FORUM PRIVATE CLIENT GROUP

Item 1: Cover Page Item 1: Cover Page Part 2A of Form ADV Firm Brochure February 19, 2026 FORUM Solutions Group, LLC dba FORUM Private Client Group SEC File No. 801-78874 11313 USA Parkway Fishers, Indiana 46037 phone: 317-558-6322 email: pcg@forumcu.com website: www.forumcu.com/wealth-management This brochure provides information about the qualifications and business practices of FORUM Private Client Group. If you have any questions about the contents of this brochure, please contact Jim Carr at 317-558-6322. 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. Registration with the SEC or state regulatory authority does not imply a certain level of skill or expertise. Additional information about FORUM Private Client Group is also available on the SEC’s website at www.adviserinfo.sec.gov. Page 1  Item 2: Material Changes Item 2: Material Changes This Firm Brochure is our disclosure document prepared according to regulatory requirements and rules. Consistent with the rules, we will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business fiscal year. Furthermore, we will provide you with other interim disclosures about material changes as necessary. The firm made the following material change from the last annual update of this Brochure issued in March 2025: ▪ As part of its portfolio management services, FORUM may recommend one or more third-party sub-advisers to manage all or a portion of the client's investment portfolio. Please see Item 4 of this Brochure for a description of services and Item 5 for fees. Page 2  Item 3: Table of Contents 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 ............................................................................................................................ 7 Item 6: Performance-Based Fees and Side-by-Side Management ......................................................... 11 Item 7: Types of Clients ........................................................................................................................................... 12 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ................................................. 13 Item 9: Disciplinary Information ........................................................................................................................... 23 Item 10: Other Financial Industry Activities and Affiliations ........................................................................ 24 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................................................................................................................................................... 25 Item 12: Brokerage Practices ................................................................................................................................... 27 Item 13: Review of Accounts ................................................................................................................................... 32 Item 14: Client Referrals and Other Compensation ........................................................................................ 33 Item 15: Custody .......................................................................................................................................................... 34 Item 16: Investment Discretion ............................................................................................................................... 35 Item 17: Voting Client Securities ............................................................................................................................ 36 Item 18: Financial Information ................................................................................................................................ 37 Page 3  Item 4: Advisory Business Item 4: Advisory Business A. Ownership/Advisory History FORUM Solutions Group, LLC, dba FORUM Private Client Group (“FORUM” or the “firm”) is an Indiana limited liability company. FORUM has been in business since 2007. FORUM Credit Union is the principal owner of FORUM. B. Advisory Services Offered FORUM provides financial planning, consulting, and wealth management services. Prior to engaging FORUM to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with FORUM setting forth the terms and conditions under which FORUM renders its services. Wealth Management Services Clients can engage FORUM to manage all or a portion of their assets on a discretionary or non- discretionary basis. In addition, as part of its wealth management services, FORUM will develop a comprehensive financial plan which takes into consideration investments, insurance, retirement, education, estate planning, and tax and cash flow needs of the client. FORUM primarily allocates clients’ investment management assets among mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities in accordance with the investment objectives of the client. FORUM also provides advice about any type of investment held in clients' portfolios. FORUM also may render discretionary or non-discretionary investment management services to clients relative to variable life/annuity products that they may own, their individual employer-sponsored retirement plans, and/or 529 plans or other products that may not be held by the client’s primary custodian. In so doing, FORUM either directs or recommends the allocation of client assets among the various investment options that are available with the product. Client assets are maintained at the specific insurance company or custodian designated by the product. Clients have the right to provide the firm with any reasonable investment restrictions on the management of their portfolio, which must be in writing and sent to the firm. Clients should promptly notify the firm in writing of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals and tolerance for risk. FORUM will remind clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the client’s account. FORUM will also contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives and tolerance for risk. Retirement Rollovers – Conflicts and Added Fees. Plan participants may be paying little or nothing for the plan’s investment services. As such, investment management costs are likely to be higher when engaging an investment adviser for professional investment management. Alternative Page 4  Item 4: Advisory Business courses of action are available to the plan participant: (i) Assuming it is permitted by the Plan, you can leave your money in your current Plan. (ii) If you have changed employers, you can roll your assets into the new employer’s Plan, if permissible by your new employer. (iii) You can establish an IRA R/O and place into a commission-based account at a broker-dealer. (iv) You can establish an IRA R/O and place into a fee-based advisory account. (v) You can withdraw your retirement money and pay the taxes and any applicable penalties. Your decision to roll assets from a qualified plan to a financial professional should be determined by your need for a desired level of investment services, the associated costs, and access to a diverse range of investment products that meet your personal risk tolerance and investment objective. Selection of Other Advisers (Sub-Advisers) As part of its portfolio management services, FORUM may recommend one or more third-party sub-advisers to manage all or a portion of the client's investment portfolio. Factors taken into consideration when making recommendations include, but are not limited to, the sub-adviser’s performance, investment strategies, methods of analysis, advisory and other fees, assets under management, and the client's financial objectives and risk tolerance. FORUM would generally retain authority to hire/fire the sub-adviser and regularly monitors the performance of the sub- adviser to ensure its management and investment style remain aligned with the client's objectives and risk tolerance. FORUM has sub-advisory agreements with unaffiliated registered investment advisers and platform providers (“sub-advisers”). FORUM accesses various investment strategies made available through the sub-advisers’ investment platforms. FORUM determines which strategies the client assets are to be invested in, and thereafter sub-advisers implement all trades necessary to cause such assets to be invested in the strategies. FORUM continuously manages any sub-adviser relationship and regularly monitors the client's account(s) for performance metrics and adherence to the client's investment objectives. Each sub-adviser maintains a separate disclosure document that will be provided to the client. The client should carefully review the sub-adviser's disclosure document for information regarding fees, risks and investment strategies, and conflicts of interest. The sub-adviser’s fee will be in addition to the advisory fees charged by FORUM. Financial Planning and Consulting Services FORUM offers clients a broad range of financial planning and consulting services, which include any or all of the following: Insurance Review & Planning Investment Planning ▪ Cash Flow Forecasting ▪ Social Security Planning ▪ Education Planning ▪ Estate Planning ▪ ▪ Business Planning ▪ Retirement Planning ▪ Tax Planning ▪ Budgeting Support ▪ ▪ Risk Management ▪ Philanthropy Planning Page 5  Item 4: Advisory Business While each of these services is available on a stand-alone basis, certain of them can also be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement. Clients may elect for a limited engagement, where services are completed upon delivery of the plan or consultation, or ongoing financial planning services. In performing these services, FORUM is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. FORUM recommends certain clients engage the firm for additional related services and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the firm to recommend that clients engage FORUM or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by FORUM under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising FORUM’s recommendations and/or services. C. Client-Tailored Services and Client-Imposed Restrictions Each client’s account will be managed on the basis of the client’s financial situation and investment objectives and in accordance with any reasonable restrictions imposed by the client on the management of the account—for example, restricting the type or amount of security to be purchased in the portfolio. D. Wrap Fee Programs FORUM does not participate in wrap fee programs. (Wrap fee programs offer services for one all-inclusive fee.) E. Client Assets Under Management As of December 31, 2025, FORUM managed assets of $381,043,472 on a discretionary basis, and $22,209,301 on a non-discretionary basis. Page 6  Item 5: Fees and Compensation Item 5: Fees and Compensation A. Methods of Compensation and Fee Schedule Wealth Management & Sub-Adviser Fees FORUM’s portfolio management fee is an asset-based fee, calculated as a percentage of the value of the managed assets. The total managed account fee will include FORUM’s tiered fee as outlined in the following fee schedule (negotiable), plus a model manager and platform fee if a sub-adviser platform is utilized (sub-adviser’s fee portion is non-negotiable). Portfolio Value Annual Fee Rate Up to $250,000 $250,001 - $1,000,000 $1,000,001 - $2,500,000 Above $2,500,001 1.25% 1.00% 0.75% Negotiable FORUM has a minimum annual fee of $1,000. For portfolio values less than $80,000, clients may be able to obtain comparable services at a lower cost elsewhere. FORUM, in its sole discretion, may negotiate to charge a lesser management fee based upon certain criteria (e.g., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing client, account retention, pro bono activities, etc.). The sub-adviser’s fee is variable depending on the sub-adviser and strategy(ies) selected and may change. In consideration for such services, the sub-adviser will charge a program fee that includes the investment management fee of the strategists, the administration of the program, and trading, clearance and settlement costs. Clients are advised that FORUM has an economic incentive to recommend those strategies that yield the highest fees to FORUM. While FORUM prioritizes clients’ best interests, it is important to be aware of this conflict of interest during the construction of the client’s investment portfolio. Please ask your FORUM professional for a current list of strategies and their costs. Clients will be required to approve in writing any strategy change that results in an increased fee. Wealth management fees are subject to the investment advisory agreement between the client and FORUM, and if a sub-adviser platform is utilized, in the separate Portfolio Confirmation Form clients are required to sign prior to implementation of their portfolio. Such fees are payable quarterly in advance. If a client utilizes leverage, the firm’s fees will be billed on the net equity in the portfolio. The fees will be prorated if the investment advisory relationship commences otherwise than at the beginning of a calendar quarter. Fees are calculated on an average daily basis; as such, any contributions or withdrawals are taken into account with regard to the fee calculation. FORUM may modify the fee at any time upon 30 days’ written notice to the client. In the event the client has an ERISA-governed plan, fee