Overview

Assets Under Management: $147 million
Headquarters: BENTONVILLE, AR
High-Net-Worth Clients: 38
Average Client Assets: $3 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals

Fee Structure

Primary Fee Schedule (ADV PART 2A)

MinMaxMarginal Fee Rate
$0 $250,000 1.50%
$250,001 $1,000,000 1.25%
$1,000,001 and above 1.00%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $13,125 1.31%
$5 million $53,125 1.06%
$10 million $103,125 1.03%
$50 million $503,125 1.01%
$100 million $1,003,125 1.00%

Clients

Number of High-Net-Worth Clients: 38
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 87.99
Average High-Net-Worth Client Assets: $3 million
Total Client Accounts: 147
Discretionary Accounts: 145
Non-Discretionary Accounts: 2

Regulatory Filings

CRD Number: 157712
Last Filing Date: 2025-01-24 00:00:00
Website: https://4318advisors.com

Form ADV Documents

Primary Brochure: ADV PART 2A (2025-05-08)

View Document Text
Forty Three Eighteen Advisors, LLC Firm Brochure This brochure provides information about the qualifications and business practices of Forty Three Eighteen Advisors, LLC. If you have any questions about the contents of this brochure, please contact us at (479) 254-9400 or by email at: mparks@4318advisors.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Forty Three Eighteen Advisors, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Forty Three Eighteen Advisors, LLC ’s CRD number is: 157712 1202 NE McClain Rd., Bentonville, AR 72712 (479) 254-9400 mparks@4318advisors.com Registration does not imply a certain level of skill or training. Version Date: 05/08/2025 Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of Forty Three Eighteen Advisors, LLC on 02/19/2024 are described below. Material changes relate to Forty Three Eighteen Advisors, LLC’s policies, practices or conflicts of interests. • Forty Three Eighteen Advisors, LLC has updated its Voting Client Securities (Proxy Voting). (Item 17) • Forty Three Eighteen Advisors, LLC has transitioned to registration with the United States Securities and Exchange Commission from its prior registration at the state level. i Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ............................................................................................................................................................................... i Item 3: Table of Contents .............................................................................................................................................................................. ii Item 4: Advisory Business ............................................................................................................................................................................ 1 A. Description of the Advisory Firm ...................................................................................................................................................... 1 B. Types of Advisory Services ................................................................................................................................................................. 1 C. Client Tailored Services and Client Imposed Restrictions .............................................................................................................. 2 D. Wrap Fee Programs ............................................................................................................................................................................. 2 E. Amounts Under Management ............................................................................................................................................................ 2 Item 5: Fees and Compensation ................................................................................................................................................................... 2 A. Fee Schedule ......................................................................................................................................................................................... 2 B. Payment of Fees .................................................................................................................................................................................... 4 Payment of Investment Supervisory Fees ......................................................................................................................................... 4 Payment of Performance Based Fees ................................................................................................................................................. 4 Payment of Financial Planning Fees .................................................................................................................................................. 4 C. Clients Are Responsible For Third Party Fees .................................................................................................................................. 4 D. Prepayment of Fees.............................................................................................................................................................................. 4 E. Outside Compensation For the Sale of Securities to Clients ........................................................................................................... 5 Item 6: Performance-Based Fees and Side-By-Side Management ........................................................................................................... 5 Item 7: Types of Clients ................................................................................................................................................................................. 5 Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss .............................................................................. 6 A. Methods of Analysis and Investment Strategies.............................................................................................................................. 6 Methods of Analysis ............................................................................................................................................................................ 6 Charting analysis.................................................................................................................................................................................. 