FINANCIAL STEWARD ASSOCIATES, LLC

ITEM 1 – COVER PAGE 1790 38th Street, Suite 101 Boulder, CO 80301 Phone: 303-444-5440 www.financialstewardassociates.com April 30, 2025 Part 2A Brochure information about Financial Steward Associates, LLC is available on This brochure provides information about the qualifications and business practices of Financial Steward Associates, LLC. If you have any questions about the contents of this brochure, please contact us at 303-444-5440. 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. Financial Steward Associates is a Registered Investment Adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. Additional the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as an IARD number. The IARD number for Financial Steward Associates, LLC is 110594. ____________________________________________________________________________________________ FINANCIAL STEWARD ASSOCIATES APRIL 2025 | PAGE 1  ITEM 2 – MATERIAL CHANGES SUMMARY OF MATERIAL CHANGES This section of the Brochure will address only those “material changes” that have been incorporated since our last delivery or posting of this document on the SEC’s public disclosure website (IAPD) www.adviserinfo.sec.gov. Since our last Annual Amendment filing made on February 26, 2024, the following updates have been made to our Brochure: • Effective March 31, 2025, the firm no longer offers investment management services as previously addressed in Item 4 and Item 5. The Firm provides comprehensive financial planning services. Our Brochure has been amended accordingly to reflect the changes in service offering. Currently, a free copy of our Brochure may be requested by contacting Marion Steward, Chief Compliance Officer of FSA at 303-444-5440. We encourage you to read this document in its entirety. ____________________________________________________________________________________________ FINANCIAL STEWARD ASSOCIATES APRIL 2025 | PAGE 2  ITEM 3 – TABLE OF CONTENTS ITEM 1 – COVER PAGE 1 ITEM 2 – MATERIAL CHANGES 2 ITEM 3 – TABLE OF CONTENTS 3 ITEM 4 – ADVISORY BUSINESS 4 ITEM 5 - FEES AND COMPENSATION 5 ITEM 6 - PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT 7 ITEM 7 - TYPES OF CLIENTS 7 ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS 7 ITEM 9 - DISCIPLINARY INFORMATION 8 ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS 8 ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL 9 TRADING ITEM 12 - BROKERAGE PRACTICES 10 ITEM 13 - REVIEW OF ACCOUNTS 10 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION 11 ITEM 15 – CUSTODY 11 ITEM 16 – INVESTMENT DISCRETION 11 ITEM 17 – VOTING CLIENT SECURITIES 11 ITEM 18 – FINANCIAL INFORMATION 11 ITEM 19 –STATE REGISTERED FIRMS ONLY 12 ____________________________________________________________________________________________ FINANCIAL STEWARD ASSOCIATES APRIL 2025 | PAGE 3  ITEM 4 – ADVISORY BUSINESS This Disclosure document is being offered to you by Financial Steward Associates, LLC (“FSA” or “Firm”) about the investment advisory services we provide. It discloses information about the services that we provide and the way those services are made available to you, the client. Financial Steward Associates, LLC was originally registered with the State of Colorado in March 2001. The principal owner is Marion Steward. Marion Steward is the Chief Compliance Officer of the Firm. FINANCIAL PLANNING Through the financial planning process, our team strives to engage our clients in conversations around the family’s goals, objectives, priorities, vision, and legacy – both for the near term as well as for future generations. With the unique goals and circumstances of each family in mind, our team will offer financial planning ideas and strategies to address the client’s holistic financial picture, including estate, income tax, charitable, cash flow, wealth transfer, and family legacy objectives. Our team may partner with our client’s other advisors (CPAs, Enrolled Agents, Estate Attorneys, Insurance Brokers, etc.) to ensure a coordinated effort of all parties toward the client’s stated goals. Such services include various reports on specific goals and objectives or general investment and/or planning recommendations, guidance to outside assets, and periodic updates. Our specific services in preparing your plan may include: • Review and clarification of your financial goals. • Assessment of your overall financial position including cash flow, balance sheet, investment strategy, risk management, and estate planning. • Creation of a unique plan for each goal you have, including personal and business real estate, education, retirement or financial independence, charitable giving, estate planning, business succession, and other personal goals. • Development of a goal-oriented investment plan, with input from various advisors to our clients around tax suggestions, asset allocation, expenses, risk, and liquidity factors for each goal. This includes IRA and qualified plans, taxable, and trust accounts that require special attention. • Design of a risk management plan including risk tolerance, risk avoidance, mitigation, and transfer, including liquidity as well as various insurance and possible company benefits. A written evaluation of each client's initial situation or Financial Plan is provided to the client. When both investment management through LPL Financial and financial plan implementation are offered through our firm, there is a conflict of interest since there is an incentive for us to recommend products or services for which our investment adviser representatives receive compensation. However, our Firm will make all recommendations independent of such considerations and based ____________________________________________________________________________________________ FINANCIAL STEWARD ASSOCIATES APRIL 2025 | PAGE 4  solely on our obligations to consider your investment objectives and financial needs. As a Financial Planning client, you have the right not to act upon any of our recommendations and not effect the transaction(s) through us if you decide to follow the investment recommendations. Our Firm’s engagement period may vary in terms of length but will be agreed to in the Financial Planning Agreement. If an engagement was to exceed one year, a new engagement agreement would be agreed to and executed by our firm and the Client. investment managers, custodian, and/or CONSULTING SERVICES We also provide clients investment advice on a more-limited basis on one or more isolated areas of concern such as estate planning, real estate, retirement planning, or any other specific topic. Additionally, we provide advice on non-securities matters about the rendering of estate planning, insurance, real estate, and/or annuity advice or any other business advisory / consulting services for equity or debt investments in privately held businesses. In these cases, clients will be required to select their own insurance companies for the implementation of consulting recommendations. If client needs include brokerage and/or other financial services, we will recommend the use of one of several investment managers, brokers, banks, custodians, insurance companies, or other financial professionals ("Firms"). Consulting clients must independently evaluate these Firms before opening an account or transacting business and have the right to effect business through any firm they choose. Clients have the right to choose whether or not to follow the consulting advice provided. Our Firm does not offer wealth management services although it should be noted that our Investment Adviser Representatives will offer wealth management services through their affiliation with LPL as noted below in Item 10. WRAP FEE PROGRAM Our Firm