethical requirements that govern professional engagements with
clients. Currently, more than 92,000 individuals have obtained CFP® certification.
To attain the right to use the CFP® marks, an individual must currently satisfactorily fulfill the
following requirements:
• Education – Complete a college-level course of study addressing the financial planning
subject areas that CFP Board’s studies have determined as necessary for the competent and
professional delivery of financial planning services or an accepted equivalent, including
completion of a financial plan development capstone course, and attain a Bachelor’s Degree
from an accredited college or university. CFP Board’s financial planning subject areas
include professional conduct and regulation, general principles of financial planning,
Page 21
education planning, risk management and insurance planning, investment planning, income
tax planning, retirement savings and income planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The examination,
administered in 6 hours, includes case studies and client scenarios designed to test one’s
ability to correctly diagnose financial planning issues and apply one’s knowledge of financial
planning to real world circumstances;
• Experience – CFP Board requires 6,000 hours of experience through the Standard Pathway,
or 4,000 hours of experience through the Apprenticeship Pathway that meets additional
requirements; and
• Ethics – Agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct, which put
clients’ interest first; acknowledge CFP Board’s right to enforce them through its Disciplinary
Rules and Procedures; comply with the Financial Planning Practice Standards which determine what
clients should reasonably expect from the financial planning engagement and complete a
CFP® Certification Application which requires disclosure of an individual’s background,
including involvement in any criminal, civil, governmental, or self-regulatory agency
proceeding or inquiry, bankruptcy, customer complaint, filing, termination/internal reviews
conducted by the individual’s employer or firm.
Individuals who become certified must complete the following ongoing education and ethics
requirements in order to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours accepted by the
CFP Board every two years, including two hours on the Code of Ethics and other parts of the
Standards of Professional Conduct, to maintain competence and keep up with developments in
the financial planning field; and
• Ethics – CFP® professionals agree to adhere to the high standards of ethics and practice
outlined in CFP Board’s Code of Ethics and Standards of Conduct and to acknowledge CFP
Board’s right to enforce them through its Disciplinary Rules and Procedures. The Code of
Ethics and Standards of Conduct require that CFP® professionals provide financial planning
services in the best interests of their clients.
• Certification Application – Properly complete a Certification Application to (i) acknowledge
voluntary adherence to the terms and conditions of certification with CFP Board and (ii)
disclose any involvement in criminal and civil proceedings, inquiries or investigations,
bankruptcy filings, internal reviews and customer complaints.
CFP® professionals who fail to comply with the above standards and requirements may be subject to
CFP Board’s enforcement process, which could result in suspension or permanent revocation of
their CFP® certification.
You may verify an individual’s CFP® certification and background through the CFP Board. The
verification function will allow you to verify an individual’s certification status, CFP Board’s
disciplinary history and any bankruptcy disclosures in the past ten years. Additional regulatory
information may also be found through FINRA’s BrokerCheck and the SEC’s Investment Adviser
Public Disclosure databases, which are free tools that may be used to conduct research on the
background and experience of CFP® professionals and those who held CFP® certification at one
time, including with respect to employment history, regulatory actions, and investment-related
licensing information, arbitrations, and complaints.
2The CIMA certification signifies that an individual has met initial and on-going experience, ethical,
education, and examination requirements for investment management consulting, including
Page 22
advanced investment management theory and application. Prerequisites for the CIMA certification
are three years of financial services experience and an acceptable regulatory history. To obtain the
CIMA certification, candidates must pass an online Qualification Examination, successfully
complete a one-week classroom education program provided by a Registered Education Provider at
an AACSB accredited university business school, pass an online Certification Examination, and have
an acceptable regulatory history as evidenced by FINRA Form U-4 or other regulatory
requirements. CIMA designees are required to adhere to IWI’s Code of Professional Responsibility,
Standards of Practice, and Rules and Guidelines for Use of the Marks. CIMA designees must report 40 hours
of continuing education credits, including two ethics hours, every two years to maintain the
certification. The designation is administered through Investments & Wealth Institute (IWI).
The CIMA certification has earned ANSI® (American National Standards Institute) accreditation
under the personnel certification program. ANSI is a private non-profit organization that facilitates
standardization and conformity assessment activities in the United States. CIMA is the first financial
services credential to meet this international standard for personnel certification.
