FLYING POINT FINANCIAL, INC.

Item 1: Cover Page Flying Point Financial, Inc. Form ADV Part 2A Investment Adviser Brochure 855 Turnpike Street North Andover, MA 01845 (978) 975-3000 www.flyingpointfinancial.com February 2026 This Brochure provides information about the qualifications and business practices of Flying Point Financial, Inc. (“we,” “us,” “our”). If you have any questions about the contents of this Brochure, please contact Amy E. Mastromonaco, Director of Operations and Chief Compliance Officer, at (978) 975-3000 or info@flyingpointfinancial.com. Additional information about our Firm is also available at www.adviserinfo.sec.gov. 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. We are a registered investment adviser. Please note that use of the term “registered investment adviser” and a description of the Firm and/or our employees as “registered” does not imply a certain level of skill or training. For more information on the qualifications of the Firm and our employees who advise you, we encourage you to review this Brochure and the Brochure Supplement(s). 1  Item 2: Summary of Material Changes In this Item of Flying Point Financial, Inc. (the “Firm,” “we,” “us,” “ours,”) Form ADV 2, we are required to discuss any material changes that have been made to Form ADV since the last Annual Amendment. Material Changes since the Last Update Since the filing of our Annual Amendment on February 4, 2025, we have no Material Changes to report. Annual Update Investment management clients will receive a summary of any material changes to our Form ADV brochure within 120 days of our fiscal year end. We may also provide updated disclosure information about material changes on a more frequent basis. Any summaries of changes will include the date of the last annual update of the ADV. The Supplement to our Form ADV Brochure (Form ADV Part 2B) provides clients with information regarding our employees that provide investment advice. Full Brochure Available Our Form ADV may be requested at any time, without charge by contacting Amy E. Mastromonaco, Director of Operations and Chief Compliance Officer, at (978) 975-3000 or info@flyingpointfinancial.com. Additional information about the Firm is also available via the SEC’s website at www.adviserinfo.sec.gov. The SEC’s website also provides information about any employees affiliated with the Firm who are registered as investment advisor representatives. 2  Item 3: Table of Contents Item 1: Cover Page .......................................................................................................................... 1 Item 2: Summary of Material Changes ........................................................................................... 2 Item 4: Advisory Business ............................................................................................................... 4 Item 5: Fees and Compensation ..................................................................................................... 7 Item 6: Performance-Based Fees and Side-by-Side Management ............................................... 10 Item 7: Types of Clients ................................................................................................................. 11 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ......................................... 12 Item 9: Disciplinary Information ................................................................................................... 14 Item 10: Other Financial Industry Activities and Affiliations ........................................................ 15 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading . 16 Item 12: Brokerage Practices ........................................................................................................ 17 Item 13: Review of Accounts ......................................................................................................... 19 Item 14: Client Referrals and Other Compensation ..................................................................... 20 Item 15: Custody ........................................................................................................................... 21 Item 16: Investment Discretion .................................................................................................... 22 Item 17: Voting Client Securities .................................................................................................. 23 Item 18: Financial Information ..................................................................................................... 24 Form ADV Part 2B – Investment Advisor Brochure Supplement ................................................. 25 3  Item 4: Advisory Business Firm Information This Disclosure Brochure (“Form ADV Part 2”) provides information regarding the qualifications, business practices, and the advisory services provided by Flying Point Financial, Inc. (the “Firm,” “we,” “us,” “ours”). We are a federally registered investment adviser with the U.S. Securities and Exchange Commission (“SEC”). We were founded in 1998 and are owned by Kevin J. Kennedy, President, and Amy E. Mastromonaco, Director of Operations and Chief Compliance Officer. Types of Advisory Services Financial Planning We offer financial planning services, which may include a review of all aspects of a client’s current financial situation, including the following components: cash management, risk management, insurance, education funding, goal setting, retirement planning, estate and charitable giving planning, tax planning, and capital needs planning. Clients understand that when we are engaged to address only certain components, the client’s overall financial and investment issues may not be taken into consideration. We meet with the client to review risk tolerance, financial goals and objectives, and time horizons. Additional meetings may