Overview

Assets Under Management: $155 million
Headquarters: LITTLE ROCK, AR
High-Net-Worth Clients: 350
Average Client Assets: $0.4 million

Frequently Asked Questions

FINANCIAL LEGACY MANAGEMENT, NC. is a fee-based investment advisor. Detailed fee schedules are available in their SEC Form ADV filing.

Yes. As an SEC-registered investment advisor (CRD #136348), FINANCIAL LEGACY MANAGEMENT, NC. is subject to fiduciary duty under federal law.

FINANCIAL LEGACY MANAGEMENT, NC. is headquartered in LITTLE ROCK, AR.

FINANCIAL LEGACY MANAGEMENT, NC. serves 350 high-net-worth clients according to their SEC filing dated April 07, 2026. View client details ↓

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

FINANCIAL LEGACY MANAGEMENT, NC. manages $155 million in client assets according to their SEC filing dated April 07, 2026.

According to their SEC Form ADV, FINANCIAL LEGACY MANAGEMENT, NC. serves high-net-worth individuals. View client details ↓

Services Offered

Services: Financial Planning, Portfolio Management for Individuals

Clients

Number of High-Net-Worth Clients: 350
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 100.00%
Average Client Assets: $0.4 million
Total Client Accounts: 715
Discretionary Accounts: 715

Regulatory Filings

CRD Number: 136348
Filing ID: 2092446
Last Filing Date: 2026-04-07 14:25:03

Form ADV Documents

Primary Brochure: FLM 2026 (2026-03-30)

