Overview
- Headquarters
- Spokane, WA
- Average Client Assets
- $2.0 million
- SEC CRD Number
- 307740
Fee Structure
Primary Fee Schedule (ADV PART 2A-2B)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 1.25% |
| $500,001 | $3,000,000 | 1.00% |
| $3,000,001 | $5,000,000 | 0.85% |
| $5,000,001 | and above | 0.70% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $11,250 | 1.12% |
| $5 million | $48,250 | 0.96% |
| $10 million | $83,250 | 0.83% |
| $50 million | $363,250 | 0.73% |
| $100 million | $713,250 | 0.71% |
Clients
- HNW Share of Firm Assets
- 53.75%
- Total Client Accounts
- 1,696
- Discretionary Accounts
- 1,696
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
Additional Brochure: ADV PART 2A APPENDIX 1 (2026-04-22)
View Document Text
Form ADV Part 2A – Appendix 1, Wrap Fee Program Brochure
Item 1 – Cover Page
FINANCIAL FORUM, INC.
501 N. Riverpoint Blvd.
Suite 104
Spokane, Washington 99202
509-458-5373
April 22, 2026
www.financialforum.io
This Wrap Fee Brochure provides information about the qualifications and business practices of Financial Forum,
Inc. If you have any questions about the contents of this Brochure, please contact us at 509-458-5373 or
info@financialforum.biz. The information in this Brochure has not been approved or verified by the United States
Securities and Exchange Commission (“SEC”) or by any state securities authority.
Additional information about Financial Forum, Inc. is available on the SEC’s website at www.adviserinfo.sec.gov. The
searchable IARD/CRD number for Financial Forum, Inc. is # 307740.
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Form ADV Part 2A – Appendix 1, Wrap Fee Program Brochure
Item 2 – Material Changes
This brochure has been updated from our last brochure dated February 23, 2026, although we have no material
changes to report.
We will ensure that all current clients receive a Summary of Material Changes to this and subsequent Brochures
within 120 days of the close of our business’ fiscal year. A Summary of Material Changes is also included with our
Brochure on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Financial Forum,
Inc. is # 307740. We may further provide other ongoing disclosure information about material changes as necessary
and will further provide you with a new Brochure as necessary based on changes or new information, at any time,
without charge.
Currently, our Brochure may be requested by contacting Jeff Comstock, Chief Compliance Officer of Financial Forum,
Inc. at 509-458-5373 or info@financialforum.biz. Our Brochure is provided free of charge.
Item 3 – Table of Contents
Page
Item 1 – Cover Page ........................................................................................................................................................ i
Item 2 – Material Changes ............................................................................................................................................. ii
Item 3 – Table of Contents ............................................................................................................................................ ii
Item 4 – Services, Fees and Compensation ................................................................................................................... 1
Item 5 – Account Requirements and Types of Clients ................................................................................................... 2
Item 6 – Portfolio Manager Selection and Evaluation ................................................................................................... 2
Item 7 – Client Information Provided to Portfolio Managers ........................................................................................ 5
Item 8 – Client Contact with Portfolio Managers .......................................................................................................... 5
Item 9 – Additional Information .................................................................................................................................... 5
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Form ADV Part 2A – Appendix 1, Wrap Fee Program Brochure
Item 4 – Services, Fees and Compensation
A
Financial Forum, Inc. (“Financial Forum” “we” or “us”) is a registered investment advisor located in Spokane,
Washington and registered with the SEC since March 2020. Financial Forum is owned by Jeff Comstock and
Landy Comstock.
Under this Wrap Fee Program, Financial Forum serves individuals and businesses in all areas of investment
management (which includes buying and selling of investments) and financial planning, including asset
management, investment consulting, education funding, risk management, tax management, retirement
planning, estate planning services, and employee and executive benefits. While we do not provide tax or
legal advice, we provide a full range of services coupled in coordination with other advisors such as
attorneys and Certified Public Accountants.
Under this Wrap Fee Program, Financial Forum charges Clients annual fees for investment advisory services
as follows:
Advisory Fee
Assets Managed
1.25%
on the first $500,000, plus
1.00%
on the next $2,500,000, plus
0.85%
on the next $2,000,000, plus
0.70%
on amounts over $5,000,000
Fees are generally not negotiable. For Clients in the Wrap Fee Program, the Advisory Fee noted on their
Advisory Agreement covers typical commissions charged by the custodian hold the Client accounts.
B
In determining whether to establish an account under our Wrap Fee Program, you should be aware that
the overall cost to you of the program may be higher or lower than you might incur by purchasing
separately, or unbundled, the types of securities available in the program. In order to compare the cost of
the program with unbundled services, you should consider the turnover rate in our investment strategies,
trading activity in the account and standard advisory fees and brokerage commissions that would be
charged at our custodian, or at other broker-dealers and investment advisors.
Depending upon the percentage wrap fee charged by our firm (as described more fully above), the amount
of portfolio activity in your account, and the value of custodial and other services provided, the wrap fee
may or may not exceed the aggregate cost of such services if they were to be provided separately and/or if
we were to negotiate transaction fees and seek best price and execution of transactions for your individual
account. In as much as the execution costs for transactions effected in your account will be paid by our firm,
a conflict of interest arises in that we may have a disincentive to trade securities in your account.
C
Clients that are enrolled in the Wrap Fee Program will still be required to pay certain fees including: (1) The
Client’s proportionate share of any internal mutual fund’s fees and charges; (2) The Client’s proportionate
share of internal fees and expenses of exchange-traded funds such as fees and expenses for investment
advisory services, administration, and other fund-level expenses; (3) Client charges imposed by the Client’s
current custodian (e.g., a transfer or termination fee) before the assets are transferred to Financial Forum;
(4) Client charges imposed by Financial Forum’s custodian (e.g., a transfer or termination fee) before the
assets are transferred from Financial Forum; (5) Client charges necessary to liquidate incoming positions
into our recommended portfolio.
D
Financial Forum and its investment advisor representatives receive compensation because of your
participation in the Wrap Fee Program. This compensation may be more than the amount Financial Forum
and its investment advisor representatives would receive if you paid separately for investment advice,
brokerage, and other services. Accordingly, a conflict of interest exists because Financial Forum and its
investment advisor representatives have a financial incentive to recommend the program.
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Form ADV Part 2A – Appendix 1, Wrap Fee Program Brochure
Item 5 – Account Requirements and Types of Clients
Financial Forum provides investment advice to individuals, high net worth individuals, businesses, and not for profit
organizations. Because each Client is unique, they must be willing to be involved in the planning and ongoing
processes. Such involvement does not have to be time consuming, however we want our Clients to remain informed
and have a sense of security about their investments. Financial Forum has no asset minimum.