6 Fundamental analysis .......................................................................................................................................................................... 6 Technical analysis ................................................................................................................................................................................ 6 Investment Strategies........................................................................................................................................................................... 6 B. Material Risks Involved ....................................................................................................................................................................... 6 Methods of Analysis ............................................................................................................................................................................ 6 Fundamental analysis .......................................................................................................................................................................... 6 Technical analysis ................................................................................................................................................................................ 6 Investment Strategies........................................................................................................................................................................... 7 C. Risks of Specific Securities Utilized ................................................................................................................................................... 7 Item 9: Disciplinary Information ................................................................................................................................................................. 7 ii A. Criminal or Civil Actions .................................................................................................................................................................... 7 B. Administrative Proceedings ................................................................................................................................................................ 7 C. Self-regulatory Organization (SR) Proceedings ............................................................................................................................... 7 Item 10: Other Financial Industry Activities and Affiliations .................................................................................................................. 7 A. Registration as a Broker/Dealer or Broker/Dealer Representative .............................................................................................. 7 B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor ............... 8 C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests ......................................... 8 D. Selection of Other Advisors or Managers and How This Adviser is Compensated for Those Selections ............................... 8 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................................................ 8 A. Code of Ethics ....................................................................................................................................................................................... 8 B. Recommendations Involving Material Financial Interests.............................................................................................................. 8 C. Investing Personal Money in the Same Securities as Clients.......................................................................................................... 9 D. Trading Securities At/Around the Same Time as Clients’ Securities ........................................................................................... 9 Item 12: Brokerage Practices ......................................................................................................................................................................... 9 A. Factors Used to Select Custodians and/or Broker/Dealers ........................................................................................................... 9 1. Research and Other Soft-Dollar Benefits ....................................................................................................................................... 9 2. Brokerage for Client Referrals ........................................................................................................................................................ 9 3. Clients Directing Which Broker/Dealer/Custodian to Use ..................................................................................................... 10 B. Aggregating (Block) Trading for Multiple Client Accounts ......................................................................................................... 10 Item 13: Reviews of Accounts .................................................................................................................................................................... 10 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews .......................................................................... 10 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts ........................................................................................ 10 C. Content and Frequency of Regular Reports Provided to Clients................................................................................................. 10 Item 14: Client Referrals and Other Compensation ................................................................................................................................ 11 A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) .. 11 B. Compensation to Non – Advisory Personnel for Client Referrals ............................................................................................... 11 Item 15: Custody .......................................................................................................................................................................................... 