View Document Text
13 Office Park Drive Little Rock, AR. 72211 Office: (501)224-PLAN Cell: (501)514-5531 Fax: (501)423-6470 John@financiallegacymanagement.com This brochure provides information about the qualifications and business practices of Financial Legacy Management, Inc. If you have any questions about the contents of this brochure, please contact us at: 501- 224-7526, or by email at: John@Financiallegacymanagement.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Inc is Additional information about Financial Legacy Management, available on the SEC’s website at www.adviserinfo.sec.gov DECEMBER 31, 2025 Financial Legacy Management, Inc. Material Changes Annual Up Date The Material Changes section of this brochure will be updated annually when material changes occur since the previous release of the Firm Brochure. Material Changes since the Last Update The U.S. Securities and Exchange Commission issued a final rule in July 2010 requiring advisers to provide a Firm Brochure in narrative “plain English” format. The new final rule specifies mandatory sections and organization. Full Brochure Available Whenever you would like to receive a complete copy of our Firm Brochure, please contact us by telephone at: 501-224-7526 or by email at: John@financiallegacymanagement.com. i Financial Legacy Management, Inc. Table of Contents Material Changes............................................................................................................ i Annual Up Date........................................................................................................... i Material Changes since the Last Update .................................................................... i Full Brochure Available ............................................................................................... i Advisory Business ........................................................................................................ 1 Firm Description ......................................................................................................... 1 Principal Owners ........................................................................................................ 2 Types of Advisory Services ........................................................................................ 2 Tailored Relationships ............................................................................................... 2 Types of Agreements ................................................................................................. 2 Financial Planning Agreement ................................................................................... 2 Advisory Service Agreement ...................................................................................... 3 Retainer Agreement ................................................................................................... 4 Investment Management Agreement ......................................................................... 4 Hourly Planning Engagements .................................................................................. 4 Asset Management .................................................................................................... 4 Fees and Compensation ............................................................................................... 5 Description ................................................................................................................. 5 Fee Billing .................................................................................................................. 5 Other Fees ................................................................................................................. 5 Expense Ratios .......................................................................................................... 6 Past Due Accounts and Termination of Agreement ................................................... 6 Performance-Based Fees ............................................................................................. 6 Sharing of Capital Gains ............................................................................................ 6 Types of Clients............................................................................................................. 7 Description ................................................................................................................. 7 Account Minimums ..................................................................................................... 7 Methods of Analysis, Investment Strategies and Risk of Loss ................................. 7 Methods of Analysis ................................................................................................... 7 Investment Strategies ................................................................................................ 8 Risk of Loss ............................................................................................................... 8 TOC 1 Financial Legacy Management, Inc. Disciplinary Information ............................................................................................... 9 Legal and Disciplinary ................................................................................................ 9 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................................................................................................................... 9 Code of Ethics............................................................................................................ 9 Participation or Interest in Client Transactions ........................................................... 9 Personal Trading........................................................................................................ 9 Brokerage Practices .................................................................................................... 10 Selecting Brokerage Firms ....................................................................................... 10 Best Execution ......................................................................................................... 10 Soft Dollars .............................................................................................................. 10 Order Aggregation ................................................................................................... 10 Review of Accounts .................................................................................................... 10 Periodic Reviews ..................................................................................................... 10 Review Triggers ....................................................................................................... 10 Regular Reports ....................................................................................................... 11 Client Referrals and Other Compensation ................................................................ 11 Incoming Referrals ................................................................................................... 