Item 6 – Portfolio Manager Selection and Evaluation
A
Investment advisor representatives of Financial Forum may act as the portfolio manager under a Wrap Fee
Program account. In circumstances where Financial Forum recommends separate account managers, we
consider several factors including account size, risk tolerance, the opinion of each Client and the investment
philosophy of the selected registered investment advisor. The recommendation of the initial portfolio
manager and or the replacement of the portfolio manager will be based on a number of factors including
Client service, portfolio performance, customer satisfaction and other similar factors. The Chief Compliance
Officer or other firm manager may conduct periodic portfolio performance evaluations where the
performance of the portfolio being evaluated may be compared to other similarly managed accounts. Each
portfolio evaluated may be evaluated based on its particular circumstances. Therefore, the portfolio
performance evaluations of accounts may not be conducted on a uniform or consistent basis.
B
Investment advisor representatives of Financial Forum may act as the portfolio manager under a Wrap Fee
Program account. Financial Forum and its investment advisor representatives receive compensation as a
result of your participation in the program. This compensation may be more than the amount Financial
Forum and its investment advisor representatives would receive if you paid separately for investment
advice, brokerage, and other services. Accordingly, a conflict of interest exists because Financial Forum and
its investment advisor representatives have a financial incentive to recommend the program. Related
persons are subject to the same selection criteria as outside portfolio managers.
Advisory Business.
C
Information regarding types of advisory services offered, how advisory services are tailored to individual
needs of Clients, and differences between the wrap fee program and separately managed accounts can be
found in Item 4 above.
Performance-Based Fees and Side-By-Side Management.
Financial Forum does not charge any performance-based fees for its services and does not provide side-by-
side management.
Methods of Analysis, Investment Strategies and Risk of Loss.
Financial Forum’s investment philosophy is based on Modern Portfolio Theory, which refers to the process
of attempting to reduce risk in a portfolio through systematic diversification across asset classes, including
but not limited to common stocks, corporate bonds, government bonds, commodities, and real estate
investment trusts. We consider ourselves global investment managers and attempt to add additional
diversification by including non-U.S. investments to clients’ portfolios. We emphasize the analysis of mutual
funds, exchange-traded funds, and separately managed accounts (SMA’s) in our selection of the
investments that comprise our clients’ portfolios.
Representatives may use additional methods of analysis to manage the accounts of their clients. Following
are typical methods of analysis that representatives may use; however, clients should inquire of their
specific representative the particular method the representative intends to use in managing the client's
account:
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Form ADV Part 2A – Appendix 1, Wrap Fee Program Brochure
Fundamental Analysis
Fundamental analysis uses publicly available data in the evaluation of a security's value. Although most
analysts use fundamental analysis to value common stocks, this method of valuation can be used for just
about any type of security. For example, an investor can perform fundamental analysis on a bond's value
by looking at economic factors such as interest rates and the overall state of the economy. He can also look
at information about the bond issuer, such as potential changes in credit ratings.
For stocks and equity instruments, this method uses revenues, earnings, future growth, return on equity,
profit margins and other data to determine a company's underlying value and potential for future growth.
In terms of common stocks, fundamental analysis focuses on the financial statements of the company being
evaluated.
Fundamental analysts study anything that can affect a security’s value including macroeconomic factors
such as the overall economy and industry conditions, and microeconomic factors such as financial
conditions and company management. The end goal of fundamental analysis is to produce a quantitative
value that an investor can compare with a security's current price, thus indicating whether the security is
undervalued or overvalued.
Technical Analysis
Technical analysis is used to attempt to forecast the price movement of virtually any tradable instrument
that is generally subject to forces of supply and demand, including common stocks, bonds, futures and
currency pairs. In fact, technical analysis can be viewed as simply the study of supply and demand forces as
reflected in the market price movements of a security. It is most commonly applied to price changes, but
some analysts may additionally track numbers other than just price, such as trading volume or open interest
figures.
Over the years, numerous technical indicators have been developed by analysts in attempts to accurately
forecast future price movements. Some indicators are focused primarily on identifying the current market
trend, including support and resistance areas, while others are focused on determining the strength of a
trend and the likelihood of its continuation. Commonly used technical indicators include trend-lines and
multiple moving averages, such as the 50-day moving average and the 200-day moving average.
Economic (Cyclical) Analysis
Economic analysis takes into consideration economic cycles in order to predict how various sectors of the
market and a market index will perform. Stocks in consumer staples such as food and household products
may be appropriate in one cycle while in a period of recovery consumer discretionary stocks may become
more attractive. The expectation of rising or falling interest rates during economic cycles can also affect
risk premiums. This type of analysis is useful over longer periods of time for portfolio planning and
allocation but does not generally provide a basis for day-to-day investment management.
Mutual Fund and ETF Analysis
In analyzing mutual funds and ETFs, we heavily scrutinize the experience and track record of the portfolio
managers to determine if they have demonstrated the ability to invest successfully in varying economic
conditions. We continuously monitor the funds in an attempt to determine if they are deviating from their
stated investment strategies. We also evaluate the fees of each fund to ensure they are reasonable for the
asset class we are investing in. A risk of our mutual fund and ETF analysis is that, as in all investments, past
performance does not guarantee future results. A manager who has been successful in the past may not
be able to replicate that success in the future. In addition, managers of different mutual funds and ETF’s
may purchase the same security in a client’s portfolio, increasing the risk to the client if that security were
to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or
strategy of the fund, which could make the fund less suitable for the client's portfolio. We specifically rely
on Morningstar for our mutual fund and ETF analytical data.
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Form ADV Part 2A – Appendix 1, Wrap Fee Program Brochure
Investment Strategies & Risks
We reserve the right to employ several investment strategies in pursuit of the investment objectives for
client portfolios, including long-term investments (investments expected to be held for more than a year)
and short-term investments (investments expected to be held for less than a year). In general, clients
should expect that our strategies will emphasize long-term investments in common stocks, bonds, mutual
funds, and ETF’s. Portfolio composition and allocation at any given time will vary based on our assessment
of current market conditions and the relative risk and reward of investments.
Additional Risks
All investment programs have certain risks that are borne by the investor. Our investment approach
constantly keeps the risk of loss in mind. Investors face the following investment risks:
•
Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example,
when interest rates rise, yields on existing bonds become less attractive, causing their market values
to decline.
• Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and
intangible events and conditions. This type of risk is caused by external factors independent of a
security’s particular underlying circumstances. For example, political, economic, and social conditions
may trigger market events.