modifications must be approved in writing by the client. Page 7  Item 5: Fees and Compensation Financial Planning and Consulting Fees FORUM offers financial planning and consulting services as a limited engagement or an ongoing service. Limited engagements will be billed an hourly fee ranging from $250 to $700 per hour depending on the experience of the professional providing the service, with a minimum engagement of $1,000. Clients are advised that, in consideration of the fee structure, FORUM has an economic incentive to place staff that bill at lower hourly rates on the engagement. FORUM will provide the client with an estimate of hours based upon the scope and complexity of the services. The terms and conditions of the limited financial planning and/or consulting engagement are set forth in the advisory agreement, and FORUM requires one-half of the fee (estimated hourly) payable upon execution of the advisory agreement. The outstanding balance is due upon delivery of the financial plan or completion of the agreed-upon services. For ongoing financial planning services, FORUM charges an annual fee as negotiated between the client and the firm. FORUM’s fee is determined based on the nature of the services being provided and the complexity of each client’s circumstances. The terms and conditions of the ongoing financial planning engagement are set forth in the advisory agreement, and FORUM requires a $1,000 onboarding fee payable upon execution of the advisory agreement, and the annual fee is paid quarterly in advance via ACH. Clients that have an investment management engagement with FORUM will be given the option of having their financial planning fee debited from their custodial account. B. Client Payment of Fees Wealth Management & Sub-Adviser Fees FORUM requires clients to authorize the direct debit of fees from their accounts. Exceptions may be granted subject to the firm’s consent for clients to be billed directly for our fees. For directly debited fees, the custodian’s periodic statements will show each fee deduction from the account. Clients may withdraw this authorization for direct billing of these fees at any time by notifying us or their custodian in writing. FORUM will deduct advisory fees directly from the client’s account provided that (i) the client provides written authorization, and (ii) the qualified custodian sends the client a statement, at least quarterly, indicating all amounts disbursed from the account. The client is responsible for verifying the accuracy of the fee calculation, as the client’s custodian will not verify the calculation. The agreement may be canceled at any time by the client, or by FORUM with 30 days’ prior written notice to the client. Upon termination, any unearned, prepaid fees will be promptly refunded. Page 8  Item 5: Fees and Compensation Financial Planning and Consulting Fees Financial planning fee terms are subject to the client services agreement between the client and FORUM. For prepaid fees of $1,200 or more, services will be completed within six months of the date fees are received. The agreement may be canceled at any time by the client, or by FORUM with 30 days’ prior written notice to the client. Upon termination, any unearned, prepaid fees will be promptly refunded. C. Additional Client Fees Charged All fees paid for investment advisory services are separate and distinct from the fees and expenses charged by exchange-traded funds, mutual funds, third-party sub-advisers, broker- dealers, and custodians retained by clients. Such fees and expenses are described in each exchange-traded fund and mutual fund’s prospectus, each sub-adviser’s Form ADV and Brochure and Brochure Supplement or similar disclosure statement, and by any broker-dealer or custodian retained by the client. Clients are advised to read these materials carefully before investing. If a mutual fund also imposes sales charges, a client may pay an initial or deferred sales charge as further described in the mutual fund’s prospectus. A client using FORUM may be precluded from using certain mutual funds or separate account managers because they may not be offered by the client's custodian. Please refer to the Brokerage Practices section (Item 12) for additional information regarding the firm’s brokerage practices. D. Prepayment of Client Fees FORUM generally requires fees to be prepaid on a quarterly basis. FORUM’s fees will either be paid directly by the client or disbursed to FORUM by the qualified custodian of the client’s investment accounts, subject to prior written consent of the client. The custodian will deliver directly to the client an account statement, at least quarterly, showing all investment and transaction activity for the period, including fee disbursements from the account. A client investment advisory agreement may be canceled at any time by the client, or by FORUM with 30 days’ prior written notice to the client. Upon termination, any unearned, prepaid fees will be promptly refunded. The client has the right to terminate an agreement without penalty within five business days after entering into the agreement. E. External Compensation for the Sale of Securities to Clients FORUM’s advisory professionals are compensated primarily through a fixed salary plus a percentage of the assets under management. FORUM’s advisory professionals may receive commission-based compensation for the sale of insurance products. Please see Item 10.C. for detailed information and conflicts of interest. Page 9  Item 5: Fees and Compensation F. Important Disclosure – Custodian Investment Programs Please be advised that the firm utilizes certain custodians/broker-dealers. Under these arrangements we can access certain investment programs offered through such custodian(s) that offer certain compensation and fee structures that create conflicts of interest of which clients need to be aware. Please note the following: Limitation on Mutual Fund Universe for Custodian Investment Programs: There are certain programs in which we participate where a client’s investment options may be limited in certain of these programs to those mutual funds and/or mutual fund share classes that pay 12b-1 fees and other revenue sharing fee payments, and the client should be aware that the firm is not selecting from among all mutual funds available in the marketplace when recommending mutual funds to the client. Conflict Between Revenue Share Class (12b-1) and Non-Revenue Share Class Mutual Funds: Revenue share class/12b-1 fees are deducted from the net asset value of the mutual fund and generally, all things being equal, cause the fund to earn lower rates of return than those mutual funds that do not pay revenue sharing fees. The client is under no obligation to utilize such programs or mutual funds. Although many factors will influence the type of fund to be used, the client should discuss with their investment adviser representative whether a share class from a comparable mutual fund with a more favorable return to investors is available that does not include the payment of any 12b-1 or revenue sharing fees given the client’s individual needs and priorities and anticipated transaction costs. In addition, the receipt of such fees can create conflicts of interest in instances where the custodian receives the entirety of the 12b-1 and/or revenue sharing fees and takes the receipt of such fees into consideration in terms of benefits it may elect to provide to the firm, even though such benefits may or may not benefit some or all of the firm clients. Page 10  Item 6: Performance-Based Fees and Side-by-Side Management Item 6: Performance-Based Fees and Side-by-Side Management FORUM does not charge performance-based fees and therefore has no economic incentive to manage clients’ portfolios in any way other than what is in their best interests. Page 11  Item 7: Types of Clients Item 7: Types of Clients FORUM provides its services to individuals, high net worth individuals, and trusts. FORUM has a minimum annual fee of $1,000. For portfolio values less than $80,000, clients may be able to obtain comparable services at a lower cost elsewhere. FORUM, at its sole discretion, may waive this minimum requirement. Page 12  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis and Investment Strategies FORUM uses a variety of sources of data to conduct its economic, investment and market analysis, such as financial newspapers and magazines, economic and market research materials prepared by others, conference calls hosted by mutual funds, corporate rating services, annual reports, prospectuses, and company press releases. It is important to keep in mind that there is no specific approach to investing that guarantees success or positive returns; investing in securities involves risk of loss that clients should be prepared to bear. FORUM and its investment adviser representatives are responsible for identifying and implementing the methods of analysis used in formulating investment recommendations to clients. The methods of analysis may include quantitative methods for optimizing client portfolios, computer-based risk/return analysis, technical analysis, and statistical and/or computer models utilizing long-term economic criteria. ▪ Optimization involves the use of mathematical algorithms to determine the appropriate mix of assets given the firm’s current capital market rate assessment and a particular client’s risk tolerance. ▪ Quantitative methods include analysis of historical data such as price and volume statistics, performance data, standard deviation and related risk metrics, how the security performs relative to the overall stock market, earnings data, price to earnings ratios, and related data. ▪ Technical analysis involves charting price and volume data as reported by the exchange where the security is traded to look for price trends. ▪ Computer models may be used to derive the future value of a security based on assumptions of various data categories such as earnings, cash flow, profit margins, sales, and a variety of other company specific metrics. In addition, FORUM reviews research material prepared by others, as well as corporate filings, corporate rating services, and a variety of financial publications. FORUM may employ outside vendors or utilize third-party software to assist in formulating investment recommendations to clients. Mutual Funds and Exchange-Traded Funds, Individual Securities, Third-Party Sub- Advisers FORUM may recommend ”institutional share class” mutual funds, exchange-traded funds (“ETFs”), and individual securities (including fixed income instruments). FORUM may also assist the client in selecting one or more appropriate sub-adviser(s) for all or a portion of the client’s portfolio. Such sub-adviser will typically manage assets for clients who commit to the sub-adviser a minimum amount of assets established by that sub-adviser—a factor that FORUM will take into account when recommending sub-advisers to clients. FORUM's selection process cannot ensure that sub-advisers will perform as desired, and FORUM will have Page 13  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss no control over the day-to-day operations of any of its selected sub-advisers. FORUM would not necessarily be aware of certain activities at the underlying sub-adviser’s level, including without limitation a sub-adviser’s engaging in unreported risks, investment “style drift,” or even regulatory breaches or fraud. A description of the criteria to be used in formulating an investment recommendation for mutual funds, ETFs, individual securities (including fixed-income securities), and sub-advisers is set forth below. FORUM has formed relationships with third-party vendors that ▪ provide a technological platform for separate account management ▪ prepare performance reports ▪ perform or distribute research of individual securities ▪ perform billing and certain other administrative tasks FORUM may utilize additional independent third parties to assist it in recommending and monitoring individual securities and mutual funds to clients as appropriate under the circumstances. FORUM may utilize additional independent third parties to assist it in recommending and monitoring individual securities, funds, and sub-advisers to clients as appropriate under the circumstances. FORUM reviews certain quantitative and qualitative criteria related to funds and sub-advisers and to formulate investment recommendations to its clients. Quantitative criteria may include ▪ performance history of a fund or sub-adviser evaluated against that of its peers and other benchmarks ▪ analysis of risk-adjusted returns ▪ analysis of the contribution to the investment return (e.g., manager’s alpha), standard deviation of returns over specific time periods, sector and style analysis ▪ fund or sub-adviser’s fee structure ▪ relevant portfolio manager’s tenure Qualitative criteria used in selecting/recommending funds or sub-advisers include the investment objectives and/or management style and philosophy of a fund or sub-adviser; a mutual fund or sub-adviser’s consistency of investment style; and employee turnover and efficiency and capacity. Quantitative and qualitative criteria related to funds and sub-advisers are reviewed by FORUM on a quarterly basis or such other interval as appropriate under the circumstances. In addition, funds or sub-advisers are reviewed to determine the extent