11 Referrals Out ........................................................................................................... 11 Custody ........................................................................................................................ 11 Account Statements ................................................................................................. 11 Performance Reports ............................................................................................... 11 Net Worth Statements .............................................................................................. 11 Investment Discretion ................................................................................................. 12 Discretionary Authority for Trading ........................................................................... 12 Limited Power of Attorney ........................................................................................ 12 Voting Client Securities .............................................................................................. 12 Proxy Votes ............................................................................................................. 12 Financial Information .................................................................................................. 12 Financial Condition .................................................................................................. 12 Business Continuity Plan ........................................................................................... 13 General .................................................................................................................... 13 TOC 2 Financial Legacy Management, Inc. Disasters .................................................................................................................. 13 Alternate Offices ...................................................................................................... 13 Loss of Key Personnel ............................................................................................. 13 Information Security Program .................................................................................... 13 Information Security ................................................................................................. 13 Privacy Notice .......................................................................................................... 13 Education and Business Standards ......................................................................... 15 Professional Certifications ....................................................................................... 15 John W. Kelley, CFP® - Born 1972.......................................................................... 16 Alvin Rogers II, CFP® - Born 1970 .......................................................................... 16 TOC 3 Financial Legacy Management, Inc. Advisory Business Firm Description Financial Legacy Management, Inc. was founded in 2005. Financial Legacy Management, Inc. provides personalized confidential financial planning and investment management to individuals, pension and profit sharing plans, trusts, estates, charitable organizations and small businesses. Advice is provided through consultation with the client and may include: determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning. Financial Legacy Management, Inc. is strictly a fee-only financial planning and investment management firm. The firm does not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products. The firm is not affiliated with entities that sell financial products or securities. No commissions in any form are accepted. No finder’s fees are accepted. Investment advice is an integral part of financial planning. In addition, Financial Legacy Management, Inc. advises clients regarding cash flow, college planning, retirement planning, tax planning and estate planning. Investment advice is provided, with the client making the final decision on investment selection. Financial Legacy Management, Inc. does not act as a custodian of client assets. The client always maintains asset control. Financial Legacy Management, Inc. places trades for clients under a limited power of attorney. A written evaluation of each client's initial situation is provided to the client, often in the form of a net worth statement. Periodic reviews are also communicated to provide reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. Conflicts of interest will be disclosed to the client in the unlikely event they should occur. The initial meeting is free of charge and is considered an exploratory interview to determine the extent to which financial planning and investment management may be beneficial to the client. - 1 - Financial Legacy Management, Inc. Principal Owners John W. Kelley is a 50% stockholder. Alvin Rogers is a 50% stockholder. Types of Advisory Services Financial Legacy Management, Inc. provides investment supervisory services, also known as asset management services. On more than an occasional basis, Financial Legacy Management, Inc. furnishes advice to clients on matters not involving securities, such as financial planning matters, taxation issues, and trust services that often include estate planning. As of December 31, 2025, Financial Legacy Management, Inc. manages approximately $155,000,000 in assets for approximately 350 clients. All Assets are managed on a discretionary basis. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system. Investment policy statements are created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without client consent. Types of Agreements The following agreements define the typical client relationships. At the time of entering into any such agreements the advisory client has a right to terminate the agreement without penalty within five business days after entering into the agreement. Financial Planning Agreement A financial plan is designed to help the client with all aspects of financial planning without ongoing investment management after the financial plan is completed. The financial plan may include, but is not limited to: a net worth statement; a cash flow statement; a review of investment accounts, including reviewing asset allocation and providing repositioning recommendations; strategic tax planning; a review of retirement accounts and plans including recommendations; a review of insurance policies and recommendations for changes, if necessary; one or more retirement scenarios; estate planning review and recommendations; and education planning with funding recommendations. - 2 - Financial Legacy Management, Inc. Detailed investment advice and specific recommendations are provided as part of a financial plan. Implementation of the recommendations is at the discretion of the client. The fee for a financial plan is predicated upon the facts known at the start of the engagement. The fee is determined based on complexity of planning issues and is Not Negotiable. Since financial planning is a discovery process, situations occur wherein the client is unaware of certain financial exposures or predicaments. The following fee schedule is utilized for financial planning