11 Item 16: Investment Discretion .................................................................................................................................................................. 11 Item 17: Voting Client Securities (Proxy Voting) ..................................................................................................................................... 11 Item 18: Financial Information ................................................................................................................................................................... 12 A. Balance Sheet ...................................................................................................................................................................................... 12 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ........................... 12 C. Bankruptcy Petitions in Previous Ten Years .................................................................................................................................. 12 iii Item 4: Advisory Business A. Description of the Advisory Firm Forty Three Eighteen Advisors, LLC is a Limited Liability Company organized in the state of Arkansas. This firm has been in business since April 2011, and the principal owner is Jack Melton Parks, Jr. B. Types of Advisory Services Forty Three Eighteen Advisors, LLC (hereinafter “FTEA”) offers the following services to advisory clients: Investment Supervisory Services FTEA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. FTEA creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan (the Investment Policy Statement) to aid in the selection of a portfolio that matches each client’s specific situation. Investment Supervisory Services include, but are not limited to, the following: • • • Investment strategy • Personal investment policy Asset allocation Risk tolerance • • Asset selection Regular portfolio monitoring FTEA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. FTEA will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Performance Based Fees Qualified clients may be charged a performance-based fee based on net profits above an agreed upon benchmark. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning, tax concerns; retirement planning; college planning; and debit/credit planning. These services are based on hourly fees and the final fee structure is documented in Exhibit II of the Financial Planning Agreement. 1 Services Limited to Specific Types of Investments FTEA generally limits its investment advice and/or money management to mutual funds, equities, bonds, fixed income, debt securities, ETFs, real estate, REITs, and government securities. FTEA may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions FTEA offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent FTEA from properly servicing the client account, or if the restrictions would require FTEA to deviate from its standard suite of services, FTEA reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. FTEA DOES NOT participate in any wrap fee programs. E. Amounts Under Management FTEA has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 143,853,814.00 $ 2,706,742.00 December 2024 Item 5: Fees and Compensation A. Fee Schedule Investment Supervisory Services Fees Total Assets Under Management Annual Fee $1 - $250,000 1.50% 2 Total Assets Under Management Annual Fee $250,001 - $1,000,000 1.25% Above $1,000,000 1.00% These fees are negotiable depending upon the needs of the client and complexity of the situation, and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Fees are paid quarterly in advance, and clients may terminate their contracts with thirty days’ written notice. Refunds are given on a prorated basis, based on the number of days remaining in a quarter at the point of termination. Fees that are collected in advance will be refunded based on the prorated amount of work completed up to the day of termination within the quarter terminated. The fee refunded will be the balance of the fees collected in advance minus the daily rate* times the number of days in the quarter up to and including the day of termination. (*The daily rate is calculated by dividing the quarterly AUM fee by the number of days in the termination quarter). Clients may terminate their contracts without penalty, for full refund, within 5 business days of signing the advisory contract. Advisory fees are withdrawn directly from the client’s accounts with client written authorization. Performance Based Fees Qualified clients may be charged a performance-based fee. There is a minimum annual fee of 0.25% on all assets under management and a performance-based fee of 35% above a benchmark as agreed upon between FTEA and client. After the first year, the performance fee is paid quarterly in arrears based on the performance during the preceding twelve months. The fees are negotiable and the final fee schedule and agreed upon benchmark will be attached as Exhibit II of the Investment Advisory Contract. Financial Planning Fees Hourly Fees Depending upon the complexity of the situation and the needs of the client, the hourly fee for these services is $150 - $200. The fees are negotiable and the final fee schedule will be attached as Exhibit II of the Financial Planning Agreement. Fees are paid in advance based on the estimated number of required hours, but never more than six months in advance. Fees that are charged in advance will be refunded based on the prorated amount of work completed at the point of termination. Clients may terminate their contracts without penalty within five business days of signing the advisory contract. The fee refunded will be the balance of the fees collected in advance minus the hourly rate times the number of hours of work that has been completed up to and including the day of termination. 