•
Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next
year, because purchasing power is eroding at the rate of inflation.
•
Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the
currency of the investment’s originating country. This is also referred to as exchange rate risk.
•
Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested
at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities.
•
Business Risk: These risks are associated with a particular industry or a particular company within an
industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy
process, before they can generate a profit. They carry a higher risk of profitability than an electric
company, which generates its income from a steady stream of customers who buy electricity no matter
what the economic environment is like.
•
Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are
more liquid if many traders are interested in a standardized product. For example, Treasury Bills are
highly liquid, while real estate properties are not.
•
Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability,
because the company must meet the terms of its obligations in good times and bad. During periods of
financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining
market value.
We use our best judgment and good faith efforts in rendering services to Client. We cannot warrant or
guarantee any particular level of account performance, or that an account will be profitable over time. Not
every investment recommendation we make will be profitable. Investing in securities involves risk of loss
that Clients should be prepared to bear. Clients assume all market risk involved in the investment of
account assets. Investments are subject to various market, currency, economic, political, and business risks.
Except as may otherwise be provided by law, we are not liable to Clients for: (1) any loss that Clients may
suffer by reason of any investment recommendation we made with that degree of care, skill, and diligence
under the circumstances that a prudent person acting in a fiduciary capacity would use; or (2) any
independent act or failure to act by a custodian of Client accounts.
4
Form ADV Part 2A – Appendix 1, Wrap Fee Program Brochure
It is the responsibility of the Client to give us complete information and to notify us of any changes in
financial circumstances or goals.
Voting Client Securities.
Without exception, Financial Forum does not vote proxies on behalf of Clients. Additionally, Financial Forum
will not provide advice to Clients on how the Client should vote.
Financial Forum does not have authority to vote Client securities unless authorized by the Client. Most
Clients will receive proxies and other solicitations directly from the custodian or transfer agent. If any proxy
materials are received on behalf of a Client, they will be sent directly to the Client or a designated
representative of the Client, who is responsible to vote the proxy.
Item 7 – Client Information Provided to Portfolio Managers
Once the Client selects an investment advisor representative and an advisory relationship is initiated, the investment
advisor representative will obtain information from the Client on the Client’s financial background, prior investment
experience, investment objectives, goals and restrictions, if any, and risk tolerance, among other things. This
information is shared with any separate account manager selected by the Client.
Item 8 – Client Contact with Portfolio Managers
Financial Forum does not place any restrictions on its Client’s ability to contact and consult with their portfolio
managers.
Item 9 – Additional Information
Disciplinary Information.
A
Financial Forum is required to disclose all material facts regarding any legal or disciplinary event that would
be material to your evaluation of our firm, or the integrity of our management. No such disclosable event
exists.
Other Financial Industry Activities and Affiliations.
Certain investment advisor representatives of Financial Forum are also licensed to sell insurance in one or
more states, either through a licensed general insurance agency or as direct agent representative of a
specific insurance company. Insurance related business is transacted with advisory Clients and individuals
may receive commissions from insurance products sold to Clients. Clients are advised that the fees paid to
Financial Forum for investment advisory services are separate and distinct from the commissions earned
by any individual for selling Clients other insurance products. If requested by a Client, we will disclose the
amount of commission expected to be paid.
The receipt of commissions by an individual associated with the firm presents a conflict of interest. As
fiduciaries we must act primarily for the benefit of investment advisory Clients. As such, we will only
transact insurance related business with Clients when fully disclosed, suitable, and appropriate. Further,
we must determine in good faith that any commissions paid to our representatives are appropriate. Clients
are informed that they are under no obligation to use any individual associated with Financial Forum for
insurance products or services. Clients may use any insurance firm or agent they choose.
Code of Ethics, Participation or interest in Client transactions and personal trading.
B
Financial Forum has a Code of Ethics which all employees are required to follow. The Code of Ethics outlines
our high standard of business conduct, and fiduciary duty to Clients. The Code of Ethics includes provisions
relating to the confidentiality of Client information, a prohibition on insider trading, a prohibition of rumor
mongering, restrictions on the acceptance of significant gifts, the reporting of certain gifts and business
entertainment items, and personal securities trading procedures, among other things.
5
Form ADV Part 2A – Appendix 1, Wrap Fee Program Brochure
Financial Forum or individuals associated with our firm may buy and sell some of the same securities for
their own account that Financial Forum buys and sells for its Clients. When appropriate, we will purchase
or sell securities for Clients before purchasing the same for our account or allowing representatives to
purchase or sell the same for their own account. In some cases, Financial Forum or representatives may
buy or sell securities for their own account for reasons not related to the strategies adopted for our Clients.
Our employees are required to follow the Code of Ethics when making trades for their own accounts in
securities which are recommended to and/or purchased for Clients. The Code of Ethics is designed to assure
that the personal securities transactions will not interfere with decisions made in the best interest of
advisory Clients while at the same time, allowing employees to invest their own accounts.
Financial Forum will disclose to advisory Clients any material conflict of interest relating to us, our
representatives, or any of our employees which could reasonably be expected to impair the rendering of
unbiased and objective advice.
As any advisory situation could present a conflict of interest, we have established the following restrictions
to ensure our fiduciary responsibilities:
1.
A director, officer, associated person, or employee of Financial Forum shall not buy or sell
securities for his personal portfolio where his decision is substantially derived, in whole or in part,
by reason of his employment unless the information is also available to the investing public on
reasonable inquiry. No person of Financial Forum shall prefer his or her own interest to that of
the advisory Client.
2.
Financial Forum maintains a list of all securities holdings for itself and for anyone associated with
its advisory practice that has access to advisory recommendations. An appropriate officer of
Financial Forum reviews these holdings on a regular basis.
3.
Any individual not in observance of the above may be subject to termination.
Review of Accounts.
Accounts are reviewed by the CCO who is responsible for overseeing all investment advisory activities for
the firm. The frequency of reviews is determined based on the Client’s investment objectives. Accounts
are generally reviewed quarterly, but in any event, no less than annually.
More frequent reviews may be triggered by a change in Client’s investment objectives; tax considerations;
large deposits or withdrawals; large sales or purchases; loss of confidence in corporate management; or,
changes in the economic climate.
Investment advisory Clients receive standard account statements from the custodian of their accounts on
a monthly basis. Financial Forum also provides Clients with a written report summarizing the account
activity generally quarterly, but in any event, no less than annually.
Client Referrals and Other Compensation.
Financial Forum has no arrangements, written or oral, in which we are compensated for referrals.