analyses, consultations, and advice: $1000 Base Plan $1250 Base Plan plus Stock Option Evaluation $1500 Base Plan plus Complex Estate Planning Issues $1750 Base Plan plus Complex Tax Planning Issues $2000 Base Plan plus Unusual Trust Issues In the event that the client’s situation is substantially different than disclosed at the initial meeting, a revised fee will be provided for mutual agreement. The client must approve the change of scope in advance of the additional work being performed when a fee increase is necessary. After delivery of a financial plan, future face-to-face meetings may be scheduled as necessary. Advisory Service Agreement Most clients choose to have Financial Legacy Management, Inc. manage their assets in order to obtain ongoing in-depth advice and life planning. All aspects of the client’s financial affairs are reviewed, including those of their children. Realistic and measurable goals are set and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. An Advisory Service Agreement includes: cash flow management; insurance review; investment management (including performance reporting); education planning; retirement planning; estate planning; and tax preparation, as well as the implementation of recommendations within each area. The annual Advisory Service Agreement fee is based on a percentage of the investable assets according to the following schedule: 1.00% on the first $1,000,000 of investment assets. 0.80 % on the assets over 1,000,000. - 3 - Financial Legacy Management, Inc. Current client relationships may exist where the fees are higher or lower than the fee schedule above. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Retainer Agreement In some circumstances, a Retainer Agreement is executed in addition to an Advisory Service Agreement when it is more appropriate to work on a fixed- fee basis. In most cases, this pertains to clients with small businesses with perpetual tax planning needs. The annual fee for a Retainer Agreement is determined per client and is negotiable. Retainer clients are billed on a monthly or quarterly basis. Investment Management Agreement An Investment Management Agreement may be executed when financial planning is not provided as part of the relationship. Hourly Planning Engagements Financial Legacy Management, Inc. provides hourly planning services for clients who need advice on a limited scope of work. The hourly rate for limited scope engagements is $250 per hour. Asset Management Assets are invested primarily in no-load or low-load mutual funds and exchange-traded funds, usually through discount brokers or fund companies. Fund companies charge each fund shareholder an investment management fee that is disclosed in the fund prospectus. Discount brokerages may charge a transaction fee for the purchase of some funds. Stocks and bonds may be purchased or sold through a brokerage account when appropriate. The brokerage firm charges a fee for stock and bond trades. Financial Legacy Management, Inc. does not receive any compensation, in any form, from fund companies. Investments may also include: equities (stocks), warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities (variable life insurance, variable annuities, and mutual funds shares), U. S. government securities, options contracts, futures contracts, and interests in partnerships. - 4 - Financial Legacy Management, Inc. Initial public offerings (IPOs) are not available through Financial Legacy Management, Inc. Termination of Agreement A Client may terminate any of the aforementioned agreements at any time by notifying Financial Legacy Management, Inc. in writing and paying the rate for the time spent on the investment advisory engagement prior to notification of termination. If the client made an advance payment, Financial Legacy Management, Inc. will refund any unearned portion of the advance payment. Financial Legacy Management, Inc. may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Financial Legacy Management, Inc. will refund any unearned portion of the advance payment. Fees and Compensation Description Financial Legacy Management, Inc. bases its fees on a percentage of assets under management, hourly charges, and fixed fees. Some Retainer Agreements may be priced based on the complexity of work, especially when asset management is not the most significant part of the relationship. Financial plans are priced according to the degree of complexity associated with the client’s situation. Fee Billing Investment management fees are billed quarterly, in arrears, meaning that we invoice you after the three-month billing period has begun. Payment in full is expected upon invoice presentation. Fees are usually deducted from a designated client account to facilitate billing. The client must consent in advance to direct debiting of their investment account. Fees for financial plans are billed in advance, with the balance due upon delivery of the financial plan. Other Fees Custodians may charge transaction fees on purchases or sales of certain mutual funds and exchange-traded funds. These transaction charges are usually small and incidental to the purchase or sale of a security. The selection of the security is more important than the nominal fee that the custodian charges to buy or sell the security. Financial Legacy Management, Inc. in its sole discretion, may waive its minimum fee and/or charge a lesser investment advisory fee based upon - 5 - Financial Legacy Management, Inc. certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with clients, etc.). New Advisory Service Agreement fees are calculated on a formula basis and adjusted for complexity of individual situations. The formula is based on gross income, gross assets and other financial considerations. Expense Ratios Mutual funds generally charge a management fee for their services as investment managers. The management fee is called an expense ratio. For example, an expense ratio of 0.50 means that the mutual fund company charges 0.5% for their services. These fees are in addition to the fees paid by you to Financial Legacy Management, Inc. Performance figures quoted by mutual fund companies in various publications are after their fees have been deducted. Past Due Accounts and Termination of Agreement Financial Legacy Management, Inc. reserves the right to stop work on any account that is more than 90 days overdue. In addition, Financial Legacy Management, Inc. reserves the right to terminate any financial planning engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in Financial Legacy Management, Inc.’s judgment, to providing proper financial advice. Any unused portion of fees collected in advance will be refunded. Performance-Based Fees Sharing of Capital Gains Fees are not based on a share of the capital gains or capital appreciation of managed securities. Financial Legacy Management, Inc. does not use a performance-based fee structure because of the potential conflict of interest. Performance-based compensation may create an incentive for the adviser to recommend an investment that may carry a higher degree of risk to the client. - 6 - Financial Legacy Management, Inc. Types of Clients Description Financial Legacy Management, Inc. generally