to which their investments reflect any of the following: efforts to time the market, engage in portfolio pumping, or evidence style drift such that their portfolios no longer accurately reflect the particular asset category attributed to the fund or sub-adviser by FORUM (all negative factors in implementing an asset allocation structure). Page 14  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss FORUM may negotiate reduced account minimum balances and reduced fees with sub-advisers under various circumstances (e.g., for clients with minimum level of assets committed to the manager for specific periods of time, etc.). There can be no assurance that clients will receive any reduced account minimum balances or fees, or that all clients, even if apparently similarly situated, will receive any reduced account minimum balances or fees available to some other clients. Also, account minimum balances and fees may significantly differ between clients. Each client’s individual needs and circumstances will determine portfolio weighting, which can have an impact on fees given the funds or sub-advisers utilized. FORUM will endeavor to obtain equal treatment for its clients with funds or sub-advisers, but cannot assure equal treatment. FORUM will regularly review the activities of funds and sub-advisers utilized for the client. Clients that engage sub-advisers or invest in funds should first review and understand the disclosure documents of those sub-advisers or funds, which contain information relevant to such retention or investment, including information on the methodology used to analyze securities, investment strategies, fees and conflicts of interest. Material Risks of Investment Instruments FORUM typically invests in open-end mutual funds and exchange-traded funds for the vast majority of its clients. However, for certain clients, FORUM may effect transactions in the following types of securities: ▪ Equity securities ▪ Warrants and rights ▪ Mutual fund securities ▪ Exchange-traded funds ▪ Fixed income securities ▪ Corporate debt securities, commercial paper, and certificates of deposit ▪ Municipal securities ▪ U.S. government securities ▪ Government and agency mortgage-backed securities ▪ Corporate debt obligations ▪ Mortgage-backed securities ▪ Asset-backed securities ▪ Collateralized obligations Equity Securities Investing in individual companies involves inherent risk. The major risks relate to the company’s capitalization, quality of the company’s management, quality and cost of the company’s services, the company’s ability to manage costs, efficiencies in the manufacturing or service delivery process, management of litigation risk, and the company’s ability to create shareholder value (i.e., increase the value of the company’s stock price). Foreign securities, in Page 15  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss addition to the general risks of equity securities, have geopolitical risk, financial transparency risk, currency risk, regulatory risk and liquidity risk. Warrants and Rights Warrants are securities, typically issued with preferred stock or bonds that give the holder the right to purchase a given number of shares of common stock at a specified price and time. The price of the warrant usually represents a premium over the applicable market value of the common stock at the time of the warrant’s issuance. Warrants have no voting rights with respect to the common stock, receive no dividends and have no rights with respect to the assets of the issuer. Investments in warrants and rights involve certain risks, including the possible lack of a liquid market for the resale of the warrants and rights, potential price fluctuations due to adverse market conditions or other factors and failure of the price of the common stock to rise. If the warrant is not exercised within the specified time period, it becomes worthless. Mutual Fund Securities Investing in mutual funds carries inherent risk. The major risks of investing in a mutual fund include the quality and experience of the portfolio management team and its ability to create fund value by investing in securities that have positive growth, the amount of individual company diversification, the type and amount of industry diversification, and the type and amount of sector diversification within specific industries. In addition, mutual funds tend to be tax inefficient and therefore investors may pay capital gains taxes on fund investments while not having yet sold the fund. Exchange-Traded Funds (“ETFs”) ETFs are investment companies whose shares are bought and sold on a securities exchange. An ETF holds a portfolio of securities designed to track a particular market segment or index. Some examples of ETFs are SPDRs®, streetTRACKS®, DIAMONDSSM, NASDAQ 100 Index Tracking StockSM (“QQQs SM”) iShares® and VIPERs®. The funds could purchase an ETF to gain exposure to a portion of the U.S. or foreign market. The funds, as a shareholder of another investment company, will bear their pro-rata portion of the other investment company’s advisory fee and other expenses, in addition to their own expenses. Investing in ETFs involves risk. Specifically, ETFs, depending on the underlying portfolio and its size, can have wide price (bid and ask) spreads, thus diluting or negating any upward price movement of the ETF or enhancing any downward price movement. Also, ETFs require more frequent portfolio reporting by regulators and are thereby more susceptible to actions by hedge funds that could have a negative impact on the price of the ETF. Certain ETFs may employ leverage, which creates additional volatility and price risk depending on the amount of leverage utilized, the collateral and the liquidity of the supporting collateral. Further, the use of leverage (i.e., employing the use of margin) generally results in additional interest costs to the ETF. Certain ETFs are highly leveraged and therefore have additional volatility and liquidity risk. Volatility and liquidity can severely and negatively impact the price Page 16  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss of the ETF’s underlying portfolio securities, thereby causing significant price fluctuations of the ETF. Fixed Income Securities Fixed income securities carry additional risks than those of equity securities described above. These risks include the company’s ability to retire its debt at maturity, the current interest rate environment, the coupon interest rate promised to bondholders, legal constraints, jurisdictional risk (U.S or foreign) and currency risk. If bonds have maturities of ten years or greater, they will likely have greater price swings when interest rates move up or down. The shorter the maturity the less volatile the price swings. Foreign bonds have liquidity and currency risk. Corporate Debt, Commercial Paper and Certificates of Deposit Fixed income securities carry additional risks than those of equity securities described above. These risks include the company’s ability to retire its debt at maturity, the current interest rate environment, the coupon interest rate promised to bondholders, legal constraints, jurisdictional risk (U.S or foreign) and currency risk. If bonds have maturities of ten years or greater, they will likely have greater price swings when interest rates move up or down. The shorter the maturity the less volatile the price swings. Foreign bonds also have liquidity and currency risk. Commercial paper and certificates of deposit are generally considered safe instruments, although they are subject to the level of general interest rates, the credit quality of the issuing bank and the length of maturity. With respect to certificates of deposit, depending on the length of maturity there can be prepayment penalties if the client needs to convert the certificate of deposit to cash prior to maturity. Municipal Securities Municipal securities carry additional risks than those of corporate and bank-sponsored debt securities described above. These risks include the municipality’s ability to raise additional tax revenue or other revenue (in the event the bonds are revenue bonds) to pay interest on its debt and to retire its debt at maturity. Municipal bonds are generally tax free at the federal level, but may be taxable in individual states other than the state in which both the investor and municipal issuer is domiciled. U.S. Government Securities U.S. government securities include securities issued by the U.S. Treasury and by U.S. government agencies and instrumentalities. U.S. government securities may be supported by the full faith and credit of the United States. Government and Agency Mortgage-Backed Securities The principal issuers or guarantors of mortgage-backed securities are the Government National Mortgage Association (“GNMA”), Fannie Mae (“FNMA”) and the Federal Home Loan Mortgage Corporation (“FHLMC”). GNMA, a wholly owned U.S. government corporation within Page 17  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss the Department of Housing and Urban Development (“HUD”), creates pass-through securities from pools of government-guaranteed (Farmers’ Home Administration, Federal Housing Authority or Veterans Administration) mortgages. The principal and interest on GNMA pass- through securities are backed by the full faith and credit of the U.S. government. FNMA, which is a U.S. government-sponsored corporation owned entirely by private stockholders that is subject to regulation by the secretary of HUD, and FHLMC, a corporate instrumentality of the U.S. government, issue pass-through securities from pools of conventional and federally insured and/or guaranteed residential mortgages. FNMA guarantees full and timely payment of all interest and principal, and FHMLC guarantees timely payment of interest and ultimate collection of principal of its pass-through securities. Mortgage-backed securities from FNMA and FHLMC are not backed by the full faith and credit of the U.S. government. Corporate Debt Obligations Corporate debt obligations include corporate bonds, debentures, notes, commercial paper and other similar corporate debt instruments. Companies use these instruments to borrow money from investors. The issuer pays the investor a fixed or variable rate of interest and must repay the amount borrowed at maturity. Commercial paper (short-term unsecured promissory notes) is issued by companies to finance their current obligations and normally has a maturity of less than nine months. In addition, the firm may also invest in corporate debt securities registered and sold in the United States by foreign issuers (Yankee bonds) and those sold outside the U.S. by foreign or U.S. issuers (Eurobonds). Mortgage-Backed Securities Mortgage-backed securities represent interests in a pool of mortgage loans originated by lenders such as commercial banks, savings associations, and mortgage bankers and brokers. Mortgage-backed securities may be issued by governmental or government-related entities, or by non-governmental entities such as special-purpose trusts created by commercial lenders. Pools of mortgages consist of whole mortgage loans or participations in mortgage loans. The majority of these loans are made to purchasers of between one and four family homes. The terms and characteristics of the mortgage instruments are generally uniform within a pool but may vary among pools. For example, in addition to fixed-rate, fixed-term mortgages, the firm may purchase pools of adjustable-rate mortgages, growing equity mortgages, graduated payment mortgages and other types. Mortgage poolers apply qualification standards to lending institutions, which originate mortgages for the pools as well as credit standards and underwriting criteria for individual mortgages included in the pools. In addition, many mortgages included in pools are insured through private mortgage insurance companies. Mortgage-backed securities differ from other forms of fixed income securities, which normally provide for periodic payment of interest in fixed amounts with principal payments at maturity or on specified call dates. Most mortgage-backed securities, however, are pass-through securities, which means that investors receive payments consisting of a pro rata share of both Page 18  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss principal and interest (less servicing and other fees), as well as unscheduled prepayments as loans in the underlying mortgage pool are paid off by the borrowers. Additional prepayments to holders of these securities are caused by prepayments resulting from the sale or foreclosure of the underlying property or refinancing of the underlying loans. As prepayment rates of individual pools of mortgage loans vary widely, it is not possible to accurately predict the average life of a particular mortgage-backed security. Although mortgage-backed securities are issued with stated maturities of up to 40 years, unscheduled or early payments of principal and interest on the mortgages may shorten considerably the securities’ effective maturities. Asset-Backed Securities Like mortgages-backed securities, the collateral underlying asset-backed securities are subject to prepayment, which may reduce the overall return to holders of asset-backed securities. Asset-backed securities present certain additional and unique risks. Primarily, these securities do not always have the benefit of a security