include a review of additional financial information: sources of income, assets owned, existing insurance, liabilities, wills, trusts, business agreements, tax returns, investments, and personal and family obligations. The financial plan may include both long and short-term considerations, depending upon the individual scenario. Upon completion a plan is presented to the client and the client is provided with recommendations that are deemed to be compatible with the client’s stated goals and objectives. An implementation schedule is reviewed with the client to determine which steps will be pursued, and with whom the steps may be accomplished. The client is under no obligation to utilize the Firm to implement the advice or plan. Clients may choose all or certain components of advice and recommendations and can implement the recommendations through the service providers of their choice. Wealth Management We typically provide a variety of wealth management services to individuals and families, in several areas of a client’s financial situation, depending on their goals, objectives, and resources. In Wealth Management engagements, we provide ongoing Financial Planning described above and Investment Management services as described below. Investment Management services include continuous advice to clients regarding investment of 4  client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client’s particular circumstances are established, we develop a client’s personal investment policy and create and manage a portfolio based on that policy. We will manage advisory accounts on a discretionary basis only. Account supervision is guided by the stated objectives of the client (i.e., maximum capital appreciation, growth, income, growth with income, etc.) We will create a portfolio consisting of one or all of the following: individual equities, bonds, other investment products, no-load or load-waived mutual funds, and ETFs. We will allocate the client’s assets among various investments taking into consideration the overall management style selected by the client. Mutual funds will be selected on the basis of any or all of the following criteria: the fund’s performance history; the industry sector in which the fund invests; the track record of the fund’s manager; the fund’s investment objectives; the fund’s management style and philosophy; and the fund’s management fee structure. Portfolio weighting between funds and market sectors will be determined by each client’s individual needs and circumstances. We may also recommend the use of an unaffiliated investment advisory firm for a portion of the client’s portfolio. We may also provide advice about any type of legacy position or investment otherwise held in client portfolios. Tailored Relationships We tailor investment advisory services to the individual needs of the client. Our clients are allowed to impose restrictions on the investments in their account. All limitations and restrictions placed on accounts must be presented to us in writing. Wrap Fee Programs A “wrap-fee” program is one that provides the client with advisory and brokerage execution services for an all-inclusive fee. The client is not charged separate fees for the respective components of the total service. We do not sponsor, manage, or participate in a wrap fee program. Fiduciary Statement We are fiduciaries under the Investment Advisers Act of 1940, and when we provide investment advice to clients regarding retirement plan accounts or individual retirement accounts, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act, (“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing retirement accounts. We must act in our clients’ best interest and not put our interest ahead of theirs. At the same time, the way we make money creates some conflicts with a client’s interests. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client: 5  • To render impartial advice; • To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives; • To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead; • To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations; • Disclose any material conflict of interest in writing; and • Treat clients fairly and equitably. Regulations prohibit us from: • Employing any device, scheme, or artifice to defraud a client; • Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client; • Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or • Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner when working with clients. We will use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Assets Under Management As of December 31, 2025, we managed $206,723,000 in client assets; $201,066,000 is managed on a discretionary basis and $5,657,000 is managed on a non-discretionary basis. 6  Item 5: Fees and Compensation We base our fees on hourly charges, fixed fees and/or a percentage of assets under management, described below. Compensation – Financial Planning Financial Planning fees are charged on an hourly basis of $250 per hour. Half of the agreed upon fee will be due upon entering a planning agreement and the balance is due upon presentation of the financial plan. Compensation – Wealth Management Services Wealth Management fees are charged an annual fee ranging from 0.50% to 1.50% depending on the total assets under management, portfolio composition, and complexity of the case. The asset-based fee is billed on a quarterly basis, in arrears, based upon the market value of the assets under management, including cash, on the last day of the previous quarter as valued by the custodian. Calculation and Payment The specific manner in which we charge fees is established in a client’s written agreement with us. Clients may elect to be invoiced directly for fees or to authorize us to directly debit fees from client accounts. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. Other Fees There are no additional types of fees or expenses that our clients pay in connection with the delivery of advisory services. Agreement Terms Either party may terminate an agreement at any time by notifying the other in writing. If the client made an advance payment, we would refund any unearned portion of the advance payment. If the client made a payment in arrears, we would collect any earned yet unpaid fees. Cash Balances Some assets may be held as cash and remain uninvested. Holding a portion of assets in cash and cash alternatives, i.e., money market fund shares, may be based on the client’s desire to have an allocation to cash as an asset class, to support a phased market entrance strategy, to facilitate transaction execution, to have available funds for withdrawal needs or to pay fees or to provide for asset protection during periods of volatile market conditions. Cash and cash equivalents will be subject to our investment advisory fees unless otherwise agreed upon. Clients may experience negative performance on the cash portion of their portfolio if the investment advisory fees charged are higher than the returns received from cash. 7  Retirement Plan Rollover Recommendations As part of our investment advisory services to our clients, we may recommend that clients roll assets from their employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively, a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA, Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will advise on the client’s behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. If the client elects to roll the assets to an IRA that is subject to our advisement, we will charge the client an asset-based fee as set forth in the advisory agreement the client executed with our firm. This creates a conflict of interest because it creates a financial incentive for our firm to recommend the rollover to the client (i.e., receipt of additional fee-based compensation). Clients are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if clients do complete the rollover, clients are under no obligation to have the assets in an IRA advised on by our firm. Due to the foregoing conflict of interest, when we make rollover recommendations, we operate under a special rule that requires us to act in our clients’ best interests and not put our interests ahead of our clients.’ Under this special rule’s provisions, we must: • meet a professional standard of care when making investment recommendations (give prudent advice); • never put our financial interests ahead of our clients’ when making recommendations (give loyal advice); • avoid misleading statements about conflicts of interest, fees, and investments; • follow policies and procedures designed to ensure that we give advice that is in our clients’ best interests; • charge no more than a reasonable fee for our services; and • give clients basic information about conflicts of interest. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, clients should consider the costs and benefits of a rollover. Note that an employee will typically have four options in this situation: 1. leaving the funds in the employer’s (former employer’s) plan; 2. moving the funds to a new employer’s retirement plan; 3. cashing out and taking a taxable distribution from the plan; or 4. rolling the funds into an IRA rollover account. Each of these options has positives and negatives. Because of that, along with the importance 8  of understanding the differences among these options, we will provide clients with a written explanation of the advantages and disadvantages of each one and document the basis for our belief that the rollover transaction we recommend is in the client’s best interests. General Information on Compensation and Other Fees In certain circumstances, fees, account minimums and payment terms are negotiable depending on a client’s unique situation – such as the size of family holdings, low-cost basis securities, or certain passively advised investments and pre-existing relationships with clients. Certain clients may pay more or less than others depending on the amount of assets, type of portfolio, or the time involved, the degree of responsibility assumed, complexity of the engagement, special skills needed to solve problems, the application of experience and knowledge of the client’s situation. Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third party investment and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to our fees, and we shall not receive any portion of these commissions, fees, and costs. All fees paid to us for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds to their shareholders. These fees and expenses are described in each fund’s prospectus. These fees will generally include a management fee, other expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund directly, without our services. In that case, the client would not receive our services, which are designed, among other things, to assist the client in determining which mutual funds are most appropriate to each client’s financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and the fees charged by us to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Clients should note that similar advisory services may (or may not) be available from other registered investment advisers for similar or lower fees. 9  Item 6: Performance-Based Fees and Side-by-Side Management “Performance-based fees” are fees based on the capital gains or capital appreciation in an account. We do not charge performance-based fees. “Side-by-side management” refers to the practice of managing both accounts that are charged a performance-based fee and accounts that are charged other types of fees, such as asset-based fees and hourly fees. Because we do not charge performance-based fees, we do not engage in side-by-side management. 