3The Certified Private Wealth Advisor® (CPWA®) designation signifies that an individual has met
initial and on-going experience, ethical, education, and examination requirements for the
professional designation, which is centered on management topics and strategies for high-net-worth
clients. Prerequisites for the CPWA designation are: a Bachelor’s degree from an accredited college
or university or one of the following designations or licenses: CIMA®, CIMC®, CFA®, CFP®, ChFC®
or CPA license; acceptable regulatory history as evidenced by FINRA Form U-4 or other regulatory
requirements; five years of professional client-centered experience in financial services or a related
industry; and two letters of reference from an IWI member, professional supervisor, or currently
licensed professional in financial services or a related industry. CPWA designees must complete a
six-month pre-class educational component and a five-day classroom education program through
The University of Chicago Booth School of Business. CPWA designees are required to adhere to
IWI’s Code of Professional Responsibility and Rules and Guidelines for Use of the Marks. CPWA
designees must report 40 hours of continuing education credits, including two ethics hours, every
two years to maintain the certification. The designation is administered through Investments &
Wealth Institute™.
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Anitha has no such disciplinary
information to report.
Item 4 - Other Business Activities
Anitha has no other business activities to report.
Item 5 - Additional Compensation
Anitha has no additional compensation to report.
Item 6 - Supervision
As majority owner of FA, David E. Hultstrom supervises all duties and activities of the firm, and is
responsible for all advice provided to clients. His contact information is on the cover page of this
Page 23
disclosure document. Kaitlyn Barnes, in her capacity as Chief Compliance Officer for FA, has
responsibility for monitoring the advice Anitha provides clients. She may be reached at 770-517-
8160 or Kaitlyn@FinancialArchitectsLLC.com.
Page 24
Brochure Supplement Form ADV Part 2B
Item 1 - Cover Page
Kaitlyn M. Barnes, CFP®, CSLP®, AIF®
CRD# 7484063 of Financial Architects, LLC
302 Creekstone Ridge
Woodstock, Georgia 30188
(770) 517-8160
www.FinancialArchitectsLLC.com
February 3rd, 2026
This brochure supplement provides information about Kaitlyn M. Barnes, and supplements the
Financial Architects, LLC (“FA”) brochure. You should have received a copy of that brochure.
Please contact FA at (770) 517-8160 if you did not receive FA’s brochure, or if you have any
questions about the contents of this supplement.
Additional information about Kaitlyn is available on the SEC’s website at www.AdviserInfo.sec.gov.
Item 2 - Educational Background and Business Experience
Kaitlyn M. Barnes (born 1994) has been employed by FA since June 2017, is a Financial Planner,
and has been Chief Compliance Officer since February 2023. She earned a Bachelor of Business
Administration degree from Kennesaw State University in 2019. Kaitlyn is also a CERTIFIED
FINANCIAL PLANNER™ professional1, a CSLP®2, and an AIF ®3.
1Certified Financial Planner Board of Standards, Inc. (“CFP Board”) owns the CFP® certification
mark, the CERTIFIED FINANCIAL PLANNER™ certification mark, and the CFP® certification
mark (with flame design) logo in the United States (these marks are collectively referred to as the
“CFP® marks”). The CFP Board authorizes use of the CFP® marks by individuals who successfully
complete the CFP Board’s initial and ongoing certification requirements.
The CFP® certification is a voluntary certification; no federal or state law or regulation requires
financial planners to hold CFP® certification. It is recognized in the United States and a number of
other countries for its (1) high standard of professional education; (2) stringent code of conduct and
standards of practice; and (3) ethical requirements that govern professional engagements with
clients. Currently, more than 92,000 individuals have obtained CFP® certification.