interest in collateral comparable to the security interests associated with mortgage-backed securities. Credit card receivables are in general unsecured. Debtors are entitled to the protection of a number of state and federal consumer credit laws, many of which give such debtors the right to set-off certain amounts owed on the credit cards, thereby reducing the balance due. Generally, automobile receivables are secured by automobiles. Most issuers of automobile receivables permit the loan servicers to retain possession of the underlying obligations. If the servicer were to sell these obligations to another party, there is a risk that the purchaser would acquire an interest superior to that of the holders of the asset-backed securities. In addition, because of the large number of vehicles involved in a typical issuance and the technical requirements under state laws, the trustee for the holders of the automobile receivables may not have a proper security interest in the underlying automobiles. As a result, the risk that recovery on repossessed collateral might be unavailable or inadequate to support payments on asset-backed securities is greater for asset-backed securities than for mortgage-backed securities. In addition, because asset-backed securities are relatively new, the market experience in these securities is limited and the market’s ability to sustain liquidity through all phases of an interest rate or economic cycle has not been tested. Collateralized Obligations Collateralized mortgage obligations (“CMOs”) are collateralized by mortgage-backed securities issued by GNMA, FHLMC or FNMA (“mortgage assets”). CMOs are multiple-class debt obligations. Payments of principal and interest on the mortgage assets are passed through to the holders of the CMOs as they are received, although certain classes (often referred to as “tranches”) of CMOs have priority over other classes with respect to the receipt of mortgage prepayments. Each tranch is issued at a specific or floating coupon rate and has a stated maturity or final distribution date. Interest is paid or accrues in all tranches on a monthly, quarterly or semi-annual basis. Payments of principal and interest on mortgage assets are commonly applied to the tranches in the order of their respective maturities or final distribution dates, so that generally no payment of principal will be made on any tranch until all other tranches with earlier stated maturity or distribution dates have been paid in full. Page 19  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Collateralized debt obligations ("CDOs") include collateralized bond obligations ("CBOs"), collateralized loan obligations ("CLOs") and other similarly structured securities. CBOs and CLOs are types of asset-backed securities. A CBO is a trust that is backed by a diversified pool of high-risk, below-investment-grade fixed income securities. A CLO is a trust typically collateralized by a pool of loans, which may include, among others, domestic and foreign senior secured loans, senior unsecured loans and subordinate corporate loans, including loans that may be rated below investment grade or equivalent unrated loans. B. Investment Strategy and Method of Analysis Material Risks Our investment strategy is custom-tailored to the client’s goals, investment objectives, risk tolerance, and personal and financial circumstances. Margin Leverage Although FORUM, as a general business practice, does not utilize leverage, there may be instances in which exchange-traded funds, other separate account managers and, in very limited circumstances, FORUM will utilize leverage. In this regard please review the following: The use of margin leverage enhances the overall risk of investment gain and loss to the client’s investment portfolio. For example, investors are able to control $2 of a security for $1. So if the price of a security rises by $1, the investor earns a 100% return on their investment. Conversely, if the security declines by $.50, then the investor loses 50% of their investment. The use of margin leverage entails borrowing, which results in additional interest costs to the investor. Broker-dealers who carry customer accounts require a minimum equity requirement when clients utilize margin leverage. The minimum equity requirement is stated as a percentage of the value of the underlying collateral security with an absolute minimum dollar requirement. For example, if the price of a security declines in value to the point where the excess equity used to satisfy the minimum requirement dissipates, the broker-dealer will require the client to deposit additional collateral to the account in the form of cash or marketable securities. A deposit of securities to the account will require a larger deposit, as the security being deposited is included in the computation of the minimum equity requirement. In addition, when leverage is utilized and the client needs to withdraw cash, the client must sell a disproportionate amount of collateral securities to release enough cash to satisfy the withdrawal amount based upon similar reasoning as cited above. Regulations concerning the use of margin leverage are established by the Federal Reserve Board and vary if the client’s account is held at a broker-dealer versus a bank custodian. Broker-dealers and bank custodians may apply more stringent rules as they deem necessary. Short-Term Trading Although FORUM, as a general business practice, does not utilize short-term trading, there may be instances in which short-term trading may be necessary or an appropriate strategy. In this regard, please read the following: Page 20  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss There is an inherent risk for clients who trade frequently in that high-frequency trading creates substantial transaction costs that in the aggregate could negatively impact account performance. Short Selling FORUM generally does not engage in short selling but reserves the right to do so in the exercise of its sole judgment. Short selling involves the sale of a security that is borrowed rather than owned. When a short sale is effected, the investor is expecting the price of the security to decline in value so that a purchase or closeout of the short sale can be effected at a significantly lower price. The primary risks of effecting short sales is the availability to borrow the stock, the unlimited potential for loss, and the requirement to fund any difference between the short credit balance and the market value of the security. Technical Trading Models Technical trading models are mathematically driven based upon historical data and trends of domestic and foreign market trading activity, including various industry and sector trading statistics within such markets. Technical trading models, through mathematical algorithms, attempt to identify when markets are likely to increase or decrease and identify appropriate entry and exit points. The primary risk of technical trading models is that historical trends and past performance cannot predict future trends, and there is no assurance that the mathematical algorithms employed are designed properly, updated with new data, and can accurately predict future market, industry, and sector performance. Option Strategies Various option strategies give the holder the right to acquire or sell underlying securities at the contract strike price up until expiration of the option. Each contract is worth 100 shares of the underlying security. Options entail greater risk but allow an investor to have market exposure to a particular security or group of securities without the capital commitment required to purchase the underlying security or groups of securities. In addition, options allow investors to hedge security positions held in the portfolio. For detailed information on the use of options and option strategies, please contact the Options Clearing Corporation for the current Options Risk Disclosure Statement. FORUM as part of its investment strategy may employ the following option strategies: ▪ Covered call writing ▪ Long call options purchases ▪ Long put options purchases ▪ Option spreading Covered Call Writing Covered call writing is the sale of in-, at-, or out-of-the-money call option against a long security position held in the client portfolio. This type of transaction is used to generate income. It also serves to create downside protection in the event the security position declines Page 21  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss in value. Income is received from the proceeds of the option sale. Such income may be reduced to the extent it is necessary to buy back the option position prior to its expiration. This strategy may involve a degree of trading velocity, transaction costs and significant losses if the underlying security has volatile price movement. Covered call strategies are generally suited for companies with little price volatility. Long Call Option Purchases Long call option purchases allow the option holder to be exposed to the general market characteristics of a security without the outlay of capital necessary to own the security. Options are wasting assets and expire (usually within nine months of issuance), and as a result can expose the investor to significant loss. Long Put Option Purchases Long put option purchases allow the option holder to sell or “put” the underlying security at the contract strike price at a future date. If the price of the underlying security declines in value, the value of the long put option increases. In this way long puts are often used to hedge a long stock position. Options are wasting assets and expire (usually within nine months of issuance), and as a result can expose the investor to significant loss. Option Spreading Option spreading usually involves the purchase of a call option and the sale of a call option at a higher contract strike price, both having the same expiration month. The purpose of this type of transaction is to allow the holder to be exposed to the general market characteristics of a security without the outlay of capital to own the security, and to offset the cost by selling the call option with a higher contract strike price. In this type of transaction, the spread holder “locks in” a maximum profit, defined as the difference in contract prices reduced by the net cost of implementing the spread. There are many variations of option spreading strategies; please contact the Options Clearing Corporation for a current Options Risk Disclosure Statement that discusses each of these strategies. C. Security-Specific Material Risks There is an inherent risk for clients who have their investment portfolios heavily weighted in one security, one industry or industry sector, one geographic location, one investment manager, one type of investment instrument (equities versus fixed income). Clients who have diversified portfolios, as a general rule, incur less volatility and therefore less fluctuation in portfolio value than those who have concentrated holdings. Concentrated holdings may offer the potential for higher gain, but also offer the potential for significant loss. Page 22  Item 9: Disciplinary Information Item 9: Disciplinary Information A. Criminal or Civil Actions There is nothing to report on this item. B. Administrative Enforcement Proceedings There is nothing to report on this item. C. Self-Regulatory Organization Enforcement Proceedings There is nothing to report on this item. Page 23  Item 10: Other Financial Industry Activities and Affiliations Item 10: Other Financial Industry Activities and Affiliations A. Broker-Dealer or Representative Registration Neither FORUM nor its supervised persons are registered broker-dealers and do not have an application to register pending. B. Futures or Commodity Registration Neither FORUM nor its affiliates are registered as a commodity firm, futures commission merchant, commodity pool operator or commodity trading advisor and do not have an application to register pending. C. Material Relationships Maintained by this Advisory Business and Conflicts of Interest FORUM Credit Union FORUM is under common control with FORUM Credit Union, a federal credit union. FORUM may recommend FORUM Credit Union to its clients to fulfill their banking needs. Clients are advised that any such referral is an inherent conflict of interest due to the common ownership among the companies. Registration as Insurance Agency FORUM Credit Union is a duly licensed insurance agency. Additionally, certain of FORUM’s supervised persons are licensed insurance agents with FORUM Credit Union, and in such capacity, may recommend, on a fully disclosed basis, the purchase of certain insurance products. A conflict of interest exists to the extent that FORUM or its supervised persons recommend the purchase of insurance products where FORUM Credit Union or FORUM’s supervised persons receive insurance commissions or other additional compensation. FORUM strives to put its clients’ interests first and foremost, and clients may utilize any insurance carrier or insurance agency they desire. D. Recommendation or Selection of Other Investment Advisors and Conflicts of Interest With respect to its wealth management services, the firm engages third-party investment managers or sub-advisers to manage FORUM client accounts, and such third parties charge a separate fee for their investment management services. FORUM does not receive any referral remuneration from advisers, investment managers, or other service providers that it recommends to clients. Page 24  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Description In accordance with the Advisers Act, FORUM has adopted policies and procedures designed to detect and prevent insider trading. In addition, FORUM has adopted a Code of Ethics (the “Code”). Among other things, the Code includes written procedures governing the conduct of FORUM's advisory and access persons. The Code also imposes certain reporting obligations on persons subject to the Code. The Code and applicable securities transactions are monitored by the chief compliance officer of FORUM. FORUM will send clients a copy of its Code of Ethics upon written request. FORUM has policies and procedures in place to ensure that the interests of its clients are given preference over those of FORUM, its affiliates and its employees. For example, there are policies in place to prevent the misappropriation of material non-public information, and such other policies and procedures reasonably designed to comply with federal and state securities laws. B. Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest FORUM does not engage in principal trading (i.e., the practice of selling stock to advisory clients from a firm’s inventory or buying stocks from advisory clients into a firm’s inventory). In addition, FORUM does not recommend any securities to advisory clients in which it has some proprietary or ownership interest. C. Advisory Firm Purchase or Sale of Same Securities Recommended to Clients and Conflicts of Interest FORUM, its affiliates, employees and their families, trusts, estates, charitable organizations and retirement plans established by it may purchase or sell the same securities as are purchased or sold for clients in accordance with its Code of Ethics policies and procedures. The personal securities transactions by advisory representatives and employees may raise potential conflicts of interest when they trade in a security that is: ▪ owned by the client, or ▪ considered for purchase or sale for the client. Such conflict generally refers to the practice of front-running (trading ahead of the client), which FORUM specifically prohibits. FORUM has adopted policies and procedures that are intended to address these conflicts of interest. These policies and procedures: ▪ require our advisory representatives and employees to act in the client’s best interest ▪ prohibit fraudulent conduct in connection with the trading of securities in a client account Page 25  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ▪ prohibit employees from personally benefitting by causing a client to act, or fail to act in making investment decisions ▪ prohibit the firm or its employees from profiting or causing others to profit on knowledge of completed or contemplated client transactions ▪ allocate investment opportunities in a fair and equitable manner ▪ provide for the review of transactions to discover and correct any trades that result in an advisory representative or employee benefitting at the expense of a client. Advisory representatives and employees must follow FORUM’s procedures when purchasing or selling the same securities purchased or sold for the client. D. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest FORUM, its affiliates, employees and their families, trusts, estates, charitable organizations, and retirement plans established by it may effect securities transactions for their own accounts that differ from those recommended or effected for other FORUM clients. The firm does not engage in aggregation or bulk trading, and does not conduct average pricing calculations. It is the policy of FORUM to place the clients’ interests above those of FORUM and its employees. Page 26  Item 12: Brokerage Practices Item 12: Brokerage Practices A. Factors Used to Select Broker-Dealers for Client Transactions Custodian Recommendations FORUM may recommend that clients establish brokerage accounts with Fidelity, a FINRA registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. Although FORUM may recommend that clients establish accounts at the custodian, it is the client’s decision to custody assets with the custodian. FORUM is independently owned and operated and not affiliated with custodian. For FORUM-managed advisory accounts, the custodian generally does not charge separately for custody services but is compensated by account holders through commissions and other transaction-related or asset- based fees for securities trades that are executed through the custodian or that settle into custodian accounts. FORUM considers the financial strength, reputation, operational efficiency, cost, execution capability, level of customer service, and related factors in recommending broker-dealers or custodians to advisory clients. In certain instances and subject to approval by FORUM, FORUM will recommend to clients certain other broker-dealers and/or custodians based on the needs of the individual client, and taking into consideration the nature of the services required, the experience of the broker-dealer or custodian, the cost and quality of the services, and the reputation of the broker-dealer or custodian. The final determination to engage a broker-dealer or custodian recommended by FORUM will be made by and in the sole discretion of the client. The client recognizes that broker-dealers and/or custodians have different cost and fee structures and trade execution capabilities. As a result, there may be disparities with respect to the cost of services and/or the transaction prices for securities transactions executed on behalf of the client. Clients are responsible for assessing the commissions and other costs charged by broker-dealers and/or custodians. Soft Dollar Arrangements FORUM does not utilize soft dollar arrangements. FORUM does not direct brokerage transactions to executing brokers for research and brokerage services. Institutional Trading and Custody Services The custodian provides FORUM with access to its institutional trading and custody services, which are typically not available to the custodian’s retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as a certain minimum amount of the advisor’s clients’ assets are maintained in accounts at a particular custodian. The custodian’s brokerage 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. Page 27  Item 12: Brokerage Practices Other Products and Services Custodian also makes available to FORUM other products and services that benefit FORUM but may not directly benefit its clients’ accounts. Many of these products and services may be used to service all or some substantial number of FORUM's accounts, including accounts not maintained at custodian. The custodian may also make available to FORUM software and other technology that ▪ provide access to client account data (such as trade confirmations and account statements) ▪ facilitate trade execution and allocate aggregated trade orders for multiple client accounts ▪ provide research, pricing and other market data ▪ facilitate payment of FORUM’s fees from its clients’ accounts ▪ assist with back-office functions, recordkeeping and client reporting The custodian may also offer other services intended to help FORUM manage and further develop its business enterprise. These services may include ▪ compliance, legal and business consulting ▪ publications and conferences on practice management and business succession ▪ access to employee benefits providers, human capital consultants and insurance providers The custodian may also provide other benefits such as educational events or occasional business entertainment of FORUM personnel. In evaluating whether to recommend that clients custody their assets at the custodian, FORUM may take into account the availability of some of the foregoing products and services and other arrangements as part of the total mix of factors it considers, and not solely the nature, cost or quality of custody and brokerage services provided by the custodian, which creates a conflict of interest. Independent Third Parties The custodian may make available, arrange, and/or pay third-party vendors for the types of services rendered to FORUM. The custodian may discount or waive fees it would otherwise charge for some of these services or all or a part of the fees of a third party providing these services to FORUM. Additional Compensation Received from Custodians FORUM may participate in institutional customer programs sponsored by broker-dealers or custodians. FORUM may recommend these broker-dealers or custodians to clients for custody and brokerage services. There is no direct link between FORUM’s participation in such programs and the investment advice it gives to its clients, although FORUM receives economic benefits through its participation in the programs that are typically not available to retail investors. These benefits may include the following products and services (provided without cost or at a discount): ▪ Receipt of duplicate client statements and confirmations Page 28  Item 12: Brokerage Practices ▪ Research-related products and tools ▪ Consulting services ▪ Access to a trading desk serving FORUM participants ▪ Access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts) ▪ The ability to have advisory fees deducted directly from client accounts ▪ Access to an electronic communications network for client order entry and account information ▪ Access to mutual funds with no transaction fees and to certain institutional money managers ▪ Discounts on compliance, marketing, research, technology, and practice management products or services provided to FORUM by third-party vendors The custodian may also pay for business consulting and professional services received by FORUM’s related persons, and may pay or reimburse expenses (including travel, lodging, meals and entertainment expenses for FORUM’s personnel to attend conferences). Some of the products and services made available by such custodian through its institutional customer programs may benefit FORUM but may not benefit its client accounts. These products or services may assist FORUM in managing and administering client accounts, including accounts not maintained at the custodian as applicable. Other services made available through the programs are intended to help FORUM manage and further develop its business enterprise. The benefits received by FORUM or its personnel through participation in these programs do not depend on the amount of brokerage transactions directed to the broker-dealer. FORUM also participates in similar institutional advisor programs offered by other independent broker-dealers or trust companies, and its continued participation may require FORUM to maintain a predetermined level of assets at such firms. In connection with its participation in such programs, FORUM will typically receive benefits similar to those listed above, including research, payments for business consulting and professional services received by FORUM’s related persons, and reimbursement of expenses (including travel, lodging, meals and entertainment expenses for FORUM’s personnel to attend conferences sponsored by the broker-dealer or trust company). As part of its fiduciary duties to clients, FORUM endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by FORUM or its related persons in and of itself creates a conflict of interest and indirectly influences FORUM’s recommendation of broker-dealers such as Fidelity for custody and brokerage services. The Firm’s Interest in Custodian’s Services The availability of these services from the custodian benefits the firm because the firm does not have to produce or purchase them. The firm does not have to pay for the custodian’s services so long as a certain minimum of client assets is kept in accounts at the custodian. Custodian’s services give the firm an incentive to recommend that clients maintain their Page 29  Item 12: Brokerage Practices accounts with the custodian based on the firm’s interest in receiving the custodian’s services that benefit the firm’s business rather than based on the client’s interest in receiving the best value in custody services and the most favorable execution of client transactions. This is a conflict of interest. The firm believes, however, that the selection of the custodian as custodian and broker is in the best interest of clients. It is primarily supported by the scope, quality, and price of the custodian’s services and not the custodian’s services that benefit only the firm. Brokerage for Client Referrals FORUM does not engage in the practice of directing brokerage commissions in exchange for the referral of advisory clients. Directed Brokerage FORUM Recommendations FORUM typically recommends Fidelity as custodian for clients’ funds and securities and to execute securities transactions on its clients’ behalf. Client-Directed Brokerage Occasionally, clients may direct FORUM to use a particular broker-dealer to execute portfolio transactions for their account or request that certain types of securities not be purchased for their account. Clients who designate the use of a particular broker-dealer should be aware that they will lose any possible advantage FORUM derives from aggregating transactions. Such client trades are typically effected after the trades of clients