10  Item 7: Types of Clients Types of Clients We provide services to individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates, and corporations. Account Minimums As a condition for starting and maintaining an investment management relationship, we generally impose a minimum portfolio size of $500,000. The Firm, in its sole discretion, may waive this minimum based on the needs of the client and the complexity of the situation. In the event we accept an account with assets below its stated portfolio minimum, we may impose a minimum annual fee of $1,500 or 2% of the value of assets under management, whichever is less. 11  Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis We use fundamental analysis in formulating our investment advice and/or managing client assets. Fundamental analysis attempts to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the security. Investment Strategies Our investment strategies and advice may vary depending upon each client's specific financial situation. As such, we determine investments and allocations based upon their predefined objectives, risk tolerance, time horizon, financial information, liquidity needs and other various suitability factors. These restrictions and guidelines may affect the composition of the portfolio. It is important that clients notify us immediately with respect to any material changes to their financial circumstances, including, for example, a change in current or expected income level, tax circumstances, or employment status. Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. All investments involve the risk of loss, including (among other things) loss of principal, a reduction in earnings (including interest, dividends, and other distributions), and the loss of future earnings. Although we manage assets in a manner consistent with a client’s investment objectives and risk tolerance, there can be no guarantee that our efforts will be successful. Clients should be prepared to bear the following risks of loss: • 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 next year will not buy as much as a dollar today, because purchasing power is eroding at the rate of inflation. 12  • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. • Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties (i.e., Non-traded REITs and other alternative investments) are not. • Financial Risk: Excessive borrowing to finance a business’s 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. • Cybersecurity Risk: A breach in cyber security refers to both intentional and unintentional events that may cause an account to lose proprietary information, suffer data corruption, or lose operational capacity. This in turn could cause an account to incur regulatory penalties, reputational damage, and additional compliance costs associated with corrective measures, and/or financial loss. • Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries, and causing significant economic, social, and political disruption. • Custodial Risk: This risk is the probability that a party to a transaction will be unable or unwilling to fulfill its contractual obligations either due to technological errors, control failures, malfeasance, or potential regulatory liabilities. 13  Item 9: Disciplinary Information We are required to disclose all pertinent facts regarding any legal, regulatory, or disciplinary events that would be material to an evaluation of the Firm or the integrity of our management. There have never been any legal, regulatory, or disciplinary actions against the Firm or our management persons. 14  Item 10: Other Financial Industry Activities and Affiliations Financial Industry Activities We are not registered as a broker-dealer. We are not registered and do not have an application pending as a securities broker-dealer, futures commission merchant, commodity pool operator or commodity trading advisor. We do not have arrangements that are material to our business and clients and investors with a related person who is a broker-dealer, investment company, other investment adviser, financial planning firm, commodity pool operator, commodity trading adviser, futures commission merchant, bank or thrift institution, accounting firm, law firm, insurance company or agency, pension consultant, real estate broker or dealer, or an entity that creates or packages limited liability companies. Other Investment Advisers As described in Item 4, we may select other investment advisers for our clients. 15  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Our employees must comply with a Code of Ethics and Statement for Insider Trading (the “Code”). The Code describes our high standard of business conduct, and fiduciary duty to our clients. The Code’s key provisions include: • Statement of General Principles • Policy on and reporting of personal securities transactions • A prohibition on insider trading • Restrictions on the acceptance of significant gifts • Procedures to detect and deter misconduct and violations • Requirement to maintain confidentiality of client information Our employees must acknowledge the terms of the Code at least annually, and any employee not in compliance with the Code may be subject to termination. We will provide a copy of our Code upon request. Participation or Interest in Client Transactions – Personal Securities Transactions Both the Firm and our employees may buy or sell securities identical to those recommended to clients for their personal accounts. The Code, described above, is designed to assure that the personal securities transactions, activities, and interests of the employees of the Firm will not interfere with (i) making decisions in the best interest of clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code certain classes of securities, primarily mutual funds, have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of our clients. In addition, the Code requires pre-clearance of many transactions. Nonetheless, because the Code in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. The Firm may maintain a list of restricted securities that employees may not purchase or sell based upon having (or possibly having) access to inside information. Employee trading is continually monitored under the Code and designed to reasonably prevent conflicts of interest between the Firm and our clients. Participation or Interest in Client Transactions and Principal/Agency Cross Trades We do not recommend any securities to our clients in which we have a material financial interest. We do not effect any principal or agency cross securities transactions for client accounts. We also do not cross trades between client accounts. Participation or Interest in Client Transactions – Aggregation Neither we nor our employees aggregate (block) trades with clients. 