provides investment advice to individuals, banks or thrift institutions, investment companies, pension and profit sharing plans, trusts, estates, or charitable organizations, corporations or business entities. Client relationships vary in scope and length of service. Account Minimums The minimum account size is $100,000 of assets under management, which equates to an annual fee of $1,000. When an account falls below $100,000 in value, the minimum annual fee of $1,000 is charged. Financial Legacy Management, Inc. has the discretion to waive the account minimum. Accounts of less than $100,000 may be set up when the client and the advisor anticipate the client will add additional funds to the accounts bringing the total to $100,000 within a reasonable time. Other exceptions will apply to employees of Financial Legacy Management, Inc. and their relatives, or relatives of existing clients. Clients receiving ongoing asset management services will be assessed a $1,000 minimum annual fee. Clients with assets below the minimum account size may pay a higher percentage rate on their annual fees than the fees paid by clients with greater assets under management. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Other sources of information that Financial Legacy Management, Inc. may use include Morningstar mutual fund information, Morningstar Principia stock information, Charles Schwab & Company's "Schwab Link" service, Advisor Intelligence, and the World Wide Web. - 7 - Financial Legacy Management, Inc. Investment Strategies The primary investment strategy used on client accounts is strategic asset allocation utilizing a core and satellite approach. This means that we use passively-managed index and exchange-traded funds as the core investments, and then add actively-managed funds where there are greater opportunities to make a difference. Portfolios are globally diversified to control the risk associated with traditional markets. The investment strategy for a specific client is based upon the objectives stated by the client during consultations. The client may change these objectives at any time. Each client executes an Investment Policy Statement that documents their objectives and their desired investment strategy. Other strategies may include long-term purchases, short-term purchases, trading, short sales, and margin transactions. Risk of Loss 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 - 8 - Financial Legacy Management, Inc. 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. Disciplinary Information Legal and Disciplinary The firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The employees of Financial Legacy Management, Inc. have committed to a Code of Ethics that is available for review by clients and prospective clients upon request. The firm will provide a copy of the Code of Ethics to any client or prospective client upon request. Participation or Interest in Client Transactions Financial Legacy Management, Inc. and its employees may buy or sell securities that are also held by clients. Employees may not trade their own securities ahead of client trades. Employees comply with the provisions of the Financial Legacy Management, Inc. Compliance Manual. Personal Trading The Chief Compliance Officer of Financial Legacy Management, Inc. is John W. Kelley. He reviews all employee trades each quarter. His trades are reviewed by Alvin Rogers. The personal trading reviews ensure that the personal trading of employees does not affect the markets, and that clients of the firm receive preferential treatment. Since most employee trades are small mutual fund trades or exchange-traded fund trades, the trades do not affect the securities markets. - 9 - Financial Legacy Management, Inc. Brokerage Practices Selecting Brokerage Firms Financial Legacy Management, Inc. does not have any affiliation with product sales firms. Specific custodian recommendations are made to Clients based on their need for such services. Financial Legacy Management, Inc. recommends custodians based on the proven integrity and financial responsibility of the firm and the best execution of orders at reasonable commission rates. Financial Legacy Management, Inc. recommends discount brokerage firms and trust companies (qualified custodians), such as Charles Schwab. Financial Legacy Management, Inc. does not receive fees or commissions from any of these arrangements. Best Execution Financial Legacy Management, Inc. reviews the execution of trades at each custodian each quarter. Trading fees charged by the custodians is also reviewed on a quarterly basis. Financial Legacy Management, Inc. does not receive any portion of the trading fees. Soft Dollars Financial Legacy Management, Inc. does not receive a software maintenance credit from Charles Schwab & Company because some client assets are custodied at Schwab. Order Aggregation Most trades are mutual funds or exchange-traded funds where trade aggregation does not garner any client benefit. Review of Accounts Periodic Reviews Account reviews are performed quarterly by advisors John W. Kelley, CEO and Alvin Rogers, CFO. Account reviews are performed more frequently when market conditions dictate. Review Triggers Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's own situation. - 10 - Financial Legacy Management, Inc. Regular Reports Account reviewers are members of the firm's Investment Committee. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Clients receive periodic communications on at least an annual basis. Advisory Service Agreement clients, Investment Management clients, and Retainer Agreement clients receive written quarterly updates. The written updates may include a net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Client Referrals and Other Compensation Incoming Referrals Financial Legacy Management, Inc. has been fortunate to receive many client referrals over the years. The referrals came from current clients, estate planning attorneys, accountants, employees, personal friends of employees and other similar sources. The firm does not compensate referring parties for these referrals. Referrals Out Financial Legacy Management, Inc. does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Custody Account Statements All assets are held at qualified custodians, which mean the custodians provide account statements directly to clients at their address of record at least quarterly. Performance Reports Clients are urged to compare the account statements received directly from their custodians to the performance report statements provided by Financial Legacy Management, Inc. Net Worth Statements Clients are frequently provided net worth statements. Net worth statements contain approximations of bank account balances provided by the client, as well as the value of land and hard-to-price real estate. The net worth - 11 - Financial Legacy Management, Inc. statements are used for long-term financial planning where the exact values of assets are not material to the financial planning tasks. Investment Discretion Discretionary Authority for Trading Financial Legacy Management, Inc. accepts discretionary authority to manage securities accounts on behalf of clients. Financial Legacy