does not provide services on a wrap fee basis. ASSETS As of March 31, 2025, the firm does not report any regulatory assets under management. ITEM 5 - FEES AND COMPENSATION FINANCIAL PLANNING FEES Our Firm offers financial planning services only. Fees may vary based on the extent and complexity of your individual or family circumstances and the amount of your assets under our management. Our fee will be agreed in advance of services being performed. The fee will be determined based on factors including the complexity of your financial situation and agreed upon deliverables. Financial ____________________________________________________________________________________________ FINANCIAL STEWARD ASSOCIATES APRIL 2025 | PAGE 5  Planning fees may be fixed or hourly. The fixed fees range will not exceed $10,000. Hourly fees are $350/hour. The specific fee for your financial plan will be discussed with you and specified in your planning agreement with FSA. The Firm will require an initial deposit of $500 to initiate services and then fees are billed as services are rendered. The Agreement may be terminated by the client within five (5) business days of signing the Agreement without penalty or incurring any fees. After the 5 business days, either party giving written notice to the other may cancel the Agreement at any time for any reason. If you choose to terminate the financial planning agreement by providing us with written notice. Upon termination, fees will be prorated to the date of termination and any earned portion of the fee will be billed to you based on the hours that our firm has spent on creating your financial plan prior to termination. The hourly rate would be stated in your executed Financial Planning Agreement. Any unearned portion of the fee will be refunded to you as described above. CONSULTING FSA provides hourly planning services for clients who need advice on a limited scope of work. FSA will negotiate consulting fees with you. Fees may vary based on the extent and complexity of the consulting project. The hourly rate for limited scope engagements is $350. You will be billed monthly as services are rendered. Either party may terminate the agreement. Upon termination, fees will be prorated to the date of termination and any unearned portion of the fee will be refunded to you as described above. You should be aware that lower fees for comparable services may be available from other sources. In the event that the client desires, the client can engage our Firm’s IARs in their individual capacities as registered representatives of LPL Financial, an SEC-registered and FINRA member broker dealer, to implement investment recommendations on a commission basis. In the event the client chooses to purchase investment products through LPL Financial, LPL Financial will charge brokerage commissions to effect securities transactions, a portion of which commissions LPL Financial shall pay to the LPL registered representatives who effectuated the purchase. Any payment of commissions to Dually Registered Persons would be through their role as registered representatives of LPL Financial, and our Firm would receive no part of those commissions. The brokerage commissions charged by LPL Financial can be higher or lower than those charged by other broker-dealers. The recommendation that a client purchase a commission product from LPL Financial presents a conflict of interest to a Dually Registered Person, as the receipt of commissions provides an incentive to recommend investment products based on commissions received in his or her role as a registered representative of LPL Financial, rather than on a particular client’s need. No client is under any obligation to purchase any commission products from LPL Financial. ____________________________________________________________________________________________ FINANCIAL STEWARD ASSOCIATES APRIL 2025 | PAGE 6  ITEM 6 - PERFORMANCE BASED FEES AND SIDE -BY-SIDE MANAGEMENT Our Firm does not engage in performance-based fees nor side-by-side management. ITEM 7 - TYPES OF CLIENTS Our Firm works with the following types of clients: individuals and high net-worth individuals. Our Firm only provides financial planning services and therefore has no account minimums. ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS The services Financial Steward Associates provides and the product we deliver is a modular Financial Plan and/or hourly consulting. The biggest risk to a client is not implementing the recommendations that have been specified in the Financial Plan or during our engagement. Other risks include: the assumptions utilized in the planning process may prove to be incorrect, human error may occur or incorrect information may be provided by the client during our data gathering process. Financial Steward Associates uses risk tolerance questionnaires, Monte Carlo analysis, modern portfolio theory and general research of investment options to create our Financial Plans and recommendations for each client. Most of the investment recommendations are for investments that have no guarantees as to principal or increase in value. Investing in securities involves risk of loss that clients should be prepared to bear. Frequently, we will use load or no-load Mutual Funds and Exchange Traded Funds, Real Estate Investment Trusts (REITs), Business Development Company’s (BDC’s) and Annuities in our investment recommendations. The following is some general information about the risks associated with several of the common types of investments recommended by Financial Steward Associates. Investors should be aware that accounts are subject to the following risks: ▪ MARKET RISK - Even a long-term investment approach cannot guarantee a profit. Economic, political, and issuer-specific events will cause the value of securities to rise or fall. Because the value of investment portfolios will fluctuate, there is the risk that you will lose money and your investment may be worth more or less upon liquidation. ▪ INTEREST RATE RISK - In a rising rate environment, the value of fixed-income securities generally declines, and the value of equity securities may be adversely affected. ▪ PERFORMANCE OF UNDERLYING MANAGERS - We select the mutual funds and ETFs in the asset allocation portfolios. However, we depend on the manager of such funds to select individual investments in accordance with their stated investment strategy. ▪ CYBERSECURITY RISK - In addition to the Material Investment Risks listed above, investing involves various operational and “cybersecurity” risks. These risks include both intentional and unintentional events at our firm or one of its third-party counterparties or service providers, that may result in a loss or corruption of data, result in the unauthorized release or other misuse of confidential information, and generally compromise our Firm’s ability to ____________________________________________________________________________________________ FINANCIAL STEWARD ASSOCIATES APRIL 2025 | PAGE 7  conduct its business. A cybersecurity breach may also result in a third-party obtaining unauthorized access to our clients’ information, including social security numbers, home addresses, account numbers, account balances, and account holdings. Our Firm has established business continuity plans and risk management systems designed to reduce the risks associated with cybersecurity breaches. However, there are inherent limitations in these plans and systems, including that certain risks may not have been identified, in large part because different or unknown threats may emerge in the future. As such, there is no guarantee that such efforts will succeed, especially because our Firm does not directly control the