Overview

Assets Under Management: $286 million
Headquarters: SPOKANE, WA
High-Net-Worth Clients: 77
Average Client Assets: $2.0 million

Frequently Asked Questions

FINANCIAL FORUM, INC. charges 1.25% on the first $0 million, 1.00% on the next $3 million, 0.85% on the next $5 million, 0.70% on all assets according to their SEC Form ADV filing. See complete fee breakdown ↓

Yes. As an SEC-registered investment advisor (CRD #307740), FINANCIAL FORUM, INC. is subject to fiduciary duty under federal law.

FINANCIAL FORUM, INC. is headquartered in SPOKANE, WA.

FINANCIAL FORUM, INC. serves 77 high-net-worth clients according to their SEC filing dated February 23, 2026. View client details ↓

According to their SEC Form ADV, FINANCIAL FORUM, INC. offers financial planning and portfolio management for individuals. View all service details ↓

FINANCIAL FORUM, INC. manages $286 million in client assets according to their SEC filing dated February 23, 2026.

According to their SEC Form ADV, FINANCIAL FORUM, INC. serves high-net-worth individuals. View client details ↓

Services Offered

Services: Financial Planning, Portfolio Management for Individuals

Fee Structure

Primary Fee Schedule (ADV PART 2A & 2B)

MinMaxMarginal 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 AssetsAnnual FeesAverage 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

Number of High-Net-Worth Clients: 77
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 53.75%
Average Client Assets: $2.0 million
Total Client Accounts: 1,696
Discretionary Accounts: 1,696
Minimum Account Size: None

Regulatory Filings

CRD Number: 307740
Filing ID: 2058677
Last Filing Date: 2026-02-23 18:22:48

Form ADV Documents

Primary Brochure: ADV PART 2A & 2B (2026-02-23)

View Document Text
501 N. Riverpoint Blvd. Suite 104 Spokane, WA 99202 February 23, 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 March 24, 2025, and updates our assets under management. 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 either Charles Schwab & Co., member FINRA/SIPC (“Schwab”) or TD Ameritrade Institutional, a division of TD Ameritrade Inc., member FINRA/SIPC (“TD Ameritrade”). Both Schwab and TD Ameritrade are unaffiliated SEC-registered broker-dealers and FINRA members. We work primarily with Schwab and TD Ameritrade 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. 7 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 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 February 23, 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 February 23, 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 February 23, 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

Additional Brochure: ADV PART 2A APPENDIX 1 (2026-02-23)

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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 February 23, 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. i Form ADV Part 2A – Appendix 1, Wrap Fee Program Brochure Item 2 – Material Changes This brochure has been updated from our March 24, 2025, 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 ii 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. 1 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: 2 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. 3 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