3 B. Payment of Fees Payment of Investment Supervisory Fees Advisory fees are withdrawn directly from the client’s accounts with client written authorization. Fees are paid quarterly in advance. Advisory fees may also be invoiced and billed directly to the client quarterly in advance. Payments are due within thirty days from billing. Clients may select the method in which they are billed. Payment of Performance Based Fees Performance based fees are withdrawn directly from the client’s accounts with client written authorization. Fees are paid quarterly in arrears. Payment of Financial Planning Fees Hourly Financial Planning fees are paid via check in advance, but never more than six months in advance. Fees that are charged in advance will be refunded based on the prorated amount of work completed at the point of termination. C. Clients Are Responsible for Third Party Fees Clients are responsible for the payment of all third-party fees (i.e. custodian fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by FTEA. Please see Item 12 of this brochure regarding broker/custodian. D. Prepayment of Fees FTEA collects fees in advance and arrears. Fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination and the total days during the billing period. Fees will be returned within fourteen days to the client via check. The fee refunded will be the balance of the fees collected in advance minus the daily rate* times the number of days in the quarter up to and including the day of termination. (*The daily rate is calculated by dividing the quarterly AUM fee by the number of days in the termination quarter). 4 E. Outside Compensation for the Sale of Securities to Clients Neither FTEA nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or services fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management Qualified clients may be charged a performance-based fee. There is a minimum annual fee of 0.25% on all assets under management and a performance-based fee of 35% above a benchmark as agreed upon between FTEA and client. Fees are paid quarterly in arrears. FTEA manages accounts that are billed on performance-based fees (a share of capital gains on or capital appreciation of the assets of a client) as well as accounts that are NOT billed on performance-based fees. Managing both kinds of accounts at the same time presents a conflict of interest because FTEA or its supervised persons have an incentive to favor accounts for which FTEA and its supervised persons receive a performance-based fee. FTEA addresses the conflicts by ensuring that clients who have performance-based accounts do not receive preferential treatment. FTEA provides best execution practices and upholds its fiduciary duty for all clients. Clients that are paying a performance-based fee should be aware that investment advisors have an incentive to invest in riskier investments when paid a performance-based fee due to the higher risk/higher reward attributes. In some cases, FTEA may receive increased compensation with regard to unrealized appreciation as well as realized gains in the client’s account. Item 7: Types of Clients FTEA generally provides investment advice and/or management supervisory services to the following types of clients:  Individuals  High-Net-Worth Individuals  Charitable Organizations Minimum Account Size There is no account minimum. 5 Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss A. Methods of Analysis and Investment Strategies Methods of Analysis FTEA’s methods of analysis include charting analysis, fundamental analysis, and technical analysis. Charting analysis involves the use of patterns in performance charts. FTEA uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Technical analysis involves the analysis of past market data; primarily price and volume. Investment Strategies FTEA uses long term and short-term trading strategies. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Charting analysis strategy involves using and comparing various charts to predict long and short-term performance or market trends. The risk involved in solely using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not work long term. 6 Investment Strategies Long term trading is designed to capture market rates of both return and risk. Frequent trading, when done, can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Short term trading generally holds greater risk and clients should be aware that there is a material risk of loss using any of those strategies. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized FTEA generally seeks investment strategies that do not involve significant or unusual risk beyond that of the general domestic and/or international equity markets. However, FTEA also charges performance-based fees which would create an incentive to invest in riskier investments due to the higher risk/higher reward attributes. Past performance is not a guarantee of future returns. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SR) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither FTEA nor its representatives are registered as or have pending applications to become a broker/dealer or as representatives of a broker/dealer. 7 B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither FTEA nor its representatives are registered as or have pending applications to become a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Neither FTEA nor its representatives have any material relationships to this advisory business that would present a possible conflict of interest. D. Selection of Other Advisors or Managers and How This Adviser is Compensated for Those Selections FTEA does not utilize nor select other advisors or third-party managers. All assets are managed by FTEA management. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics We have a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. Our Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests FTEA does not recommend that clients buy or sell any security in which a related person to FTEA or FTEA has a material financial interest. 8 C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of FTEA may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of FTEA to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. FTEA will always document any transactions that could be construed as conflicts of interest and will always transact client business before their own when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of FTEA may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of FTEA to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. FTEA will always transact client’s transactions before its own when similar securities are being bought or sold. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers The Custodian Schwab Institutional, a division of Charles Schwab & Co., Inc., was chosen based on their relatively low transaction fees and access to mutual funds and ETFs. FTEA will never charge a premium or commission on transactions, beyond the actual cost imposed by Custodian. 