Financial Forum participates in the institutional advisor program (the “Program”) offered by TD Ameritrade
Institutional. TD Ameritrade Institutional is a division of TD Ameritrade Inc., member FINRA/SIPC (“TD
Ameritrade”), an unaffiliated SEC-registered broker-dealer and FINRA member. TD Ameritrade offers to
independent investment advisors services which include custody of securities, trade execution, clearance
and settlement of transactions. Financial Forum receives some benefits from TD Ameritrade through its
participation in the Program.
We also participate in TD Ameritrade’s institutional customer program and we may recommend TD
Ameritrade to Clients for custody and brokerage services. While there is no direct link between our
participation in the Program and the investment advice provided to Clients, we do receive economic
benefits through its participation in the Program that are typically not available to TD Ameritrade retail
investors. These benefits include the following products and services (provided without cost or at a
discount): receipt of duplicate Client statements and confirmations; research related products and tools;
6
Form ADV Part 2A – Appendix 1, Wrap Fee Program Brochure
consulting services; access to a trading desk serving our participants; access to block trading (which provides
the ability to aggregate securities transactions for execution and then allocate the appropriate shares to
Client accounts); the ability to have advisory fees deducted directly from Client accounts; access to an
electronic communications network for Client order entry and account information; access to mutual funds
with no transaction fees and to certain institutional money managers; and discounts on compliance,
marketing, research, technology, and practice management products or services provided to us by third
party vendors. TD Ameritrade may also have paid for business consulting and professional services received
by our related persons. Some of the products and services made available by TD Ameritrade through the
program may benefit us but may not benefit our Client accounts. These products or services may assist us
in managing and administering Client accounts, including accounts not maintained at TD Ameritrade. Other
services made available by TD Ameritrade are intended to help us manage and further develop our business
enterprise. The benefits received by Financial Forum or its personnel through participation in the program
do not depend on the amount of brokerage transactions directed to TD Ameritrade. As part of its fiduciary
duties to clients, Financial Forum endeavors at all times to put the interests of its clients first. Clients should
be aware, however, that the receipt of economic benefits by Financial Forum or its related persons in and
of itself creates a potential conflict of interest and may indirectly influence our choice of TD Ameritrade for
custody and brokerage services.
Financial Forum also receives from TD Ameritrade certain additional economic benefits (“Additional
Services”) that may or may not be offered to any other independent investment advisors participating in
the program. Specifically, the Additional Services include services provided by Black Diamond, which
provides client portfolio management software. TD Ameritrade provides the Additional Services to
Financial Forum in its sole discretion and at its own expense, and Financial Forum does not pay any fees to
TD Ameritrade for the Additional Services. Financial Forum and TD Ameritrade have entered into a separate
agreement (the “Additional Services Addendum”) to govern the terms of the provision of the Additional
Services.
Financial Forum’s receipt of Additional Services raises potential conflicts of interest. In providing Additional
Services to Financial Forum, TD Ameritrade most likely considers the amount and profitability to TD
Ameritrade of the assets in, and trades placed for, Financial Forum’s Client accounts maintained with TD
Ameritrade. TD Ameritrade has the right to terminate the Additional Services Addendum with Financial
Forum, in its sole discretion, provided certain conditions are met. Consequently, in order to continue to
obtain the Additional Services from TD Ameritrade, Financial Forum may have an incentive to recommend
to its Clients that the assets under management by Financial Forum be held in custody with TD Ameritrade
and to place transactions for Client accounts with TD Ameritrade. Financial Forum’s receipt of Additional
Services does not diminish its duty to act in the best interests of its Clients, including to seek best execution
of trades for Client accounts.
Financial Information.
Financial Forum does not require or solicit prepayment of more than $1,200 in fees per Client, six months
or more in advance. Financial Forum does have discretionary authority over Client funds or securities, but
we have no financial commitments that would impair our ability to meet contractual and fiduciary
commitments to Clients. Neither Financial Forum, nor any of the principals, have been the subject of a
bankruptcy petition at any time in the past.
7
Additional Brochure: ADV PART 2A-2B (2026-04-22)
View Document Text
501 N. Riverpoint Blvd.
Suite 104
Spokane, WA 99202
April 22, 2026
FIRM BROCHURE (ADV Part 2A-2B)
This brochure provides information about the qualifications and business practices of Financial Forum, Inc. For
any questions about the contents of this brochure, please contact us at 509-458-5373.
The information in this brochure has not been approved or verified by the United States Securities and Exchange
Commission (“SEC”) or by any state securities authority. Additional information about Financial Forum, Inc. is
also available on the SEC’s website at www.adviserinfo.sec.gov and our CRD number is 307740.
Financial Forum, Inc. is a registered investment advisor. Registration as an investment advisor does not imply
any certain level of skill or training.
Item 2 - Summary of Material Changes
This brochure has been updated from our Brochure dated February 23, 2026, and updates our Part 2B with the
addition of Callie Johnson. We have also removed TD Ameritrade as a custodian under Item 12.
In the future, this section will discuss specific material changes that are made to the Brochure and provide clients
with a summary of such changes. Following the SEC and state rules, we will ensure that clients receive a
summary of any materials changes to this and subsequent Brochures within 120 days of the close of the
Advisor’s fiscal year. We will provide other ongoing disclosure information about material changes as necessary.
Our Brochure may be requested by contacting Jeff Comstock, Chief Compliance Officer of Financial Forum, Inc.
at (509) 458-5373. Our Brochure is provided free of charge.
Item 3—Table of Contents
Page
Item 1
Cover Page………………………………………....……...……………………..………….….
1
Item 2
Summary of Material Changes………………….……………………………..………………
2
Item 3
Table of Contents…………………………………………..…….……………………………...
2
Item 4
Advisory Business………………………………………………………………………….....…
3
Item 5
Fees and Compensation……………………………………………………………………..…
3
Item 6
Performance-Based Fees and Side-by-Side Management………………………….……..
4
Item 7
Types of Clients………………………………………………………………………….………
4
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss…………….................……
4
Item 9
Disciplinary Information………...………………………………………...…………………..…
6
Item 10
Other Financial Industry Activities and Affiliations………………………………………..….
6
Item 11
Code of Ethics, Participation or Interest in Client Transactions, Personal Trading………
6
Item 12
Brokerage Practices……………………………………………………………………………..
6
Item 13
Review of Accounts…………………………………...……………………………….………..
7
Item 14
Client Referrals and Other Compensation………….…...……………………………………
7
Item 15
Custody…………...…………………………………………..…………………………..………
8
Item 16
Investment Discretion……………………………………...……………………………………
8
Item 17
Voting Client Securities………………………………………..………………………….…….