cybersecurity systems of our third-party service providers. There is also a risk that cybersecurity breaches may not be detected. Our financial planning services may include recommendations related to budgeting, cash flow management, retirement planning, insurance coverage, estate planning, tax strategies, and investment allocation, among other areas. Clients are under no obligation to implement any recommendations made. However, failure to implement or follow through on the financial plan and associated recommendations may increase the risk of not meeting stated financial goals and objectives. Clients who delay or neglect to take recommended actions—such as obtaining appropriate insurance coverage, adjusting spending and savings habits, or reallocating investment assets—may be exposed to unnecessary financial vulnerabilities or shortfalls. Clients assume full responsibility for the consequences of not acting on or delaying action on the financial planning advice received. All financial planning and investment decisions involve a risk of loss, including the potential loss of principal. Clients should be aware that there is no assurance that any financial plan or strategy will ultimately be successful. ITEM 9 - DISCIPLINARY INFORMATION The Firm does not have legal, financial, or other “disciplinary” item to report. ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS INSURANCE Some of our IARs are also licensed insurance agents and sell various life insurance products, long term care and annuities. Our IARs receive compensation (commissions, trails, or other compensation from the respective product sponsors) as a result of effecting insurance transactions for clients. A portion of the time IARs spend (generally 10%) is in connection with these insurance activities and it represents 10% of the ongoing revenue for our IARs. The advisor has an incentive to recommend insurance and this incentive creates a conflict of interest between your interests and our Firm. Clients should note that they have the right to decide whether or not to engage the services of our IARs. Further, clients should note they have the right to decide whether to act on the recommendations ____________________________________________________________________________________________ FINANCIAL STEWARD ASSOCIATES APRIL 2025 | PAGE 8  and the right to choose any professional to execute the advice for any insurance products through our IAR or any licensed insurance agent not affiliated with our Firm. We recognize the fiduciary responsibility to place your interests first and have established policies in this regard to avoid any conflicts of interest. BROKER DEALER FSA is not a broker/dealer, but our Investment Adviser Representatives (“IAR”) are registered representatives and Investment Adviser Representatives of LPL Financial, LLC (“LPL”), a full-service broker-dealer, member FINRA/SIPC, which compensates them for effecting securities transactions. When placing securities transactions through LPL in their capacity as registered representatives, they may earn sales commissions. LPL and FSA are not affiliated companies. IARs of FSA spend a portion their time in connection with broker/dealer activities. OTHER AFFILIATIONS Our Firm does not have an application pending to register as a futures commission merchant, commodity pool operator, a commodity trading adviser, or an associated person of the foregoing entities. ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Our Firm and people associated with us are allowed to invest for their own accounts, or to have a financial investment in the same securities or other investments that we recommend or acquire for your account and may engage in transactions that are the same as or different than transactions recommended to or made for your account. This creates a conflict of interest. We recognize the fiduciary responsibility to act in your best interest and have established polices to mitigate conflicts of interest. We have developed and implemented a Code of Ethics that sets forth standards of conduct expected of our advisory personnel to mitigate this conflict of interest. The Code of Ethics addresses, among other things, personal trading, gifts, and the prohibition against the use of inside information. The Code of Ethics is designed to protect our clients to detect and deter misconduct, educate personnel regarding the Firm’s expectations and laws governing their conduct, remind personnel that they are in a position of trust and must act with complete propriety at all times, protect the reputation of FSA, safeguard against the violation of the securities laws, and establish procedures for personnel to follow so that we may determine whether their personnel are complying with the Firm’s ethical principles. We have established the following restrictions in order to ensure our Firm’s fiduciary responsibilities: ____________________________________________________________________________________________ FINANCIAL STEWARD ASSOCIATES APRIL 2025 | PAGE 9  ▪ No supervised employee of FSA shall prefer his or her own interest to that of the advisory client. Trades for supervised employees are traded alongside client accounts. ▪ We maintain a list of all securities holdings of anyone associated with this advisory practice with access to advisory recommendations. These holdings are reviewed on a regular basis by an appropriate officer/individual of FSA. ▪ We emphasize the unrestricted right of the client to decline implementation of any advice rendered, except in situations where we are granted discretionary authority of the client’s account. ▪ We require that all supervised employees must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. ▪ Any supervised employee not in observance of the above may be subject to termination. You may request a complete copy of our Code by contacting us at the address, telephone, or email on the cover page of this Part 2; ATTN: Marion Steward, Chief Compliance Officer. ITEM 12 - BROKERAGE PRACTICES Investment Adviser Representatives (“IARs”) may suggest that clients Our implement recommendations set forth in the financial plan through LPL in their capacity as a registered representative or an independent licensed insurance agent. If the client chooses to do so, this would present a conflict of interest to the extent that IARs would receive normal and customary commissions as a registered representative or licensed insurance agent resulting from any securities or insurance transactions. Clients are advised that they are under no obligation to implement the plan or its recommendations through our firm’s IARs in their capacity as a registered representative or licensed insurance agent. All potential conflicts of interest relating to compensation have also been disclosed. ITEM 13 - REVIEW OF ACCOUNTS ACCOUNT REVIEWS AND REVIEWERS – INVESTMENT SUPERVISORY SERVICES Our Investment Adviser Representatives will provide an one-time annual meeting to discuss the Plan or if determined, on a more frequent basis in the event of a material change in the client’s financial situation. Plans are modified based on material financial changes or changes in the client’s goals or objectives. STATEMENTS AND REPORTS A Financial Plan is delivered to the client upon completion of an initial engagement or subsequent update due to material financial changes or changes in the client’s goals or objectives. No other written financial reports are provided. Statements may be generated and sent by financial institutions ____________________________________________________________________________________________ FINANCIAL STEWARD ASSOCIATES APRIL 2025 | PAGE 10  or other investment sponsors that the client engages through the implementation of the Financial Plan. The custodian for the individual client’s account will also provide clients with an account statement at least quarterly. You are urged to compare the reports provided by FSA against the account statements you receive directly from your account custodian. ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION Our firm does not accept nor receive compensation for client referrals. We encourage you to discuss any such conflicts of interest with your representative before making a decision to custody your assets at LPL Financial. ITEM 15 – CUSTODY Custody, as it applies to investment advisors, has been defined by regulators as having access or control over client funds and/or securities. In other words, custody is not limited to physically holding client funds and securities. If an investment advisor has the ability to access or control client funds or securities, the investment advisor is deemed to have custody and must ensure proper procedures are implemented. Financial Steward Associates does not provide any investment management services and therefore does not hold or “custody” any client funds. ITEM 16 – INVESTMENT DISCRETION Financial Steward Associates does not manage any client accounts and therefore does not take any authority or discretion with regards to any client accounts. ITEM 17 – VOTING CLIENT SECURITIES As a matter of firm policy and practice, Financial Steward Associates does not have any authority to and does not vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Financial Steward Associates may provide advice to clients regarding the clients’ voting of proxies. ITEM 18 – FINANCIAL INFORMATION We do not require or solicit prepayment of more than $500 in fees per client, six months or more in advance. Therefore, we are not required to include a balance sheet for our most recent fiscal year. We are not subject to a financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients. Finally, we have not been the subject of a bankruptcy petition at any time. ____________________________________________________________________________________________ FINANCIAL STEWARD ASSOCIATES APRIL 2025 | PAGE 11  ITEM 19 –STATE REGISTERED FIRMS ONLY Education and business background can be found in Item 10 above and in the individual's Form ADV Part 2B brochure supplement. Other business activities for each relevant individual can be found on the Form ADV Part 2B brochure supplement for each such individual. Our Firm does not accept performance-based fees or other fees based on a share of capital gains or capital appreciation of the assets of a client. There are no civil, self-regulatory organization, or arbitration proceedings to report under this section. There are no relationships or arrangements of management persons that are issuers of securities. ITEM 2 – EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE ____________________________________________________________________________________________ FINANCIAL STEWARD ASSOCIATES APRIL 2025 | PAGE 12  ITEM 2 – MARION STEWARD, CFP® Marion Steward, CFP® 1790 38th Street, Suite 101 Boulder, CO 80301 (303) 444-5440 April 2025 This brochure supplement provides information about Financial Steward Associates, LLC. (“FSA”) that supplements our brochure. You should have received a copy of that brochure. Please contact us at (303) 444-5440 or financial.steward@lpl.com if you did not receive Financial Steward Associates brochure or if you have any questions about the contents of this supplement. Additional information about Marion Steward is available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD#2795970. ____________________________________________________________________________________________ FINANCIAL STEWARD ASSOCIATES APRIL 2025 | PAGE 13  ITEM 2 – EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE Marion Steward, CFP® Year of Birth: 1966 Educational Background: • 1988: University of California, Berkley; B.A. Economics, B.A. French • Insurance License: Life, Health & Long-Term Disability Business Background: • Financial Steward Associates, Investment Adviser Representative, 2001-Present • LPL Investment Advisor Representative, Previously 2000 – 2022, 2025 – Present • LPL Financial Services, Registered Representative, 2000-Present Professional Designations: • 1CFP ®, Certified Financial Planner, 2000 1Minimum Qualifications for The CERTIFIED FINANCIAL PLANNER™ Designation. I am certified for financial planning services in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER® professional or a CFP® professional, and I may use these and the other certification marks (the “CFP Board Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning, Inc. has licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state law or regulation requires financial planners to hold the CFP® certification. You may find more information about the CFP® certification at www.cfp.net. CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics. To become a CFP® professional, an individual must fulfill the following requirements: • • • • Education – Earn a bachelor’s degree or higher from an accredited college or university and complete CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The coursework covers the financial planning subject areas CFP Board has determined are necessary for the competent and professional delivery of financial planning services, as well as a comprehensive financial plan development capstone course. A candidate may satisfy some of the coursework requirement through other qualifying credentials. CFP Board implemented the bachelor’s degree or higher requirement in 2007 and the financial planning development capstone course requirement in March 2012. Therefore, a CFP® professional who first became certified before those dates may not have earned a bachelor’s or higher degree or completed a financial planning development capstone course. Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the context of real- life financial planning situations. Experience – Complete 6,000 hours of professional experience related to the personal financial planning process, or 4,000 hours of apprenticeship experience that meets additional requirements. Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for CFP® professionals. ____________________________________________________________________________________________ FINANCIAL STEWARD ASSOCIATES APRIL 2025 | PAGE 14  Individuals who become certified must complete the following ongoing education and ethics requirements to remain certified and maintain the right to continue to use the CFP Board Certification Marks: • • Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the client, at all times when providing financial advice and financial planning. CFP Board may sanction a CFP® professional who does not abide by this commitment, but CFP Board does not guarantee a CFP® professional's services. A client who seeks a similar commitment should obtain a written engagement that includes a fiduciary obligation to the client. Continuing Education – Complete 30 hours of continuing education every two years to maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with developments in financial planning. Two of the hours must address the Code and Standards. ITEM 3 – DISCIPLINARY INFORMATION Marion Steward has no history of any legal or disciplinary events that deem to be material to a client’s consideration of Marion Steward to act as their investment adviser representative. FINRA’s BrokerCheck® is a resource available to review the disciplinary history of Marion Steward. https://brokercheck.finra.org/ ITEM 4 – OTHER BUSINESS ACTIVITIES Marion Steward is a registered representative and an Investment