1. Research and Other Soft-Dollar Benefits FTEA receives research, products, or services other from its broker-dealer or another third-party in connection with client securities transactions (“soft dollar benefits”). There is no minimum client number or dollar number that FTEA must meet in order to receive free research from the custodian or broker/dealer. There is no incentive for FTEA to direct clients to this particular broker-dealer over other broker-dealers who offer the same services. The first consideration when recommending broker/dealers to clients is best execution. 2. Brokerage for Client Referrals FTEA receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 9 3. Clients Directing Which Broker/Dealer/Custodian to Use FTEA allows clients to direct brokerage. FTEA may be unable to achieve most favorable execution of client transactions if clients choose to direct brokerage. This may cost clients’ money because without the ability to direct brokerage FTEA may not be able to aggregate orders to reduce transactions costs resulting in higher brokerage commissions and less favorable prices. Not all investment advisers allow their clients to direct brokerage. B. Aggregating (Block) Trading for Multiple Client Accounts FTEA maintains the ability to block trade purchases across accounts. Block trading may benefit a large group of clients by providing FTEA the ability to purchase larger blocks resulting in smaller transaction costs to the client. Declining to block trade can cause more expensive trades for clients. Item 13: Reviews of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews Client accounts are reviewed at least annually by Jack Melton Parks, Jr., Managing Member. Jack Melton Parks, Jr. is the chief advisor and is instructed to review clients’ accounts with regards to their investment policies and risk tolerance levels. All accounts at FTEA are assigned to this reviewer. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Jack Melton Parks, Jr. , Managing Member. There is only one level of review and that is the total review conducted to create the financial plan. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client will receive at least quarterly from the custodian, a written report that details the client’s account including assets held and asset value which will come from the custodian. 10 Clients are provided a one-time financial plan concerning their financial situation. After the presentation of the plan, there are no further reports. Clients may request additional plans or reports for a fee. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) FTEA does not receive any economic benefit, directly or indirectly from any third party for advice rendered to FTEA clients. B. Compensation to Non – Advisory Personnel for Client Referrals FTEA does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody FTEA, with Client’s written authority, has limited custody of client’s assets through direct fee deduction of FTEA’s Fees only. Constructive custody of all client’s assets and holdings is maintained primarily at the Schwab Institutional, a division of Charles Schwab & Co., Inc. Clients will receive all required account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Item 16: Investment Discretion For those client accounts where FTEA provides ongoing supervision, the client has given FTEA written discretionary authority over the client’s accounts with respect to securities to be bought or sold and the amount of securities to be bought or sold. Details of this relationship are fully disclosed to the client before any advisory relationship has commenced. The client provides FTEA discretionary authority via a limited power of attorney in the Investment Advisory Contract and in the contract between the client and the custodian. Item 17: Voting Client Securities (Proxy Voting) FTEA accepts the authority to vote client securities, in accordance with Rule 206(4)-6 of the Investment Advisers Act of 1940, unless clients notify FTEA of their preference to vote directly. FTEA has adopted and implemented written proxy voting policies and procedures that are reasonably designed to ensure proxies are voted in the best interest of its clients. These procedures are described below and are available to clients upon request. 11 FTEA votes client proxies solely in the best interest of clients and their beneficiaries. FTEA utilizes the Voting Guidelines of an independent proxy advisory firm, Broadridge, which reviews and votes proxies based on these established guidelines. These guidelines are designed to address common proxy matters and ensure a consistent, client-focused approach. When FTEA has implemented a client-provided voting policy, that policy will take precedence, even if it conflicts with FTEA’s own guidelines. Clients may direct FTEA’s proxy voting by providing a written proxy voting policy. When a client provides such a policy, FTEA will vote in accordance with the client’s instructions. However, in some instances—such as nominee voting restrictions—it may not be feasible for FTEA to participate in certain votes. FTEA is committed to avoiding conflicts of interest in the proxy voting process. When a conflict arises, FTEA will adhere to the Voting Guidelines or, where the guideline indicates a “case-by- case” decision, defer to Broadridge’s recommendation. FTEA conducts oversight of Broadridge to ensure voting recommendations are based on current, accurate, and complete information, and that any potential conflicts of interest within the Broadridge are properly addressed and disclosed. Clients may obtain information from FTEA regarding how their proxies were voted by submitting a request. This transparency ensures that clients remain informed and can evaluate FTEA’s adherence to its voting obligations. Clients may request a copy of FTEA’s Proxy Voting Policy Policies and Procedures at any time. Item 18: Financial Information A. Balance Sheet FTEA does not require nor solicit prepayment of more than $ 1200 in fees per client, six months or more in advance and therefore does not need to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither FTEA nor its management have any financial conditions that are likely to reasonably impair our ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years FTEA has not been the subject of a bankruptcy petition in the last ten years. 12