16  Item 12: Brokerage Practices Research and Other Soft Dollar Benefits We have no written or verbal arrangements whereby we receive soft dollars. Brokerage for Client Referrals We do not receive client referrals from broker/dealers. Client Directed Brokerage We allow directed brokerage accounts. Directed Brokerage We generally recommend Raymond James & Associates, Inc., a member of FINRA/SIPC and New York Stock Exchange, an independent and unaffiliated broker-dealer (“RJ”). RJ provides us with access to its institutional trading and custody services, which are typically not available to retail investors. These services generally are available to independent investment advisors on an unsolicited basis and are not otherwise contingent upon our commitment to RJ for any specific amount of business (assets in custody or trading). RJ’s services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For our client accounts maintained there, RJ is compensated through commissions or other transaction-related fees for securities trades that are executed through them or that settle into RJ accounts. The brokerage commissions and/or transaction fees charged by RJ are exclusive of and in addition to our fees. We do not earn or share in any commissions or other transaction- related fees. Directed Brokerage – Other Economic Benefits We may receive from RJ, at no cost to us, professional services, computer software and related systems support, enabling us to better monitor client accounts maintained at RJ. We may receive this support without cost because of the portfolio management services rendered to clients who maintain assets at RJ. The support provided may benefit us, but not our clients directly. In fulfilling our duties to our clients, we endeavor at all times to put the interests of our clients first. Clients should be aware, however, that our receipt of economic benefits from a broker-dealer may create a conflict of interest since these benefits may influence our choice of broker-dealer over another broker-dealer that does not furnish similar services, software, and systems support. The transaction charges paid by our clients shall comply with our duty to obtain “best execution.” However, a client may pay a transaction charge that is higher than another qualified broker-dealer might charge to effect the same transaction where we determine, in good faith, that the commission is reasonable in relation to the value of the brokerage and 17  research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including among others, the value of research provided, execution capability, commission rates, and responsiveness. Consistent with the foregoing, while we will seek competitive rates, we may not necessarily obtain the lowest possible transaction charges for client transactions. RJ also makes available to us other products and services that benefit us but may not directly benefit our clients’ accounts. Many of these products and services may be used to service all or some substantial number of our accounts, including accounts not maintained at RJ. RJ’s products and services that assist us in managing and administering clients’ accounts include software and other technology that (i) provide access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of our fees from our clients’ accounts; and (v) assist with back-office functions, recordkeeping and client reporting. Trade Aggregation We may aggregate trades for multiple accounts. Trade aggregation is the act of trading a large block of a security in a single order. Shares of a purchased security are then allocated to the appropriate accounts in the appropriate proportion. The main purposes of order aggregation are (i) for ease of trading and (ii) to obtain a lower transaction cost associated with trading a larger quantity. Orders for the same security entered on behalf of more than one client may be aggregated (i.e., blocked or bunched), subject to the aggregation being in the best interests of all participating clients. If the order is filled at different prices during the day, the prices are averaged for the day so that all participating accounts receive the same price. If an order has not been filled completely so that there are not enough shares to allocate among all the clients equally, shares will be allocated in good faith, based on the following considerations: amount of cash in the account, existing asset allocation and industry exposure, risk profile, and type of security. If a partial execution is attained at the end of the trading day, we will generally allocate shares on a pro rata basis but may fill small orders entirely before applying the pro rata allocation. All clients participating in each aggregated order shall receive the average price and subject to minimum ticket charges, pay a pro-rata portion of commissions. Our allocation procedure seeks to be fair and equitable to all clients with no particular group or client(s) being favored or disfavored over any other clients. Accounts for us or our employees will not be included in a block trade with client accounts. 