To attain the right to use the CFP® marks, an individual must currently satisfactorily fulfill the
following requirements:
• Education – Complete a college-level course of study addressing the financial planning
subject areas that CFP Board’s studies have determined as necessary for the competent and
professional delivery of financial planning services or an accepted equivalent, including
completion of a financial plan development capstone course, and attain a Bachelor’s Degree
from an accredited college or university. CFP Board’s financial planning subject areas
include professional conduct and regulation, general principles of financial planning,
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education planning, risk management and insurance planning, investment planning, income
tax planning, retirement savings and income planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The examination,
administered in 6 hours, includes case studies and client scenarios designed to test one’s
ability to correctly diagnose financial planning issues and apply one’s knowledge of financial
planning to real world circumstances;
• Experience – CFP Board requires 6,000 hours of experience through the Standard Pathway,
or 4,000 hours of experience through the Apprenticeship Pathway that meets additional
requirements; and
• Ethics – Agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct, which put
clients’ interest first; acknowledge CFP Board’s right to enforce them through its Disciplinary
Rules and Procedures; comply with the Financial Planning Practice Standards which determine what
clients should reasonably expect from the financial planning engagement and complete a
CFP® Certification Application which requires disclosure of an individual’s background,
including involvement in any criminal, civil, governmental, or self-regulatory agency
proceeding or inquiry, bankruptcy, customer complaint, filing, termination/internal reviews
conducted by the individual’s employer or firm.
Individuals who become certified must complete the following ongoing education and ethics
requirements in order to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours accepted by the
CFP Board every two years, including two hours on the Code of Ethics and other parts of the
Standards of Professional Conduct, to maintain competence and keep up with developments in
the financial planning field; and
• Ethics – CFP® professionals agree to adhere to the high standards of ethics and practice
outlined in CFP Board’s Code of Ethics and Standards of Conduct and to acknowledge CFP
Board’s right to enforce them through its Disciplinary Rules and Procedures. The Code of
Ethics and Standards of Conduct require that CFP® professionals provide financial planning
services in the best interests of their clients.
• Certification Application – Properly complete a Certification Application to (i) acknowledge
voluntary adherence to the terms and conditions of certification with CFP Board and (ii)
disclose any involvement in criminal and civil proceedings, inquiries or investigations,
bankruptcy filings, internal reviews and customer complaints.
CFP® professionals who fail to comply with the above standards and requirements may be subject to
CFP Board’s enforcement process, which could result in suspension or permanent revocation of
their CFP® certification.
You may verify an individual’s CFP® certification and background through the CFP Board. The
verification function will allow you to verify an individual’s certification status, CFP Board’s
disciplinary history and any bankruptcy disclosures in the past ten years. Additional regulatory
information may also be found through FINRA’s BrokerCheck and the SEC’s Investment Adviser
Public Disclosure databases, which are free tools that may be used to conduct research on the
background and experience of CFP® professionals and those who held CFP® certification at one
time, including with respect to employment history, regulatory actions, and investment-related
licensing information, arbitrations, and complaints.
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2The CSLP® designation is awarded by the Certified Student Loan Advisors Board of Standards and
is used by financial professionals who seek to provide information to clients about how to efficiently
repay student loans within the larger scope of their financial plans. Certification requires individuals
to have two years of industry experience in financial services or hold a bachelor’s degree in business
or finance from an accredited college or university. Individuals must also hold a license or
registration in a regulated financial services industry (brokerage, investment adviser services,
insurance). Unlicensed individuals providing coaching services may qualify for the certificate
program subject to the verification of business and individual qualifications. Designees are required
to complete an annual competency exam to ensure that they continue to demonstrate the knowledge
required to provide student loan repayment advice to clients).
3The Accredited Investment Fiduciary® (AIF®) Designation certifies that the recipient has
specialized knowledge of fiduciary standards of care and their application to the investment
management process. To receive the AIF Designation, the individual must meet prerequisite criteria
based on a combination of education, relevant industry experience, and/or ongoing professional
development, complete a training program, successfully pass a comprehensive, closed-book final
examination under the supervision of a proctor and agree to abide by the Code of Ethics and
Conduct Standards. In order to maintain the AIF Designation, the individual must annually attest to
the Code of Ethics and Conduct Standards, and accrue and report a minimum of six hours of
continuing education. The Designation is administered by the Center for Fiduciary Studies, the
standards-setting body of fi360.
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Kaitlyn has no such disciplinary
information to report.
Item 4 - Other Business Activities
Kaitlyn has no other business activities to report.
Item 5 - Additional Compensation
Kaitlyn has no additional compensation to report.
Item 6 - Supervision
As majority owner of FA, David E. Hultstrom supervises all duties and activities of the firm, and is
responsible for all advice provided to clients. He may be reached at 770-517-8160 or
David@FinancialArchitectsLLC.com.
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