8
Item 18
Financial Information……………………………………………..……………………….…….
8
-
ADV Part 2B…………………………………………………………..…………………………. 9-14
2
Item 4– Advisory Business
Financial Forum, Inc. (“Financial Forum”) is a registered investment advisor located in Spokane, Washington
and registered with the SEC since March 2020. Financial Forum is owned by Jeff Comstock and Landy
Comstock.
Financial Forum serves individuals and businesses in all areas of investment management and financial
planning, including asset management, cash management, investment consulting, education funding, risk
management, tax management, retirement planning, estate planning services, and employee and executive
benefits. While we do not provide tax or legal advice, we provide a full range of services coupled in coordination
with other advisors such as attorneys and Certified Public Accountants.
Our clients may impose restrictions on investing in certain securities, industries, or sectors, but must advise us
of any such restrictions in writing. Financial Forum provides tailored advisory services to meet our clients’
particular needs. We work individually and with other advisers to build and enhance our clients’ wealth over the
long term. We ask you to complete an investor questionnaire or provide us an interview to assist us in
developing investment objectives that reflect your unique goals, needs, risk tolerance and time horizon. You may
have multiple accounts with us, and each may have different investment objectives. We offer to review your
financial situation with you at least annually to be sure the objectives continue to meet your needs and goals.
Clients can also provide us with access to accounts not at the custodian through the Pontera Order Management
System (“Pontera”). Through Pontera Financial Forum can access and trade a client’s 401(k), HSA, or other
brokerage accounts. When a client requests that we manage an account through Pontera it will be governed by
the Advisory Agreement (“Agreement”) signed by the client. Investments within Pontera are limited to the
choices available through the custodian holding these accounts.
Please review Item 8 for a description of our investment strategy. We provide some existing clients investment
management services through a Wrap Fee program, and more information on that is provided in the Wrap Fee
Brochure (Appendix 1). But in most cases, all new accounts will be opened in a non-Wrap Fee basis, meaning
any transaction charges for specific trades will be paid by the clients.
As of December 31, 2025, we managed $285,773,471 of client assets on a discretionary basis.
Item 5 - Fees and Compensation
Financial Forum, Inc. charges annual fees (“Advisory Fees”) for managing client portfolios. Our standard
Advisory Fee schedule is as follows:
Advisory Fee
Assets Managed
1.25%
$0 to $500,000
1.00%
$500,001 to $3,000,000
0.85%
$3,000,001 to $5,000,000
0.70%
on amounts over $5,000,000
Fees may be negotiable for existing clients may be on a different fee schedule, although in no case does any
client pay Advisory Fees more than 1.25% annually. Financial Forum has no asset minimum. Standalone
financial planning services are also available and billed at an hourly rate of $150 per hour.
We bill Advisory Fees monthly and in arrears. Fees are paid directly to us from the account by the custodian
upon our submission of an invoice or upload to the custodian. Payment of fees may result in the liquidation of
client’s securities if there is insufficient cash in the account. The fee is based on the average daily market value
of the client’s account for the preceding month.
Clients pay brokerage transaction costs and other charges directly to the custodian, unless enrolled in a wrap
fee program. See Item 12 – Brokerage Practices. Clients may be required to pay, in addition to Financial
Forum’s fee, a proportionate share of any exchange traded fund’s or mutual fund’s fees and charges. For
example, Mutual fund operating expenses are paid out of the fund and are in addition to our Advisory Fees or
any transaction fees charged by the custodian.
3
Fees for partial months at the commencement or termination of this Agreement will be billed based on the
average daily balance of the account during the billing period. Additionally, all agreements may be terminated
at any time.
If Financial Forum has provided the client a copy of its Form ADV Part 2 less than forty-eight hours prior to
entering any investment advisory contract or if Financial Forum provided the client a copy of its Form ADV Part
2 at the time of entering into the investment advisory agreement, then the client may terminate the investment
advisory agreement without penalty within five business days after entering into the contract. Alternatively, the
investment advisory agreement may be terminated at any time by either party by providing 15 days written notice
to the other party.
Certain investment advisor representatives of Financial Forum are also licensed to sell insurance in one or more
states, either through a licensed general insurance agency or as direct agent representative of a specific
insurance company. Insurance related business is transacted with advisory clients and individuals may receive
commissions from insurance products sold to clients. Clients are advised that Advisory Fees paid to Financial
Forum for investment advisory services are separate and distinct from the commissions earned by any individual
for selling clients other insurance products. If requested by a client, we will disclose the amount of commission
expected to be paid.
The receipt of commissions by an individual associated with the firm presents a conflict of interest. As fiduciaries
we must act primarily for the benefit of investment advisory clients. As such, we will only transact insurance
related business with clients when fully disclosed, suitable, and appropriate. Further, we must determine in
good faith that any commissions paid to our representatives are appropriate. Clients are informed that they are
under no obligation to use any individual associated with Financial Forum for insurance products or services.
Clients may use any insurance firm or agent they choose.
Item 6 - Performance-Based Fees and Side-By-Side Management
We do not charge fees that are based upon a share of capital gains or capital appreciation of Assets.
Item 7 - Types of Clients
We provide investment advice to individuals, high net worth individuals, businesses, and not for profit
organizations. Because each client is unique, they must be willing to be involved in the planning and ongoing
processes. Such involvement does not have to be time consuming, however we want our clients to remain
informed and have a sense of security about their investments. Financial Forum has no asset minimum.
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Our investment philosophy is based upon Modern Portfolio Theory (“MPT”). MPT states that assets should be
selected on the basis of how they interact with one another, rather than how they perform in isolation.
Additionally, we utilize numerous sources of information to provide advice, including but not limited to: financial
newspapers and magazines, websites, research materials and software prepared by third parties, annual
reports, prospectuses and filings with the SEC, company press reports, as well as our proprietary analysis of
data and information.
It is important to know that all methods of analysis include specific risks, including timing errors, inaccurate
information, economic impacts and other factors that can impact client investment performance.
Investment Strategies
We may utilize long term purchases (securities held at least a year) and short-term purchases (securities sold
within a year) when implementing investment advice. Short term purchases may increase costs and may also
increase the tax obligation of the portfolio. Investments may also be made on margin, which may increase the
costs due to the interest payments on the margin loan balance. Option strategies may also be implemented,
which carries the risk of expiration with no value, as well as called equity positions, which could create a risk of
taxation.