18  Item 13: Review of Accounts Reviews We monitor client portfolios as part of an ongoing process, and regular account reviews are generally conducted on a quarterly basis. Reviews could also occur at the time of new deposits, material changes in the client’s financial information, changes in economic cycles, at our discretion or as often as the client directs. Reviews entail analyzing securities, sensitivity to overall markets, economic changes, investment results, asset allocation, etc., to ensure the investment strategy and expectations are structured to continue to meet the client’s objectives. These reviews are conducted by one of our Investment Advisor Representatives. Clients are encouraged to discuss their needs, goals, and objectives with us and to inform us of any changes. Reporting At least quarterly, the custodian provides clients with an account statement for each client account, which may include individual holdings, cost basis information, deposits and withdrawals, accrued income, dividends, and performance. We may also provide clients with periodic reports regarding their holdings, allocations, and performance. Financial Planning – Reviews and Reporting The initial financial plan is included as a component of the financial planning service. Clients may receive updated financial plans for a separate fee. 19  Item 14: Client Referrals and Other Compensation Other Compensation – Brokerage Arrangements See disclosure in Item 12 regarding compensation, including economic benefits received in connection with giving advice to clients. Compensation – Client Referrals We have 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. We do not compensate referring parties for these referrals. 20  Item 15: Custody Custody – Fee Debiting Clients may authorize us (in the client agreement) to debit fees directly from their account at the broker dealer, bank, or other qualified custodian (“custodian”). The custodian is advised in writing of the limitation of our access to the account. The custodian sends a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of advisory fees paid directly to the Firm. Custody – Account Statements Clients receive at least quarterly statements from the custodian that holds and maintains client’s investment assets. Clients are urged to carefully review such statements and compare such official custodial records to the reports that we may provide. Our reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. 21  Item 16: Investment Discretion We may accept limited power of attorney to act on a discretionary basis on behalf of clients. A limited power of attorney allows us to execute trades on behalf of clients. When such limited powers exist between the Firm and the client, we have the authority to determine, without obtaining specific client consent, both the amount and type of securities to be bought to satisfy client account objectives. 22  Item 17: Voting Client Securities Proxy Voting We do not have any authority to and do not vote proxies on behalf of clients, nor do we make any express or implied recommendation with respect to voting proxies. Clients retain the sole responsibility for receiving and voting proxies that they receive directly from either their custodian or transfer agents. Clients may contact us for information about proxy voting. 23  Item 18: Financial Information We have no financial commitments that impair our ability to meet contractual and fiduciary commitments to clients and we have not been the subject of a bankruptcy proceeding. We do not require prepayment of fees of both more than $1,200 per client, and more than six months in advance; and therefore, we are not required to provide a balance sheet to clients. We have not ever filed a bankruptcy petition. 24  Form ADV Part 2B – Investment Advisor Brochure Supplement Flying Point Financial, Inc. Form ADV Part 2B Investment Advisor Brochure Supplement 855 Turnpike Street North Andover, MA 01845 (978) 975-3000 www.flyingpointfinancial.com Kevin J. Kennedy February 2026 This Brochure provides information about the qualifications and business practices of Flying Point Financial, Inc. (“we,” “us,” “our”). If you have any questions about the contents of this Brochure, please contact Amy E. Mastromonaco, Director of Operations and Chief Compliance Officer, at (978) 975-3000 or info@flyingpointfinancial.com. Additional information about our employee(s) referenced above is also available on the SEC’s website at www.adviserinfo.sec.gov. You may search this site using a unique identifying number, known as a CRD number for each employee. 25  Item 2: Educational Background and Business Experience We require that advisers 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 designation. Additionally, advisers must have work experience that demonstrates their aptitude for financial planning and investment management. Born 1972 Kevin J. Kennedy CRD# 4421611 2001 to Present Business Background: Flying Point Financial, Inc. President Formal Education after High School: Boston University Master of Physical Therapy Boston University Bachelor of Science in Health Science Boston University Program for Financial Planners Item 3: Disciplinary Information Kevin J. Kennedy has never been involved in any activities resulting in a disciplinary disclosure. Item 4: Other Business Activities Kevin J. Kennedy does not have any outside business activities. Item 5: Additional Compensation Kevin J. Kennedy does not receive any economic benefit outside of regular salaries or bonuses related to amount of sales, client referrals or new accounts. Item 6: Supervision Amy E. Mastromonaco, Director of Operations and Chief Compliance Officer, supervises all persons named in this Form ADV Part 2B Investment Advisor Brochure Supplement. Amy E. Mastromonaco supervises these persons by holding regular staff, investment, and other ad hoc meetings. In addition, Amy E. Mastromonaco regularly reviews client