who have not directed the use of a particular broker-dealer. FORUM loses the ability to aggregate trades with other FORUM advisory clients, potentially subjecting the client to inferior trade execution prices as well as higher commissions. B. Aggregating Securities Transactions for Client Accounts Best Execution FORUM may recommend that clients establish brokerage accounts with Fidelity, a FINRA- registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. Such accounts will be prime broker eligible so that if and when the need arises to effect securities transactions at broker-dealers ("executing brokers") other than with the client’s current custodian, such custodian will accept delivery or deliver the applicable security from/to the executing broker. Fidelity charges a “trade away” fee which is charged against the client account for each trade away occurrence. Other custodians have their own policies concerning prime broker accounts and trade away fees. Clients are directed to consult their current custodian for their policies and fees. FORUM, pursuant to the terms of its investment advisory agreement with clients, has discretionary authority to determine which securities are to be bought and sold, the amount of such securities, the executing broker, and the commission rates to be paid to effect such Page 30  Item 12: Brokerage Practices transactions. FORUM recognizes that the analysis of execution quality involves a number of factors, both qualitative and quantitative. FORUM will follow a process in an attempt to ensure that it is seeking to obtain the most favorable execution under the prevailing circumstances when placing client orders. These factors include but are not limited to the following: ▪ The financial strength, reputation and stability of the broker ▪ The efficiency with which the transaction is effected ▪ The ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any) ▪ The availability of the broker to stand ready to effect transactions of varying degrees of difficulty in the future ▪ The efficiency of error resolution, clearance and settlement ▪ Block trading and positioning capabilities ▪ Performance measurement ▪ Online access to computerized data regarding customer accounts ▪ Availability, comprehensiveness, and frequency of brokerage and research services ▪ Commission rates ▪ The economic benefit to the client ▪ Related matters involved in the receipt of brokerage services Consistent with its fiduciary responsibilities, FORUM seeks to ensure that clients receive best execution with respect to clients’ transactions by blocking client trades to reduce commissions and transaction costs. To the best of FORUM’s knowledge, these custodians provide high-quality execution, and FORUM’s clients do not pay higher transaction costs in return for such execution. Commission rates and securities transaction fees charged to effect such transactions are established by the client’s independent custodian and/or broker-dealer. Based upon its own knowledge of the securities industry, FORUM believes that such commission rates are competitive within the securities industry. Lower commissions or better execution may be able to be achieved elsewhere. Page 31  Item 13: Review of Accounts Item 13: Review of Accounts A. Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved For those clients to whom FORUM provides investment management services, FORUM monitors those portfolios as part of an ongoing process while regular account reviews are conducted on at least a semi-annual basis. Such reviews are conducted by one of FORUM’s investment adviser representatives. All investment advisory clients are encouraged to discuss their needs, goals, and objectives with FORUM and to keep FORUM informed of any changes thereto. FORUM contacts ongoing investment advisory clients at least semi-annually to review its previous services and/or recommendations and to discuss the impact resulting from any changes in the client’s financial situation and/or investment objectives. For limited financial planning and consulting engagements, clients receive their financial plans and recommendations at the time service is completed. The firm will reach out to clients annually to offer a review and update of their financial plan. Clients may also request a review of their plan at any time. For ongoing financial planning engagements, reviews normally correspond with the client’s periodic meeting schedule. This is often quarterly, but reviews occur no less than annually. B. Review of Client Accounts on Non-Periodic Basis FORUM may perform ad hoc reviews on an as-needed basis if there have been material changes in the client’s investment objectives or risk tolerance, or a material change in how FORUM formulates investment advice. C. Content of Client-Provided Reports and Frequency Clients to whom FORUM provides investment advisory services will receive a report from FORUM that may include such relevant account and/or market-related information such as an inventory of account holdings and account performance on a quarterly basis. The client’s independent custodian provides account statements directly to the client no less frequently than quarterly. Clients should compare the account statements they receive from their custodian with those they receive from FORUM. The custodian’s statement is the official record of the client’s securities account and supersedes any statements or reports created on behalf of the client by FORUM. Those clients to whom FORUM provides financial planning and/or consulting services will receive reports from FORUM summarizing its analysis and conclusions as requested by the client or otherwise agreed to in writing by FORUM. Page 32  Item 14: Client Referrals and Other Compensation Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest Fidelity FORUM receives an economic benefit from Fidelity in the form of the support products and services it makes available to us and other independent investment advisors that have their clients maintain accounts at Fidelity. These products and services, how they benefit us, and the related conflicts of interest are described above in Item 12: Brokerage Practices. The availability of Fidelity’s products and services to us is not based on our giving particular investment advice, such as buying particular securities for our clients. Expense Reimbursements The firm may from time to time receive expense reimbursement for travel and/or marketing expenses from distributors of investment and/or insurance products. Travel expense reimbursements are typically a result of attendance at due diligence and/or investment training events hosted by product sponsors. Marketing expense reimbursements are typically the result of informal expense sharing arrangements in which product sponsors may underwrite costs incurred for marketing, such as advertising, publishing, and seminar expenses. Although receipt of these travel and marketing expense reimbursements are not predicated upon specific sales quotas, the product sponsor reimbursements are typically made by those sponsors for whom sales have been made or it is anticipated sales will be made. This creates a conflict of interest in that there is an incentive to recommend certain products and investments based on the receipt of this compensation instead of what is the in best interest of our clients. We attempt to control for this conflict by always basing investment decisions on the individual needs of our clients. B. Advisory Firm Payments for Client Referrals The firm may enter into arrangements with promoters, endorsers, solicitors, or with clients for testimonials (herein collectively referred to as “promoter”) who will promote the advisory firm for compensation. Agreements are required when compensation to the promoter is equal to or greater than $1,000. The receipt of such compensation creates a conflict of interest in that the promoter is economically incented to promote our firm. Please be advised that the firm’s payment of compensation to the promoter does not increase the client’s advisory fee paid to the firm. Employees of FORUM’s affiliate, FORUM Credit Union, may recommend to clients our firm’s financial services and receive a referral fee. The receipt of such compensation creates a conflict of interest in that FORUM Credit Union has an economic interest to recommend our firm. Please be advised that the payment of a referral fee does not increase the client’s advisory fee paid to the firm. Page 33  Item 15: Custody Item 15: Custody FORUM is considered to have custody of client assets for purposes of the Advisers Act for the following reasons: ▪ The client authorizes us to instruct their custodian to deduct our advisory fees directly from the client’s account. ▪ Our authority to direct client requests, utilizing standing instructions, for wire transfer of funds for first-party money movement and third-party money movement (checks and/or journals, ACH, Fed-wires). The firm has elected to meet the SEC’s seven conditions to avoid the surprise custody exam, as outlined below: 1. The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. 2. The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. 3. The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization, and provides a transfer of funds notice to the client promptly after each transfer. 4. The client has the ability to terminate or change the instruction to the client’s qualified custodian. 5. The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. 6. The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. 7. The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. Individual advisory clients will receive at least quarterly account statements directly from their custodian containing a description of all activity, cash balances, and portfolio holdings in their accounts. FORUM urges its clients to compare the account balance(s) shown on their account statements to the quarter-end balance(s) on their custodian's monthly statement. The custodian’s statement is the official record of the account. Page 34  Item 16: Investment Discretion Item 16: Investment Discretion Clients may grant a limited power of attorney to FORUM with respect to trading activity in their accounts by signing the appropriate custodian limited power of attorney form. In those cases, FORUM will exercise full discretion as to the nature and type of securities to be purchased and sold, and the amount of securities for such transactions. Investment limitations may be designated by the client as outlined in the investment advisory agreement. In addition, subject to the terms of its investment advisory agreement, FORUM may be granted discretionary authority for the retention of independent third-party sub-advisers. Under such terms, the firm would also exercise discretion as to the executing broker to be used for securities transactions and the amount of commissions to be paid. Please see the applicable third-party sub-adviser’s disclosure brochure for detailed information relating to discretionary authority. Page 35  Item 17: Voting Client Securities Item 17: Voting Client Securities FORUM does not take discretion with respect to voting proxies on behalf of its clients. All proxy material will be forwarded to the client by the client’s custodian for the client’s review and action. Clients may contact the firm with questions regarding proxies they have received. Except as required by applicable law, FORUM will not be obligated to render advice or take any action on behalf of clients with respect to assets presently or formerly held in their accounts that become the subject of any legal proceedings, including bankruptcies. From time to time, securities held in the accounts of clients will be the subject of class action lawsuits. FORUM has no obligation to determine if securities held by the client are subject to a pending or resolved class action lawsuit. FORUM also has no duty to evaluate a client’s eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, FORUM has no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients. Where FORUM receives written or electronic notice of a class action lawsuit, settlement, or verdict affecting securities owned by a client, it will forward all notices, proof of claim forms, and other materials to the client. Electronic mail is acceptable where appropriate and where the client has authorized contact in this manner. Page 36  Item 18: Financial Information Item 18: Financial Information A. Balance Sheet FORUM does not require the prepayment of fees of $1200 or more, six months or more in advance, and as such is not required to file a balance sheet. B. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients FORUM does not have any financial issues that would impair its ability to provide services to clients. C. Bankruptcy Petitions During the Past Ten Years There is nothing to report on this item. Page 37 