4
The types of securities include, but are not limited to the following: equities, fixed income (corporate debt,
municipal bonds, certificates of deposit, etc.), mutual funds, unit investment trusts, options, exchange traded
funds, U.S. Government issues securities, real estate investment trusts, limited partnerships, direct participation
programs, variable annuities, variable life insurance and fixed annuities. We only sell annuities and life insurance
policies where we are licensed and/or registered.
Risks
We use our best judgment and good faith efforts in rendering services to clients. We cannot warrant or
guarantee any particular level of account performance, or that an account will be profitable over time. Not every
investment recommendation we make will be profitable. Investing in securities involves risk of loss that clients
should be prepared to bear. Clients assume all market risk involved in the investment of account assets.
Investments are subject to various market, currency, economic, political, and business risks. Risks to consider
include, but are not limited to the following:
Financial Planning: Risks associated with the financial planning process include the possibility that the
investment performance, interest rates, inflation assumptions, and longevity assumptions used in the
development of client’s financial plan turn out to be materially different than the actual future investment
performance, interest rate, inflation and life span. Differences between the assumptions used in the plan and
actual events can materially affect the results of the financial plan over long periods of time. While we base our
assumptions on historical information, clients must acknowledge that past performance or events might not be
indicative of the future returns.
Investing: Investing is not without risk and involves the risk of loss of principal which clients should be prepared
to bear. We use several strategies to try to reduce risk, including diversifying a portfolio across multiple asset
classes. Despite these strategies, every asset class has experienced severe declines in value, sometimes over
many years.
Asset Class Risk: Securities in client portfolios or in underlying investments such as mutual funds may
underperform in comparison to the general securities markets or other asset classes.
Issuer Risk: Client account performance depends on the performance of individual securities selected in client
accounts. Any issuer may perform poorly or be unable to continue operations, causing the value of its securities
to decline or default.
Management Risk: The performance of client accounts is subject to the risk that our investment management
strategy may not produce the intended results.
Market Risk: Client accounts can lose money over short periods due to short-term market movements and over
longer periods during market downturns. The value of a security may decline due to general market conditions,
economic trends, or events that are not specifically related to the issuer of the security or to factors that affect a
particular industry or industries.
Passive Investment Risk: We may use a passive investment strategy that is not actively managed where we
do not attempt to take defensive positions in declining markets.
Liquidity Risk: A security may not be able to be sold at the time desired which can impact performance.
Interest Rate Risk: An increase in interest rates may cause the value of fixed income securities and funds that
hold these securities to decline in value. Securities with longer durations tend to be more sensitive to interest
rate changes, usually making them more volatile than securities with shorter durations.
Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year,
because purchasing power is eroding at the rate of inflation.
Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency
of the investment’s originating country. This is also referred to as exchange rate risk.
Reinvestment Risk: This is a risk that future proceeds from fixed income investments may have to be reinvested
at a potentially lower rate of return (i.e. interest rate).
Business Risk: These risks are associated with a particular industry or a particular company within an industry.
Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because
the company must meet the terms of its obligations in good times and bad.
5
Except as may otherwise be provided by law, we are not liable to clients for (1) any loss that clients may suffer
by reason of any investment recommendation we made with that degree of care, skill, and diligence under the
circumstances that a prudent person acting in a fiduciary capacity would use; or (2) any independent act or
failure to act by a custodian of client accounts. It is the responsibility of the client to give us complete
information and to notify us of any changes in financial circumstances or goals.
Item 9 - Disciplinary Information
Financial Forum is required to disclose all material facts regarding any legal or disciplinary event that would be
material to your evaluation of our firm, or the integrity of our management. No such disclosable event exists.
Item 10 - Other Financial Industry Activities and Affiliations
As disclosed in Item 5 above, certain investment advisor representatives of Financial Forum are also licensed
as insurance agents in one or more states, either through a licensed general insurance agency or as direct agent
representative of a specific insurance company. The conflicts of interest associated with the above
arrangements and how these conflicts are addressed are described in Item 5, above.
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
We have implemented policies and procedures to govern our employees and to mitigate the conflicts of interest
we encounter when providing our advisory services to clients. These include:
• A Code of Ethics that each employee is required to review and sign an acknowledgement of receipt and
understanding (upon hire, and annually);
• Prohibitions on the misuse of material non-public information.
• Personal securities trading policies and procedures (governing not only our employee but also the
members of their household and any other securities or brokerage accounts where they have beneficial
ownership of with a spouse, family member or other person). Employees are not allowed to:
“Front-run” or trade in anticipation of client transactions.
o Trade on inside information.
o
o Trade or participate in any activity prohibited under the federal securities laws.
o Place their interests in front of client’s interests.
We strive to achieve the highest ethical and fiduciary standards (in dealing with clients, the public, vendors,
prospective clients and each other). As a fiduciary, we have an affirmative duty to act with integrity, competence
and care; this includes disclosing all potential and actual conflicts of interest.
It may be possible for our employees to buy or sell securities in their personal accounts that were also purchased
in client accounts. We have a strict policy against using the trade flow of clients to economically benefit our
employees or Financial Forum. We monitor the transactions of employee accounts to protect clients from
violation of our Code of Ethics.
We perform services for various other clients. We may give advice or take actions for our clients that differ from
the advice given to other clients. The timing or nature of any action taken for all clients or other sponsors may
also vary. For more information or to request a copy of our Code of Ethics, please contact us at 509-458-5373.
Item 12 - Brokerage Practices
Our client assets are held by independent third-party custodians. Except to the extent that the client directs
otherwise, Financial Forum may use its discretion in selecting or recommending the broker-dealer. The client
is not obligated to effect transactions through any broker-dealer recommended by Financial Forum. In
recommending broker-dealers, Financial Forum will comply with its fiduciary duty to seek best execution and
with the Securities Exchange Act of 1934 and will take into account such relevant factors as: (1) price; (2) the
custodian’s facilities, reliability and financial responsibility; (3) the ability of the custodian to effect transactions,
particularly with regard to such aspects as timing, order size and execution of order; and (4) any other factors
that we consider to be relevant.
6
We typically recommend that clients establish brokerage accounts with Charles Schwab & Co., member
FINRA/SIPC (“Schwab”) Schwab is an unaffiliated SEC-registered broker-dealer and FINRA member. We work
primarily with Schwab for administrative convenience and because they offer good values to our clients for the
transaction costs and other costs incurred.