reports, emails, and 26  trading, as well as employees’ personal securities transaction and holdings reports. She may be reached at (978) 975-3000 or info@flyingpointfinancial.com. 27  Form ADV Part 2B – Investment Advisor Brochure Supplement Flying Point Financial, Inc. Form ADV Part 2B Investment Advisor Brochure Supplement 855 Turnpike Street North Andover, MA 01845 (978) 975-3000 www.flyingpointfinancial.com Amy E. Mastromonaco February 2026 This Brochure provides information about the qualifications and business practices of Flying Point Financial, Inc. (“we,” “us,” “our”). If you have any questions about the contents of this Brochure, please contact Amy E. Mastromonaco, Director of Operations and Chief Compliance Officer, at (978) 975-3000 or info@flyingpointfinancial.com. Additional information about our employee(s) referenced above is also available on the SEC’s website at www.adviserinfo.sec.gov. You may search this site using a unique identifying number, known as a CRD number for each employee. 28  Item 2: Educational Background and Business Experience We require that advisers 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 designation. Additionally, advisers must have work experience that demonstrates their aptitude for financial planning and investment management. Born 1972 Amy E. Mastromonaco CRD# 2740891 1998 to Present Business Background: Flying Point Financial, Inc. Director of Operations and Chief Compliance Officer Formal Education after High School: Boston University Bachelor of Science in Business Administration Item 3: Disciplinary Information Amy E. Mastromonaco has never been involved in any activities resulting in a disciplinary disclosure. Item 4: Other Business Activities Amy E. Mastromonaco does not have any outside business activities. Item 5: Additional Compensation Amy E. Mastromonaco does not receive any economic benefit outside of regular salaries or bonuses related to amount of sales, client referrals or new accounts. Item 6: Supervision Amy E. Mastromonaco, Director of Operations and Chief Compliance Officer, supervises all persons named in this Form ADV Part 2B Investment Advisor Brochure Supplement. Amy E. Mastromonaco supervises these persons by holding regular staff, investment, and other ad hoc meetings. In addition, Amy E. Mastromonaco regularly reviews client reports, emails, and trading, as well as employees’ personal securities transaction and holdings reports. She may be reached at (978) 975-3000 or info@flyingpointfinancial.com. 29  Form ADV Part 2B – Investment Advisor Brochure Supplement Flying Point Financial, Inc. Form ADV Part 2B Investment Advisor Brochure Supplement 855 Turnpike Street North Andover, MA 01845 (978) 975-3000 www.flyingpointfinancial.com Elaine B. Morgillo February 2026 This Brochure provides information about the qualifications and business practices of Flying Point Financial, Inc. (“we,” “us,” “our”). If you have any questions about the contents of this Brochure, please contact Amy E. Mastromonaco, Director of Operations and Chief Compliance Officer, at (978) 975-3000 or info@flyingpointfinancial.com. Additional information about our employee(s) referenced above is also available on the SEC’s website at www.adviserinfo.sec.gov. You may search this site using a unique identifying number, known as a CRD number for each employee. 30  Item 2: Educational Background and Business Experience We require that advisers 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 designation. Additionally, advisers must have work experience that demonstrates their aptitude for financial planning and investment management. Born 1948 Elaine B. Morgillo CRD# 1578345 1998 to Present Business Background: Flying Point Financial, Inc. Founder Formal Education after High School: Albertus Magnus College Bachelor of Arts in Psychology Georgia State University Graduate School of Business Coursework in Accounting and Finance The College For Financial Planning Certified Financial Planner Certification Program Professional Designations: CERTIFIED FINANCIAL PLANNER™ (CFP®) Professional Certifications Elaine B. Morgillo maintains a professional designation, which requires the following minimum requirements: CERTIFIED FINANCIAL PLANNER™ (CFP®) Issued By Certified Financial Planner Board of Standards, Inc. Candidate must meet the following requirements: • A bachelor’s degree (or higher) from an accredited college Prerequisites or university, and • 3 years of full-time personal financial planning experience ndidate must complete a CFP®-board registered program, or hold one of the following designations: Education Requirements • CPA • ChFC® • Chartered Life Underwriter® (CLU®) 31  • CFA® • Ph.D. in business or economics • Doctor of Business Administration • Attorney's License CFP® Certification Examination 30 hours every 2 years Exam Type Continuing Education Requirements Item 3: Disciplinary Information Elaine B. Morgillo has never been involved in any activities resulting in a disciplinary disclosure. Item 4: Other Business Activities Elaine B. Morgillo owns a real estate property management company. This outside business activity does not create a conflict of interest with clients. Item 5: Additional Compensation Elaine B. Morgillo does not receive any economic benefit outside of regular salaries or bonuses related to amount of sales, client referrals or new accounts. Item 6: Supervision Amy E. Mastromonaco, Director of Operations and Chief Compliance Officer, supervises all persons named in this Form ADV Part 2B Investment Advisor Brochure Supplement. Amy E. Mastromonaco supervises these persons by holding regular staff, investment, and other ad hoc meetings. In addition, Amy E. Mastromonaco regularly reviews client reports, emails, and trading, as well as employees’ personal securities transaction and holdings reports. She may be reached at (978) 975-3000 or info@flyingpointfinancial.com. 32