Adviser Representative of LPL Financial LLC (“LPL”), a securities broker/dealer, and a member of the Financial Industry Regulatory Authority, Inc. (“FINRA”) and an investment adviser registered with the Securities Exchange Commission. As a broker-dealer, LPL engages in a broad range of activities normally associated with securities brokerage firms. Pursuant to the investment advice given by Marion Steward, investments in securities will be recommended for you. If LPL is selected as the broker-dealer, it will affect transactions in securities for you, a client of FSA and Marion Steward. By serving as the broker-dealer, LPL and Marion Steward will receive commissions for executing securities transactions. You are advised that if LPL is selected as the broker-dealer, the transaction charges may be higher or lower than the charges you may pay if the transactions were executed at other broker-dealers. You should note, however, that you have the right to not purchase securities through Marion Steward, FSA or LPL. Marion Steward will provide advice regarding investment company securities. You should be aware that, in addition to the advisory fees paid by you, each investment company also charges its own separate investment advisory fees and other expenses (internal management fees). In addition, you should be aware that mutual funds may be purchased separately independent of the investment management services of FSA. Marion Steward, in her capacity as a registered representative of LPL, or as an agent appointed with various life, disability or other insurance companies, receives commissions, 12(b) -1 fees, trails, or other compensation from the respective product sponsors and/or as a result of effecting securities transactions for you. However, you should note that you have the right to not purchase any investment products through Marion Steward. She spends 10% of her time on these activities. This presents a conflict of interest to the extent that she may recommend the purchase of an insurance product which results in commission being paid to her as an insurance agent. ____________________________________________________________________________________________ FINANCIAL STEWARD ASSOCIATES APRIL 2025 | PAGE 15  ITEM 5 – ADDITIONAL COMPENSATION Marion Steward does not receive additional compensation beyond the scope of her role as your investment adviser representative and items listed in Item 4. ITEM 6 – SUPERVISION Marion Steward is the Chief Compliance Officer of Financial Steward Associates. She supervises and oversees all activities conducted through the firm and maintains policies and procedures to guide her activities. Marion Steward reviews those policies and procedures annually for their adequacy and the effectiveness of their implementation. Marion Steward will abide by and adhere to all industry rules and regulations in addition to the firm’s written supervisory procedures and code of ethics. Marion Steward may be reached at (303) 444-5440. ITEM 7 – REQUIREMENTS FOR STATE REGISTERED ADVISORS This disclosure is required by state securities authorities and is provided for your use in evaluating this investment advisor representative’s suitability. Marion Steward has NOT been involved in any of the events listed below. 1. An award or otherwise being found liable in an arbitration claim alleging damages more than $2,500, involving any of the following: a) an investment or an investment-related business or activity; b) fraud, false statement(s), or omissions; c) theft, embezzlement, or other wrongful taking of property; d) bribery, forgery, counterfeiting, or extortion; or e) dishonest, unfair, or unethical practices. 2. An award or otherwise being found liable in a civil, self-regulatory organization, or administrative proceeding involving any of the following: a) an investment or an investment-related business or activity; b) fraud, false statement(s), or omissions; c) theft, embezzlement, or other wrongful taking of property; d) bribery, forgery, counterfeiting, or extortion; or e) dishonest, unfair, or unethical practices. B. Marion Steward has NOT been the subject of a bankruptcy petition ____________________________________________________________________________________________ FINANCIAL STEWARD ASSOCIATES APRIL 2025 | PAGE 16  HEATHER WILLIAMS, CFP® Heather Williams, CFP® 1790 38th Street, Suite 101 Boulder, CO 80301 (303) 444-5440 April 2025 PART 2B BROCHURE This brochure supplement provides information about Financial Steward Associates(“FSA”) that supplements our brochure. You should have received a copy of that brochure. Please contact us at (303) 444-5440 or financial.steward@lpl.com if you did not receive Financial Steward Associates brochure or if you have any questions about the contents of this supplement. Additional information about Heather Williams is available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD5475507.  ITEM 2 – EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE Heather Williams, CFP® Year of Birth: 1982 Educational Background: • • 2007: Metropolitan State University of Denver; B.S. Finance Insurance Licenses: Life Business Background: Financial Steward Associates, Office Manager, 2013-2015 Financial Steward Associates, Client Relationship Manager, 2015-2016 LPL Financial, Investment Advisor Representative, Previously 2016-2022, 2025 - • • • Present • • • LPL Financial, Registered Representative, 2016-Present Financial Steward Associates, Investment Advisor Representative, 2017 - Present Financial Steward Associates, Financial Planner, 2017 - Present Professional Designations:1CFP ®, Certified Financial Planner, 2016 1Minimum Qualifications for The CERTIFIED FINANCIAL PLANNER™ Designation. I am certified for financial planning services in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER® professional or a CFP® professional, and I may use these and the other certification marks (the “CFP Board Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning, Inc. has licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state law or regulation requires financial planners to hold the CFP® certification. You may find more information about the CFP® certification at www.cfp.net. CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics. To become a CFP® professional, an individual must fulfill the following requirements: • • • • Education – Earn a bachelor’s degree or higher from an accredited college or university and complete CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The coursework covers the financial planning subject areas CFP Board has determined are necessary for the competent and professional delivery of financial planning services, as well as a comprehensive financial plan development capstone course. A candidate may satisfy some of the coursework requirement through other qualifying credentials. CFP Board implemented the bachelor’s degree or higher requirement in 2007 and the financial planning development capstone course requirement in March 2012. Therefore, a CFP® professional who first became certified before those dates may not have earned a bachelor’s or higher degree or completed a financial planning development capstone course. Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the context of real-life financial planning situations. Experience – Complete 6,000 hours of professional experience related to the personal financial planning process, or 4,000 hours of apprenticeship experience that meets additional requirements. Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for CFP® professionals. FINANCIAL STEWARD ASSOCIATES MARCH 2025 | PAGE 1  Individuals who become certified must complete the following ongoing education and ethics requirements to remain certified and maintain the right to continue to use the CFP Board Certification Marks: • • Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the client, at all times when providing financial advice and financial planning. CFP Board may sanction a CFP® professional who does not abide by this commitment, but CFP Board does not guarantee a CFP® professional's services. A client who seeks a similar commitment should obtain a written engagement that includes a fiduciary obligation to the client. Continuing Education – Complete 30 hours of continuing education every two years to maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with developments in financial planning. Two of the hours must address the Code and Standards. ITEM 3 – DISCIPLINARY INFORMATION Heather Williams has no legal or disciplinary events that deem to be material to a client’s consideration of Heather Williams to act as their investment adviser representative. FINRA’s BrokerCheck® is a resource available to review the disciplinary history of Heather Williams. https://brokercheck.finra.org/ ITEM 4 – OTHER BUSINESS ACTIVITIES Heather Williams is a registered representative and an Investment Adviser Representative of LPL Financial LLC (“LPL”), a securities broker/dealer, and a member of the Financial Industry Regulatory Authority, Inc. (“FINRA”) and an investment adviser registered with the Securities Exchange Commission. As a broker-dealer, LPL engages in a broad range of activities normally associated with securities brokerage firms. Pursuant to the investment advice given by Heather Williams, investments in securities will be recommended for you. If LPL is selected as the broker-dealer, it will affect transactions in securities for you, a client of FSA and Heather Williams. By serving as the broker-dealer, LPL and Heather Williams will receive commissions for executing securities transactions. You are advised that if LPL is selected as the broker-dealer, the transaction charges may be higher or lower than the charges you may pay if the transactions were executed at other broker-dealers. You should note, however, that you have the right to not purchase securities through Heather Williams, FSA or LPL. Heather Williams will provide advice regarding investment company securities. You should be aware that, in addition to the advisory fees paid by you, each investment company also charges its own separate investment advisory fees and other expenses (internal management fees). In addition, you should be aware that mutual funds may be purchased separately independent of the investment management services of FSA. Heather Williams, in her capacity as a registered representative of LPL, or as an agent appointed with various life insurance companies, receives commissions, 12(b) -1 fees, trails, or other compensation from the respective product sponsors and/or as a result of effecting securities transactions for you. However, you should note that you have the right to not purchase any investment products through Heather Williams. She spends 25% of her time on these activities. This presents a conflict of interest to the extent that she may recommend the purchase of an insurance product which results in commission being paid to her as an insurance agent. FINANCIAL STEWARD ASSOCIATES MARCH 2025 | PAGE 2  ITEM 5 – ADDITIONAL COMPENSATION Heather Williams does not receive additional compensation beyond the scope of her role as your investment adviser representative and items listed in Item 4. ITEM 6 – SUPERVISION Heather Williams is supervised through a compliance program designed to prevent and detect violations of the federal and state securities laws. Supervision is conducted by the Chief Compliance Officer, Marion Steward, who is responsible for administering the policies and procedures. As Chief Compliance Officer, Marion Steward reviews those policies and procedures annually for their adequacy and the effectiveness of their implementation. All policies and procedures of the firm are followed. Marion Steward may be reached at (303) 444-5440. ITEM 7 – REQUIREMENTS FOR STATE REGISTERED ADVISORS This disclosure is required by state securities authorities and is provided for your use in evaluating this investment advisor representative’s suitability. A. Heather Williams has NOT been involved in any of the events listed below. 1. An award or otherwise being found liable in an arbitration claim alleging damages more than $2,500, involving any of the following: a) an investment or an investment-related business or activity; b) fraud, false statement(s), or omissions; c) theft, embezzlement, or other wrongful taking of property; d) bribery, forgery, counterfeiting, or extortion; or e) dishonest, unfair, or unethical practices. 2. An award or otherwise being found liable in a civil, self-regulatory organization, or administrative proceeding involving any of the following: a) an investment or an investment-related business or activity; b) fraud, false statement(s), or omissions; c) theft, embezzlement, or other wrongful taking of property; d) bribery, forgery, counterfeiting, or extortion; or e) dishonest, unfair, or unethical practices. to review B. Heather Williams has no current disclosures regarding bankruptcy petitions that are deemed material to disclose on this Brochure supplement. FINRA’s BrokerCheck® is a the disciplinary history of Heather Williams. resource available https://brokercheck.finra.org/ FINANCIAL STEWARD ASSOCIATES MARCH 2025 | PAGE 3  NED MELONI, CFP® , CRPC® Ned Meloni, CFP®, CRPC® 1790 38th Street, Suite 101 Boulder, CO 80301 (303) 444-5440 April 2025 Part 2B Brochure This brochure supplement provides information about Financial Steward Associates(“FSA”) that supplements our brochure. You should have received a copy of that brochure. Please contact us at (303) 444-5440 or financial.steward@lpl.com if you did not receive Financial Steward Associates brochure or if you have any questions about the contents of this supplement. Additional information about Ned Meloni is available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD 4143605. FINANCIAL STEWARD ASSOCIATES MARCH 2025 | PAGE 4  ITEM 2 – EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE Ned Meloni, CFP®, CRPC® Year of Birth: 1975 Educational Background: • 1998-2000: SUNY College at Brockport; B.A. Economics and International Business • Insurance Licenses: Variable Products, Accident, Life and Health Business Background: LPL Investment Advisor Representative, 2025 – Present LPL Financial LLC, Registered Representative, 2024-Present • Financial Steward Associates, LLC, Financial Advisor, 2024-Present • • • Elevations CU, CUSO Financial Services, Senior Financial Advisor, 2023-2024 • Empower Financial, GWFS Equities, Lead Retirement Planner, 2018-2023 Professional Designations: • • 1CFP ®, Certified Financial Planner, 2022 2CRPC ®, Chartered Retirement Planning Counselor, 2020 1Minimum Qualifications for The CERTIFIED FINANCIAL PLANNER™ Designation. I am certified for financial planning services in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER® professional or a CFP® professional, and I may use these and the other certification marks (the “CFP Board Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning, Inc. has licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state law or regulation requires financial planners to hold the CFP® certification. You may find more information about the CFP® certification at www.cfp.net. CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics. To become a CFP® professional, an individual must fulfill the following requirements: • • • • Education – Earn a bachelor’s degree or higher from an accredited college or university and complete CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The coursework covers the financial planning subject areas CFP Board has determined are necessary for the competent and professional delivery of financial planning services, as well as a comprehensive financial plan development capstone course. A candidate may satisfy some of the coursework requirement through other qualifying credentials. CFP Board implemented the bachelor’s degree or higher requirement in 2007 and the financial planning development capstone course requirement in March 2012. Therefore, a CFP® professional who first became certified before those dates may not have earned a bachelor’s or higher degree or completed a financial planning development capstone course. Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the context of real-life financial planning situations. Experience – Complete 6,000 hours of professional experience related to the personal financial planning process, or 4,000 hours of apprenticeship experience that meets additional requirements. Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for CFP® professionals. FINANCIAL STEWARD ASSOCIATES MARCH 2025 | PAGE 5  Individuals who become certified must complete the following ongoing education and ethics requirements to remain certified and maintain the right to continue to use the CFP Board Certification Marks: • • Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the client, at all times when providing financial advice and financial planning. CFP Board may sanction a CFP® professional who does not abide by this commitment, but CFP Board does not guarantee a CFP® professional's services. A client who seeks a similar commitment should obtain a written engagement that includes a fiduciary obligation to the client. Continuing Education – Complete 30 hours of continuing education every two years to maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with developments in financial planning. Two of the hours must address the Code and Standards. 2* Minimum Qualifications for the Chartered Retirement Planning Counselor (CRPC®): The CRPC program is administered by the College for Financial Planning. Individuals who hold the CRPC® designation have completed a course of study encompassing pre-and post-retirement needs, asset management, estate planning and the entire retirement planning process using models and techniques from real client situations. Additionally, individuals must pass an end- of-course examination that tests their ability to synthesize complex concepts and apply theoretical concepts to real-life situations. All designees have agreed to adhere to Standards of Professional Conduct and are subject to a disciplinary process. Designees renew their designation every two-years by completing 16 hours of continuing education, reaffirming adherence to the Standards of Professional Conduct and complying with self-disclosure requirements. ITEM 3 – DISCIPLINARY INFORMATION Ned Meloni has no history of any legal or disciplinary events that deem to be material to a client’s consideration of Ned Meloni to act as their investment adviser representative. FINRA’s BrokerCheck® is a resource available to review the disciplinary history of Ned Meloni. https://brokercheck.finra.org/ ITEM 4 – OTHER BUSINESS ACTIVITIES Ned Meloni is a registered representative and an Investment Adviser Representative of LPL Financial LLC (“LPL”), a securities broker/dealer, and a member of the Financial Industry Regulatory Authority, Inc. (“FINRA”) and an investment adviser registered with the Securities Exchange Commission. As a broker-dealer, LPL engages in a broad range of activities normally associated with securities brokerage firms. Pursuant to the investment advice given by Ned Meloni, investments in securities will be recommended for you. If LPL is selected as the broker-dealer, it will affect transactions in securities for you, a client of FSA and Ned Meloni. By serving as the broker-dealer, LPL and Ned Meloni will receive commissions for executing securities transactions. You are advised that if LPL is selected as the broker-dealer, the transaction charges may be higher or lower than the charges you may pay if the transactions were executed at other broker-dealers. You should note, however, that you have the right to not purchase securities through Ned Meloni, FSA or LPL. Ned Meloni will provide advice regarding investment company securities. You should be aware that, in addition to the advisory fees paid by you, each investment company also charges its own separate investment advisory fees and other expenses (internal management fees). In addition, you should be aware that mutual funds may be purchased separately independent of the investment management services of FSA. Ned Meloni, in his capacity as a registered representative of LPL, or as an agent appointed with various life insurance companies, receives commissions, 12(b) -1 fees, trails, or other compensation FINANCIAL STEWARD ASSOCIATES MARCH 2025 | PAGE 6  from the respective product sponsors and/or as a result of effecting securities transactions for you. However, you should note that you have the right to not purchase any investment products through Ned Meloni. He spends 25% of his time on these activities. This presents a conflict of interest to the extent that he may recommend the purchase of an insurance product which results in commission being paid to him as an insurance agent. ITEM 5 – ADDITIONAL COMPENSATION Ned Meloni does not receive additional compensation beyond the scope of his role as your investment adviser representative and items listed in Item 4. ITEM 6 – SUPERVISION Ned Meloni is supervised through a compliance program designed to prevent and detect violations of the federal and state securities laws. Supervision is conducted by the Chief Compliance Officer, Marion Steward, who is responsible for administering the policies and procedures. As Chief Compliance Officer, Marion Steward reviews those policies and procedures annually for their adequacy and the effectiveness of their implementation. All policies and procedures of the firm are followed. Marion Steward may be reached at (303) 444-5440. ITEM 7 – REQUIREMENTS FOR STATE REGISTERED ADVISORS This disclosure is required by state securities authorities and is provided for your use in evaluating this investment advisor representative’s suitability. A. Ned Meloni has NOT been involved in any of the events listed below. 1. An award or otherwise being found liable in an arbitration claim alleging damages more than $2,500, involving any of the following: a) an investment or an investment-related business or activity; b) fraud, false statement(s), or omissions; c) theft, embezzlement, or other wrongful taking of property; d) bribery, forgery, counterfeiting, or extortion; or e) dishonest, unfair, or unethical practices. 