Financial Forum may aggregate trades for clients. The allocations of a particular security will be determined by
Financial Forum before the trade is placed with the broker. When practical, client trades in the same security will
be bunched in a single order (“block”) to obtain best execution at the best security price available. When
employing a block trade: (1) Financial Forum will make reasonable efforts to attempt to fill client orders by day-
end. (2) If the block order is not filled by day-end, Financial Forum will allocate shares executed to underlying
accounts on a pro rata basis, adjusted as necessary to keep client transaction costs to a minimum. (3) If a block
order is filled (full or partial fill) at several prices through multiple trades, an average price and commission will
be used for all trades executed. (4) All participants receiving securities from the block trade will receive the
average price. (5) Only trades executed within the block on the single day may be combined for purposes of
calculating the average price.
It is expected that this trade aggregation and allocation policy will be applied consistently. However, if application
of this policy results in unfair or inequitable treatment to some or all our clients, we may deviate from this policy.
Item 13 - Review of Accounts
Accounts are reviewed by Jeff Comstock, or his assignee. The frequency of reviews is determined based on
the client’s investment objectives. Accounts are generally reviewed quarterly, but in any event, no less than
annually.
More frequent reviews may be triggered by a change in client’s investment objectives; tax considerations; large
deposits or withdrawals; large sales or purchases; loss of confidence in corporate management; or, changes in
the economic climate.
Investment advisory clients receive standard account statements from the custodian of their accounts typically
on a monthly basis. Financial Forum may also provide clients with a written report summarizing their accounts.
There may be a difference between the report provided by Financial Forum and the statement from the Custodian
based on settlement versus trade date accounting, dividends or accrued interest. It is important that clients rely
on the value as provided by the Custodian for the actual value of their accounts.
Item 14 - Client Referrals and Other Compensation
Financial Forum neither compensates, nor receives compensation from, any third parties in connection with
client referrals.
As disclosed under Item 12 above, we may recommend TD Ameritrade or Schwab (collectively referred to as
“Custodians”) to clients for custody and brokerage services. The Custodians provide us economic benefits that
may or may not be available for retail clients. These benefits include the following products and services
(provided without cost or at a discount): receipt of duplicate client statements and confirmations; research related
products and tools; consulting services; access to a trading desk serving our participants; access to block trading
(which provides the ability to aggregate securities transactions for execution and then allocate the appropriate
shares to client accounts); the ability to have advisory fees deducted directly from client accounts; access to an
electronic communications network for client order entry and account information; access to mutual funds with
no transaction fees and to certain institutional money managers; and discounts on compliance, marketing,
research, technology, and practice management products or services provided to us by third party vendors. The
Custodians may pay for business consulting and professional services received by our related persons. Some
of the products and services made available by the Custodians may benefit us but may not benefit our client
accounts. These products or services may assist us in managing and administering client accounts, including
accounts not maintained at the Custodians. Other services made available by the Custodians are intended to
help us manage and further develop our business enterprise. The benefits received by Financial Forum do not
depend on the amount of brokerage transactions directed to the Custodians.
As part of its fiduciary duties to clients, Financial Forum endeavors at all times to put the interests of its clients
7
first. Clients should be aware, however, that the receipt of economic benefits by Financial Forum or its related
persons in and of itself creates a potential conflict of interest and may indirectly influence our choice of the
Custodians for custody and brokerage services.
Financial Forum also receives from TD Ameritrade certain additional economic benefits (“Additional Services”)
that may or may not be offered to any other independent investment advisors. Specifically, the Additional
Services include services provided by Black Diamond, which provides client portfolio management software.
TD Ameritrade provides the Additional Services to Financial Forum in its sole discretion and at its own expense,
and Financial Forum does not pay any fees to TD Ameritrade for the Additional Services. Financial Forum and
TD Ameritrade have entered into a separate agreement (the “Additional Services Addendum”) to govern the
terms of the provision of the Additional Services.
Financial Forum’s receipt of Additional Services raises potential conflicts of interest. In providing Additional
Services to Financial Forum, TD Ameritrade most likely considers the amount and profitability to TD Ameritrade
of the assets in, and trades placed for, Financial Forum’s client accounts maintained with TD Ameritrade. TD
Ameritrade has the right to terminate the Additional Services Addendum with Financial Forum, in its sole
discretion, provided certain conditions are met. Consequently, to continue to obtain the Additional Services from
TD Ameritrade, Financial Forum may have an incentive to recommend to its clients that the assets under
management by Financial Forum be held in custody with TD Ameritrade and to place transactions for client
accounts with TD Ameritrade. Financial Forum’s receipt of Additional Services does not diminish its duty to act
in the best interests of its clients, including to seek best execution of trades for client accounts.
Item 15 - Custody
As noted in the Advisory Agreement signed by the client, we have the ability to deduct our advisory fee directly
from client accounts. Additionally, we are reporting custody on certain accounts where the client has requested
the ability to electronically transfer assets to a third-party through a standing limited power of attorney (known as
a SLOA). Although, we do not have any relationship, affiliation or share an address with any of the third parties,
we are following SEC guidelines to report having custody of these assets. Other than these situations, we do
not have custody of any client Assets.
Item 16 - Investment Discretion
Clients grant us discretion through a limited power of attorney to select, purchase, or sell securities without
obtaining client specific consent within client accounts. Our Advisory Agreement will provide us discretion
authority to trade accounts.
Item 17 - Voting Client Securities
We will not vote proxies for securities held in client accounts.
Item 18 - Financial Information
We are not aware of any circumstance that is reasonably likely to impair our ability to meet contractual
commitments to clients. We do not require pre-payment of Advisory Fees in excess of $1,200 and more than six
months in advance.
8
501 N. Riverpoint Blvd.
Suite 104
Spokane, WA 99202
April 22, 2026
FIRM BROCHURE SUPPLEMENT (ADV Part 2B)
Jeffrey L. Comstock
This Brochure supplement provides information about Jeffrey L. Comstock (CRD #4538817) that supplements the
Brochure from Financial Forum, Inc. Client should have received a copy of that Brochure. Please contact us at
509-458-5373 to receive the Advisor’s Brochure or for any questions about the contents of this supplement.
Additional information is available on the SEC’s website at www.adviserinfo.sec.gov.
9
Item 2 - Educational Background and Business Experience
Jeffrey L. Comstock, born 1977, has been in the financial services industry since 2011. He graduated with a
Bachelor’s degree from Eastern Washington University in 2003. From 2011 through 2020, he was an
Investment Advisor Representative and Registered Representative with LPL Financial, LLC. In May of 2020, he
started Financial Forum, Inc., where he is owner and an Investment Advisor Representative.
Item 3 - Disciplinary Information
Jeff Comstock is required to disclose all material facts regarding any legal or disciplinary event that would be
material to your evaluation of Financial Forum Inc., or the integrity of our management. There are no material
facts to disclose for Jeff Comstock.