Management, Inc. has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. However, Financial Legacy Management, Inc. consults with the client prior to each trade to obtain concurrence if a blanket trading authorization has not been given. The client approves the custodian to be used and the commission rates paid to the custodian. Financial Legacy Management, Inc. does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Discretionary trading authority facilitates placing trades in your accounts on your behalf so that we may promptly implement the investment policy that you have approved in writing. Limited Power of Attorney A limited power of attorney is a trading authorization for this purpose. You sign a limited power of attorney so that we may execute the trades that you have approved. Voting Client Securities Proxy Votes Financial Legacy Management, Inc. does not vote proxies on behalf of clients. When assistance on voting proxies is requested, Financial Legacy Management, Inc. will provide recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client. Financial Information Financial Condition Financial Legacy Management, Inc. does not have any financial impairment that will preclude the firm from meeting contractual commitments to clients. A balance sheet is not required to be provided because Financial Legacy Management, Inc. does not serve as a custodian for client funds or securities, - 12 - Financial Legacy Management, Inc. and does not require prepayment of fees of more than $500 per client, and six months or more in advance. Business Continuity Plan General Financial Legacy Management, Inc. has a Business Continuity Plan in place that provides detailed steps to mitigate and recover from the loss of office space, communications, services or key people. Disasters The Business Continuity Plan covers natural disasters such as snow storms, hurricanes, tornados, and flooding. The Plan covers man-made disasters such as loss of electrical power, loss of water pressure, fire, bomb threat, nuclear emergency, chemical event, biological event, T-1 communications line outage, Internet outage, railway accident and aircraft accident. Electronic files are backed up daily and archived offsite. Alternate Offices Alternate offices are identified to support ongoing operations in the event the main office is unavailable. It is our intention to contact all clients within five days of a disaster that dictates moving our office to an alternate location. Loss of Key Personnel Financial Legacy Management, Inc. has signed a Business Continuation Agreement in the event of serious disability or death. Information Security Program Information Security Financial Legacy Management, Inc. maintains an information security program to reduce the risk that your personal and confidential information may be breached. Privacy Notice Financial Legacy Management, Inc. is committed to maintaining the confidentiality, integrity and security of the personal information that is entrusted to us. The categories of nonpublic information that we collect from you may include information about your personal finances, information about your health to the extent that it is needed for the financial planning process, information about - 13 - Financial Legacy Management, Inc. transactions between you and third parties, and information from consumer reporting agencies, e.g., credit reports. We use this information to help you meet your personal financial goals. With your permission, we disclose limited information to attorneys, accountants, and mortgage lenders with whom you have established a relationship. You may opt out from our sharing information with these nonaffiliated third parties by notifying us at any time by telephone, mail, fax, email, or in person. With your permission, we share a limited amount of information about you with your brokerage firm in order to execute securities transactions on your behalf. We maintain a secure office to ensure that your information is not placed at unreasonable risk. We employ a firewall barrier, secure data encryption techniques and authentication procedures in our computer environment. We do not provide your personal information to mailing list vendors or solicitors. We require strict confidentiality in our agreements with unaffiliated third parties that require access to your personal information, including financial service companies, consultants, and auditors. Federal and state securities regulators may review our Company records and your personal records as permitted by law. Personally identifiable information about you will be maintained while you are a client, and for the required period thereafter that records are required to be maintained by federal and state securities laws. After that time, information may be destroyed. We will notify you in advance if our privacy policy is expected to change. We are required by law to deliver this Privacy Notice to you annually, in writing. - 14 - Financial Legacy Management, Inc. Brochure Supplement (Part 2B of Form ADV) Education and Business Standards Financial Legacy Management, Inc. requires that advisors in its employ have a bachelor's degree and further coursework demonstrating knowledge of financial planning and tax planning. Examples of acceptable coursework include: an MBA, a CFP®, a CFA, a ChFC, JD, CTFA, EA or CPA. Additionally, advisors must have work experience that demonstrates their aptitude for financial planning and investment management. Professional Certifications Employees have earned certifications and credentials that are required to be explained in further detail. Certified Financial Planner (CFP): Certified Financial Planners are licensed by the CFP Board to use the CFP mark. CFP certification requirements:  Bachelor’s degree from an accredited college or university.  Completion of the financial planning education requirements set by the CFP Board (www.cfp.net).  Successful completion of the 10-hour CFP® Certification Exam.  Three-year qualifying full-time work experience.  Successfully pass the Candidates Fitness Standards and background check. - 15 - Financial Legacy Management, Inc. John W. Kelley, CFP® - Born 1972 Educational Background:  University of Arkansas at Little Rock, 1998 BA Finance Business Experience:  Financial Legacy Management, Inc.- 6/2005 – Present o CEO/Financial Planner/Portfolio Manager  The Arkansas Financial Group, Inc.- 7/1999 - 6/2005 o Financial Planner/Portfolio Manager/Chief Compliance Officer Arbitration Claims: None Self-Regulatory Organization or Administrative Proceeding: None Bankruptcy Petition: None Alvin Rogers II, CFP® - Born 1970 Educational Background:  University of Arkansas at Little Rock, 1992 BS, Accounting  State of Arkansas Life Insurance License  Webster University, 1994, MBA Business Experience:  Financial Legacy Management, Inc. – 9/2006 – Present o CFO/Financial Planner/Portfolio Manager  Rogers Financial Services – 3/2006 – Present o Vice President/Accountant  Financial Decisions Institute, Inc. – 5/2000 – 10/2005 o Managing Planner/Portfolio Manager Arbitration Claims: None Self-Regulatory Organization or Administrative Proceeding: None Bankruptcy Petition: None - 16 - Financial Legacy Management, Inc.