Item 1: Cover Page Item 1: Cover Page Part 2A of Form ADV Firm Brochure February 19, 2026 FORUM Solutions Group, LLC dba SafisLife Advisors SEC File No. 801-78874 11313 USA Parkway Fishers, Indiana 46037 phone: 317-558-6322 email: SafisLife@forumcu.com website: https://www.forumcu.com/resources/financial-coaching This brochure provides information about the qualifications and business practices of SafisLife Advisors. If you have any questions about the contents of this brochure, please contact Jim Carr at 317-558-6322 or email SafisLife@forumcu.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. Registration with the SEC or state regulatory authority does not imply a certain level of skill or expertise. Additional information about SafisLife Advisors is also available on the SEC’s website at www.adviserinfo.sec.gov. Page 1  Item 2: Material Changes Item 2: Material Changes This Firm Brochure is our disclosure document prepared according to regulatory requirements and rules. Consistent with the rules, we will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business fiscal year. Furthermore, we will provide you with other interim disclosures about material changes as necessary. There are no material changes to this Brochure from the last annual update issued on March 17, 2025. Page 2  Item 3: Table of Contents 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 ............................................................................................................................ 6 Item 6: Performance-Based Fees and Side-by-Side Management ........................................................... 9 Item 7: Types of Clients ........................................................................................................................................... 10 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ................................................. 11 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 ................................................................................................................................... 18 Item 13: Review of Accounts ................................................................................................................................... 21 Item 14: Client Referrals and Other Compensation ........................................................................................ 22 Item 15: Custody .......................................................................................................................................................... 23 Item 16: Investment Discretion ............................................................................................................................... 24 Item 17: Voting Client Securities ............................................................................................................................ 25 Item 18: Financial Information ................................................................................................................................ 26 Page 3  Item 4: Advisory Business Item 4: Advisory Business A. Ownership/Advisory History FORUM Solutions Group, LLC, dba SafisLife Advisors (“SafisLife” or the “firm”) is an Indiana limited liability company formed in 2007. FORUM Credit Union is the principal owner of the firm. B. Advisory Services Offered EnrichTM Financial Wellness Program SafisLife offers a personal financial wellness program through Enrich and FORUM Credit Union. Users pay a monthly subscription to access the online interface that offers features to help set and achieve financial goals, such as the following: ▪ Access to savings account yielding competitive dividends ▪ Financial wellness coaching ▪ Financial topics and courses, such as planning for retirement, repaying student loans, buying a home and understanding mortgages, buying or leasing a car, filing taxes, and many others. ▪ Tools for discovering your money personality, budgeting, tracking student loans, accessing credit scores and reports, and more ▪ Financial literacy webinars Investment Advisory Services SafisLife offers investment advisory services to clients through Betterment LLC, using an automated, online investment management platform for use by independent investment advisors. Through this Third Party Asset Management Program (“TAMP”), we provide clients a variety of risk-based model portfolios consisting of exchange-traded funds (“ETFs”) and a cash allocation. The client’s portfolio is held in a brokerage account opened by the client at Betterment Securities, a registered broker-dealer. We are independent of and not owned by, affiliated with, or sponsored or supervised by Betterment LLC, Betterment Securities, or their affiliates (together, “Betterment”). The Program is described in the Betterment Disclosure Brochure (the “Program Disclosure Brochure”), which is delivered to clients by Betterment during the online enrollment process. We, and not Betterment, are the client’s investment advisor and primary point of contact with respect to the Program. We are solely responsible, and Betterment is not responsible, for determining the appropriateness of the Program for the client, assisting the client in choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, and assisting the client in managing that portfolio on an ongoing basis. Betterment’s role is limited to delivering the Program Disclosure Brochure to clients and administering the Program so that it operates as described in the Program Disclosure Brochure. Page 4  Item 4: Advisory Business We have contracted with Betterment to provide us with the technology platform and related trading and account management services for the Program. This platform enables us to make the Program available to clients online and includes a system that automates certain key parts of our investment process (the “System”). The System includes an online questionnaire that helps us determine the client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that we will recommend a portfolio via the System in response to the client’s answers to the online questionnaire. The client may then indicate an interest in a portfolio that is less or more conservative or aggressive than the recommended portfolio, but the client will make the final decision in selecting a portfolio based on all the information provided by the client. The client has the ability to reallocate assets or select other portfolios on a self-directed basis or in consultation with their adviser. The System also includes an automated investment engine through which we manage the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). Clients agree to promptly inform SafisLife, via the platform, if the information provided, including client’s investment objectives, goals, risk tolerance, other personal and financial circumstances, time horizon, and investment experience becomes inaccurate, and to provide updated information, if any, about the client’s financial circumstances and investment objectives. C. Client-Tailored Services and Client-Imposed Restrictions Each client’s account will be managed on the basis of the client’s financial situation and investment objectives and in accordance with any reasonable restrictions imposed by the client on the management of the account—for example, restricting the type or amount of security to be purchased in the portfolio. D. Wrap Fee Programs SafisLife may refer clients to the Betterment wrap fee program. While SafisLife does not sponsor a wrap fee program, it may recommend third-party wrap fee programs depending on the needs of a particular client. In wrap fee programs, brokerage commissions and transaction costs are included in the asset-based fee charged to the client. E. Client Assets Under Management As of December 31, 2025, FORUM Solutions Group, LLC, managed assets of $381,043,472 on a discretionary basis, and $22,209,301 on a non-discretionary basis. Page 5  Item 5: Fees and Compensation Item 5: Fees and Compensation A. Methods of Compensation and Fee Schedule Personal Finance Program Fee For the personal finance program, users are charged a monthly subscription fee of $5.00. Initial subscription fee will be billed on the first day of the month following enrollment. Investment Advisory Services Fees Investment advisory services are charged an asset-based fee calculated as a percentage of the value of the assets being managed through the Betterment TAMP according to the following fee schedule, which represents the firm’s maximum fees for individual services. Assets Under Management SafisLife Fee Betterment Fee Total Fee $0–$75,000 25 bps 20 bps 45 bps $75,000–$150,000 55 bps 20 bps 75 bps $150,000+ 70 bps 20 bps 90 bps Asset-based fees are always subject to the investment advisory agreement between the client and SafisLife. Such fees are payable quarterly in arrears. B. Client Payment of Fees Personal Finance Program Fee Subscription fees will be paid on the online app with the user’s credit card or debited from their online savings account. A subscription to the online app may be canceled by the user at any time for any reason but will continue until the end of the subscription period. Upon cancellation, the user’s savings account held at our affiliate will remain open and continue to earn interest at the prevailing rate on FORUM Credit Union’s regular savings account. The subscription will auto-renew unless canceled by the user before the end of the subscription period. No refunds will be issued if the subscription is terminated before the end of the subscription period. Investment Advisory Services Fees SafisLife does not require the prepayment of its fees, as fees are payable quarterly in arrears. SafisLife requires clients to authorize the direct debit of fees from their accounts. Exceptions may be granted subject to the firm’s consent for clients to be billed directly for our fees. For directly debited fees, the custodian’s periodic statements will show each fee deduction from the account. Clients may withdraw this authorization for direct billing of these fees at any time by notifying us or their custodian in writing. Page 6  Item 5: Fees and Compensation SafisLife will deduct advisory fees directly from the client’s account provided that (i) the client provides written authorization, and (ii) the qualified custodian sends the client a statement, at least quarterly, indicating all amounts disbursed from the account. The client is responsible for verifying the accuracy of the fee calculation, as the client’s custodian will not verify the calculation. A client investment advisory agreement may be canceled at any time by the client, or by SafisLife with 30 days’ prior written notice to the client. Upon termination, any earned, unpaid fees will be immediately due and payable. The client has the right to terminate an agreement without penalty within five business days after entering into the agreement. C. Additional Client Fees Charged All fees paid for investment advisory services are separate and distinct from the fees and expenses charged by exchange-traded funds, mutual funds, separate account managers, broker- dealers and custodians retained, if any. Such fees and expenses are described in each exchange- traded fund and mutual fund’s prospectus, each separate account manager’s Form ADV and Brochure and Brochure Supplement or similar disclosure statement, and by any broker-dealer or custodian retained. Clients are advised to read these materials carefully before investing. If a mutual fund also imposes sales charges, a client may pay an initial or deferred sales charge as further described in the mutual fund’s prospectus. A client using SafisLife may be precluded from using certain mutual funds or separate account managers because they may not be offered by the client's custodian. Please refer to the Brokerage Practices section (Item 12) for additional information regarding the firm’s brokerage practices. D. External Compensation for the Sale of Securities to Clients SafisLife’s advisory professionals are compensated primarily through a fixed salary plus a percentage of the assets under management. SafisLife’s advisory professionals may receive commission-based compensation for the sale of insurance products. Please see Item 10.C. for detailed information and conflicts of interest. E. Important Disclosure – Custodian Investment Programs Please be advised that the firm utilizes certain custodians/broker-dealers. Under these arrangements we can access certain investment programs offered through such custodian(s) that offer certain compensation and fee structures that create conflicts of interest of which clients need to be aware. Please note the following: Limitation on Mutual Fund Universe for Custodian Investment Programs: There are certain programs in which we participate where a client’s investment options may be limited in certain of these programs to those mutual funds and/or mutual fund share classes that pay 12b-1 fees and other revenue sharing fee payments, and the client should be aware that the firm is not Page 7  Item 5: Fees and Compensation selecting from among all mutual funds available in the marketplace when recommending mutual funds to the client. Conflict Between Revenue Share Class (12b-1) and Non-Revenue Share Class Mutual Funds: Revenue share class/12b-1 fees are deducted from the net asset value of the mutual fund and generally, all things being equal, cause the fund to earn lower rates of return than those mutual funds that do not pay revenue sharing fees. The client is under no obligation to utilize such programs or mutual funds. Although many factors will influence the type of fund to be used, the client should discuss with their investment adviser representative whether a share class from a comparable mutual fund with a more favorable return to investors is available that does not include the payment of any 12b-1 or