2. An award or otherwise being found liable in a civil, self-regulatory organization, or administrative proceeding involving any of the following: a) an investment or an investment-related business or activity; b) fraud, false statement(s), or omissions; c) theft, embezzlement, or other wrongful taking of property; d) bribery, forgery, counterfeiting, or extortion; or e) dishonest, unfair, or unethical practices. B. Ned Meloni has NOT been the subject of a bankruptcy petition. FINANCIAL STEWARD ASSOCIATES MARCH 2025 | PAGE 7  SIDNEY SMITH, CFP ® Sidney Smith, CFP® 1790 38th Street, Suite 101 Boulder, CO 80301 (303) 444-5440 April 2025 Part 2B Brochure This brochure supplement provides information about Financial Steward Associates(“FSA”) that supplements our brochure. You should have received a copy of that brochure. Please contact us at (303) 444-5440 or financial.steward@lpl.com if you did not receive Financial Steward Associates brochure or if you have any questions about the contents of this supplement. Additional information about Sidney Smith is available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD7449184. FINANCIAL STEWARD ASSOCIATES MARCH 2025 | PAGE 8  ITEM 2 – EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE Sidney Smith, CFP® Year of Birth: 1995 Educational Background: • 2013-2017: Gannon University; B.S. Environmental Engineering • 2020-2021: Edinboro University; CFP Board Registered Program Business Background: Financial Steward Associates, LLC, Financial Planner, 2024-Present LPL Financial LLC, Registered Representative, 2024-Present LPL Financial LLC, Investment Adviser Representative, 2025-Present Financial Steward Associates, LLC, Financial Planning Assistant, 2022-2024 LPL Financial LLC, Licensed Admin, 2022-2024 Fidelity Investments, Customer Relationship Advocate, 2021-2022 • • • • • • • UPMC Hamot, Administrative Professional, 2020-2021 • Deiss & Halmi Engineering, Inc., Engineering Staff, 2018-2020 Professional Designations:1CFP ®, Certified Financial Planner, 2024 1Minimum Qualifications for The CERTIFIED FINANCIAL PLANNER™ Designation. I am certified for financial planning services in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER® professional or a CFP® professional, and I may use these and the other certification marks (the “CFP Board Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning, Inc. has licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state law or regulation requires financial planners to hold the CFP® certification. You may find more information about the CFP® certification at www.cfp.net. CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics. To become a CFP® professional, an individual must fulfill the following requirements: • • • • Education – Earn a bachelor’s degree or higher from an accredited college or university and complete CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The coursework covers the financial planning subject areas CFP Board has determined are necessary for the competent and professional delivery of financial planning services, as well as a comprehensive financial plan development capstone course. A candidate may satisfy some of the coursework requirement through other qualifying credentials. CFP Board implemented the bachelor’s degree or higher requirement in 2007 and the financial planning development capstone course requirement in March 2012. Therefore, a CFP® professional who first became certified before those dates may not have earned a bachelor’s or higher degree or completed a financial planning development capstone course. Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the context of real-life financial planning situations. Experience – Complete 6,000 hours of professional experience related to the personal financial planning process, or 4,000 hours of apprenticeship experience that meets additional requirements. Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements to remain certified and maintain the right to continue to use the CFP Board Certification Marks: FINANCIAL STEWARD ASSOCIATES MARCH 2025 | PAGE 9  • • Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the client, at all times when providing financial advice and financial planning. CFP Board may sanction a CFP® professional who does not abide by this commitment, but CFP Board does not guarantee a CFP® professional's services. A client who seeks a similar commitment should obtain a written engagement that includes a fiduciary obligation to the client. Continuing Education – Complete 30 hours of continuing education every two years to maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with developments in financial planning. Two of the hours must address the Code and Standards. ITEM 3 – DISCIPLINARY INFORMATION Sidney Smith has no history of any legal or disciplinary events that deem to be material to a client’s consideration of Sidney Smith to act as their investment adviser representative. FINRA’s BrokerCheck® is a resource available to review the disciplinary history of Sidney Smith. https://brokercheck.finra.org/ ITEM 4 – OTHER BUSINESS ACTIVITIES Sidney Smith is a registered representative and an Investment Adviser Representative of LPL Financial LLC (“LPL”), a securities broker/dealer, and a member of the Financial Industry Regulatory Authority, Inc. (“FINRA”) and an investment adviser registered with the Securities Exchange Commission. As a broker-dealer, LPL engages in a broad range of activities normally associated with securities brokerage firms. Pursuant to the investment advice given by Sidney Smith, investments in securities will be recommended for you. If LPL is selected as the broker-dealer, it will affect transactions in securities for you, a client of FSA and Sidney Smith. By serving as the broker-dealer, LPL and Sidney Smith will receive commissions for executing securities transactions. You are advised that if LPL is selected as the broker-dealer, the transaction charges may be higher or lower than the charges you may pay if the transactions were executed at other broker-dealers. You should note, however, that you have the right to not purchase securities through Sidney Smith, FSA or LPL. Sidney Smith will provide advice regarding investment company securities. You should be aware that, in addition to the advisory fees paid by you, each investment company also charges its own separate investment advisory fees and other expenses (internal management fees). In addition, you should be aware that mutual funds may be purchased separately independent of the investment management services of FSA. ITEM 5 – ADDITIONAL COMPENSATION Sidney Smith does not receive additional compensation beyond the scope of his role as your investment adviser representative and items listed in Item 4. FINANCIAL STEWARD ASSOCIATES MARCH 2025 | PAGE 10  ITEM 6 – SUPERVISION Sidney Smith is supervised through a compliance program designed to prevent and detect violations of the federal and state securities laws. Supervision is conducted by the Chief Compliance Officer, Marion Steward, who is responsible for administering the policies and procedures. As Chief Compliance Officer, Marion Steward reviews those policies and procedures annually for their adequacy and the effectiveness of their implementation. All policies and procedures of the firm are followed. Marion Steward may be reached at (303) 444-5440. ITEM 7 – REQUIREMENTS FOR STATE REGISTERED ADVISORS This disclosure is required by state securities authorities and is provided for your use in evaluating this investment advisor representative’s suitability. A. Sidney Smith has NOT been involved in any of the events listed below. 1. An award or otherwise being found liable in an arbitration claim alleging damages more than $2,500, involving any of the following: a) an investment or an investment-related business or activity; b) fraud, false statement(s), or omissions; c) theft, embezzlement, or other wrongful taking of property; d) bribery, forgery, counterfeiting, or extortion; or e) dishonest, unfair, or unethical practices. 2. An award or otherwise being found liable in a civil, self-regulatory organization, or administrative proceeding involving any of the following: a) an investment or an investment-related business or activity; b) fraud, false statement(s), or omissions; c) theft, embezzlement, or other wrongful taking of property; d) bribery, forgery, counterfeiting, or extortion; or e) dishonest, unfair, or unethical practices. B. Sidney Smith has NOT been the subject of a bankruptcy petition. FINANCIAL STEWARD ASSOCIATES MARCH 2025 | PAGE 11