Item 4 - Other Business Activities
Jeff Comstock is licensed to sell insurance in one or more states. Jeff Comstock may receive commissions
from insurance products sold to Financial Forum Inc.’s advisory clients. The receipt of commissions presents
a conflict of interest. As fiduciaries, representatives of Financial Forum, Inc. must act primarily for the benefit of
investment advisory clients. As such, Jeff Comstock will only transact insurance-related business with clients
when fully disclosed, suitable, and appropriate. Clients are under no obligation to purchase insurance products
or services through Jeff Comstock. Clients may use any insurance firm or agent they choose.
Item 5 - Additional Compensation
Jeff Comstock does not receive any additional compensation (or other economic benefit) for providing investment
advisory services.
Item 6 - Supervision
Jeff Comstock is the Chief Compliance Officer of Financial Forum Inc. and supervises the firm in the areas of
client services and advice, investment policies, forms and procedures, day to day operations, general
management of the firm and compliance related matters.
10
501 N. Riverpoint Blvd.
Suite 104
Spokane, WA 99202
April 22, 2026
FIRM BROCHURE SUPPLEMENT (ADV Part 2B)
Kathryn M. Young
.
This Brochure supplement provides information about Kathryn M. Young (CRD #5027604) that supplements the
Brochure from Financial Forum, Inc. Client should have received a copy of that Brochure. Please contact us at
509-458-5373 to receive the Advisor’s Brochure or for any questions about the contents of this supplement.
Additional information is available on the SEC’s website at www.adviserinfo.sec.gov.
11
Item 2 - Educational Background and Business Experience
Kathryn M. Young, born 1980, attended Whitworth University and obtained a Bachelor of Arts in Speech
Communication in 2002. She joined Financial Forum in 2005 as an Administrative Associate. In November
2020 she became an Investment Advisor Representative.
Item 3 - Disciplinary Information
Kathryn Young is required to disclose all material facts regarding any legal or disciplinary event that would be
material to your evaluation of Financial Forum Inc., or the integrity of our management. There are no material
facts to disclose for Kathryn Young.
Item 4 - Other Business Activities
Kathryn Young has no other business activities to disclose.
Item 5 - Additional Compensation
Kathryn Young does not receive any additional compensation (or other economic benefit) for providing
investment advisory services.
Item 6 - Supervision
Jeff Comstock is the Chief Compliance Officer of Financial Forum Inc. and supervises the firm in the areas of
client services and advice, investment policies, forms and procedures, day to day operations, general
management of the firm and compliance related matters.
12
501 N. Riverpoint Blvd.
Suite 104
Spokane, WA 99202
April 22, 2026
FIRM BROCHURE SUPPLEMENT (ADV Part 2B)
Landy L. Comstock
.
This Brochure supplement provides information about Landy L. Comstock (CRD #3268899) that supplements the
Brochure from Financial Forum, Inc. Client should have received a copy of that Brochure. Please contact us at
509-458-5373 to receive the Advisor’s Brochure or for any questions about the contents of this supplement.
Additional information is available on the SEC’s website at www.adviserinfo.sec.gov.
13
Item 2 - Educational Background and Business Experience
Landy L. Comstock, born 1949, has been in the financial services industry since 1999. He graduated with a
Bachelor of Science degree in Business from the University of Idaho in 1971. He was with Edward Jones from
1999 through 2003. From 2003 thought 2020 he was an Investment Advisor Representative and Registered
Representative with LPL Financial, LLC. In May of 2020 he started Financial Forum, Inc., where he is owner and
an Investment Advisor Representative.
Item 3 - Disciplinary Information
Landy Comstock is required to disclose all material facts regarding any legal or disciplinary event that would be
material to your evaluation of Financial Forum Inc., or the integrity of our management. There are no material
facts to disclose for Landy Comstock.
Item 4 - Other Business Activities
Landy Comstock is licensed to sell insurance in one or more states. Landy Comstock may receive commissions
from insurance products sold to Financial Forum Inc.’s advisory clients. The receipt of commissions presents
a conflict of interest. As fiduciaries, representatives of Financial Forum, Inc. must act primarily for the benefit of
investment advisory clients. As such, Landy Comstock will only transact insurance-related business with clients
when fully disclosed, suitable, and appropriate. Clients are under no obligation to purchase insurance products
or services through Landy Comstock. Clients may use any insurance firm or agent they choose.
Item 5 - Additional Compensation
Landy Comstock does not receive any additional compensation (or other economic benefit) for providing
investment advisory services.
Item 6 - Supervision
Jeff Comstock is the Chief Compliance Officer of Financial Forum Inc. and supervises the firm in the areas of
client services and advice, investment policies, forms and procedures, day to day operations, general
management of the firm and compliance related matters.
14
501 N. Riverpoint Blvd.
Suite 104
Spokane, WA 99202
April 22, 2026
FIRM BROCHURE SUPPLEMENT (ADV Part 2B)
Callie C. Johnson
.
This Brochure supplement provides information about Callie C. Johnson (CRD #8067991) that supplements the
Brochure from Financial Forum, Inc. Client should have received a copy of that Brochure. Please contact us at
509-458-5373 to receive the Advisor’s Brochure or for any questions about the contents of this supplement.
Additional information is available on the SEC’s website at www.adviserinfo.sec.gov.
15
Item 2 - Educational Background and Business Experience
Callie C. Johnson was born in 1993. She graduated in 2015 from Gonzaga University with a BA in Business with
an emphasis on Entrepreneurship and Marketing. From 2016-2025, she worked for various bakeries and coffee
companies in the Spokane area. From 2025 to 2026, she was a client service associate and registered
representative with LPL Financial, LLC. In April of 2026, she started at Financial Forum, Inc., where she is now
a wealth management associate.
Item 3 - Disciplinary Information
Callie Johnson is required to disclose all material facts regarding any legal or disciplinary event that would be
material to your evaluation of Financial Forum Inc., or the integrity of our management. There are no material
facts to disclose for Callie Johnon.
Item 4 - Other Business Activities
Callie receives monthly income from the sale of her business, Made with Love Bakery. She is also a board
member for Gonzaga’s School of Business. Outside of these activities, there are no other outside business
activities to report for Ms. Johnson.
Item 5 - Additional Compensation
Callie Johnon does not receive any additional compensation (or other economic benefit) for providing investment
advisory services.
Item 6 - Supervision
Jeff Comstock is the Chief Compliance Officer of Financial Forum Inc. and supervises the firm in the areas of
client services and advice, investment policies, forms and procedures, day to day operations, general
management of the firm and compliance related matters.
16