revenue sharing fees given the client’s individual needs and priorities and anticipated transaction costs. In addition, the receipt of such fees can create conflicts of interest in instances where the custodian receives the entirety of the 12b-1 and/or revenue sharing fees and takes the receipt of such fees into consideration in terms of benefits it may elect to provide to the firm, even though such benefits may or may not benefit some or all of the firm clients. Page 8  Item 6: Performance-Based Fees and Side-by-Side Management Item 6: Performance-Based Fees and Side-by-Side Management SafisLife does not charge performance-based fees and therefore has no economic incentive to manage clients’ portfolios in any way other than what is in their best interests. Page 9  Item 7: Types of Clients Item 7: Types of Clients SafisLife provides its services to individuals. SafisLife has a minimum account size/investment of $5,000. SafisLife reserves the right to waive the minimum. Page 10  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis and Investment Strategies SafisLife uses a variety of sources of data to conduct its economic, investment and market analysis, such as financial newspapers and magazines, economic and market research materials prepared by others, conference calls hosted by mutual funds, corporate rating services, annual reports, prospectuses, and company press releases. It is important to keep in mind that there is no specific approach to investing that guarantees success or positive returns; investing in securities involves risk of loss that clients should be prepared to bear. SafisLife and its investment adviser representatives are responsible for identifying and implementing the methods of analysis used in formulating investment recommendations to clients. The methods of analysis may include quantitative methods for optimizing client portfolios, computer-based risk/return analysis, technical analysis, and statistical and/or computer models utilizing long-term economic criteria. ▪ Optimization involves the use of mathematical algorithms to determine the appropriate mix of assets given the firm’s current capital market rate assessment and a particular client’s risk tolerance. ▪ Quantitative methods include analysis of historical data such as price and volume statistics, performance data, standard deviation and related risk metrics, how the security performs relative to the overall stock market, earnings data, price to earnings ratios, and related data. ▪ Technical analysis involves charting price and volume data as reported by the exchange where the security is traded to look for price trends. ▪ Computer models may be used to derive the future value of a security based on assumptions of various data categories such as earnings, cash flow, profit margins, sales, and a variety of other company specific metrics. In addition, SafisLife reviews research material prepared by others, as well as corporate filings, corporate rating services, and a variety of financial publications. SafisLife may employ outside vendors or utilize third-party software to assist in formulating investment recommendations to clients. Recommendation of Portfolios SafisLife will assist the client in selecting an appropriate risk-based model strategy for the client’s portfolio. A description of the criteria to be used in formulating an investment recommendation for model portfolios is set forth below. SafisLife may utilize additional independent third parties to assist it in recommending portfolios. SafisLife reviews certain quantitative and qualitative criteria related to mutual or exchange traded funds and to formulate investment recommendations to its clients. Quantitative criteria may include: Page 11  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ▪ the performance history of an ETF manager evaluated against that of its peers and other benchmarks ▪ an analysis of risk-adjusted returns ▪ an analysis of returns over specific time periods, sector, and style analysis ▪ the fund’s fee structure ▪ the relevant portfolio manager’s tenure Qualitative criteria used in selecting/recommending managers include the investment objectives and/or management style and philosophy of a mutual fund or manager; a mutual fund or manager’s consistency of investment style; and employee turnover and efficiency and capacity. SafisLife will regularly review the activities of the portfolios selected by the client. Risk of Loss The securities in the portfolios typically consist of ETFs, which are subject to some or all of the following risk factors: ETFs are investment companies whose shares are bought and sold on a securities exchange. An ETF holds a portfolio of securities designed to track a particular market segment or index. Some examples of ETFs are SPDRs®, streetTRACKS®, DIAMONDSSM, NASDAQ 100 Index Tracking StockSM (“QQQs SM”) iShares® and VIPERs®. ETFs have embedded expenses that the client indirectly bears. Investing in ETFs involves risk. Specifically, ETFs, depending on the underlying portfolio and its size, can have wide price (bid and ask) spreads, thus diluting or negating any upward price movement of the ETF or enhancing any downward price movement. Also, ETFs require more frequent portfolio reporting by regulators and are thereby more susceptible to actions by hedge funds that could have a negative impact on the price of the ETF. Certain ETFs may employ leverage, which creates additional volatility and price risk depending on the amount of leverage utilized, the collateral and the liquidity of the supporting collateral. Further, the use of leverage (i.e., employing the use of margin) generally results in additional interest costs to the ETF. Certain ETFs are highly leveraged and therefore have additional volatility and liquidity risk. Volatility and liquidity can severely and negatively impact the price of the ETF’s underlying portfolio securities, thereby causing significant price fluctuations of the ETF. B. Investment Strategy and Method of Analysis Material Risks Our investment strategy is custom-tailored to the client’s goals, investment objectives, risk tolerance, and personal and financial circumstances. For this TAMP portfolio program. SafisLife employs a passively-managed portfolio strategy. The investment strategy for a specific client is based upon the objectives stated by the client during consultations, and on their risk profile. The client may change these objectives at any time and should notify SafisLife immediately of these changes. Page 12  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss C. Security-Specific Material Risks There is an inherent risk for clients who have their investment portfolios heavily weighted in one security, one industry or industry sector, one geographic location, one investment manager, one type of investment instrument (equities versus fixed income). Clients who have diversified portfolios, as a general rule, incur less volatility and therefore less fluctuation in portfolio value than those who have concentrated holdings. Concentrated holdings may offer the potential for higher gain, but also offer the potential for significant loss. Page 13  Item 9: Disciplinary Information Item 9: Disciplinary Information A. Criminal or Civil Actions There is nothing to report on this item. B. Administrative Enforcement Proceedings There is nothing to report on this item. C. Self-Regulatory Organization Enforcement Proceedings There is nothing to report on this item. Page 14  Item 10: Other Financial Industry Activities and Affiliations Item 10: Other Financial Industry Activities and Affiliations A. Broker-Dealer or Representative Registration Neither SafisLife nor its supervised persons are registered broker-dealers and do not have an application to register pending. B. Futures or Commodity Registration Neither SafisLife nor its affiliates are registered as a commodity firm, futures commission merchant, commodity pool operator or commodity trading advisor and do not have an application to register pending. C. Material Relationships Maintained by this Advisory Business and Conflicts of Interest FORUM Credit Union SafisLife is under common control with FORUM Credit Union, a federal credit union. SafisLife may recommend FORUM Credit Union and its products to its clients to fulfill their banking needs. Clients are advised that any such referral is an inherent conflict of interest due to (i) the common ownership among the companies, and (ii) the indirect economic benefit SafisLife receives from FORUM Credit Union products, such as the savings account. Registration as Insurance Agency FORUM Credit Union is a duly licensed insurance agency. Additionally, certain of SafisLife’s supervised persons are licensed insurance agents with FORUM Credit Union, and in such capacity, may recommend, on a fully disclosed basis, the purchase of certain insurance products. A conflict of interest exists to the extent that SafisLife or its supervised persons recommend the purchase of insurance products where FORUM Credit Union or SafisLife’s supervised persons receive insurance commissions or other additional compensation. SafisLife strives to put its clients’ interests first and foremost, and clients may utilize any insurance carrier or insurance agency they desire. D. Recommendation or Selection of Other Investment Advisors and Conflicts of Interest SafisLife does not recommend separate account managers or other investment products in which it receives any form of referral or solicitor compensation from the separate account manager or client. Page 15  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Description In accordance with the Advisers Act, SafisLife has adopted policies and procedures designed to detect and prevent insider trading. In addition, SafisLife has adopted a Code of Ethics (the “Code”). Among other things, the Code includes written procedures governing the conduct of SafisLife's advisory and access persons. The Code also imposes certain reporting obligations on persons subject to the Code. The Code and applicable securities transactions are monitored by the chief compliance officer of SafisLife. SafisLife will send clients a copy of its Code of Ethics upon written request. SafisLife has policies and procedures in place to ensure that the interests of its clients are given preference over those of SafisLife, its affiliates and its employees. For example, there are policies in place to prevent the misappropriation of material non-public information, and such other policies and procedures reasonably designed to comply with federal and state securities laws. B. Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest SafisLife does not engage in principal trading (i.e., the practice of selling stock to advisory clients from a firm’s inventory or buying stocks from advisory clients into a firm’s inventory). In addition, SafisLife does not recommend any securities to advisory clients in which it has some proprietary or ownership interest. C. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest SafisLife, its affiliates, employees and their families, trusts, estates, charitable organizations and retirement plans established by it may purchase the same securities as are purchased for clients in accordance with its Code of Ethics policies and procedures. The personal securities transactions by advisory representatives and employees may raise potential conflicts of interest when they trade in a security that is: ▪ owned by the client, or ▪ considered for purchase or sale for the client. Such conflict generally refers to the practice of front-running (trading ahead of the client), which SafisLife specifically prohibits. SafisLife has adopted policies and procedures that are intended to address these conflicts of interest. These policies and procedures: ▪ require our advisory representatives and employees to act in the client’s best interest ▪ prohibit fraudulent conduct in connection with the trading of securities in a client account Page 16  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ▪ prohibit employees from personally benefitting by causing a client to act, or fail to act in making investment decisions ▪ prohibit the firm or its employees from profiting or causing others to profit on knowledge of completed or contemplated client transactions ▪ allocate investment opportunities in a fair and equitable manner ▪ provide for the review of transactions to discover and correct any trades that result in an advisory representative or employee benefitting at the expense of a client. Advisory representatives and employees must follow SafisLife’s procedures when purchasing or selling the same securities purchased or sold for the client. D. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest SafisLife, its affiliates, employees and their families, trusts, estates, charitable organizations, and retirement plans established by it may effect securities transactions for their own accounts that differ from those recommended or effected for other SafisLife clients. The firm does not engage in aggregation or bulk trading, and does not conduct average pricing calculations. It is the policy of SafisLife to place the clients’ interests above those of SafisLife and its employees. Page 17  Item 12: Brokerage Practices Item 12: Brokerage Practices A. Factors Used to Select Broker-Dealers for Client Transactions Custodian Recommendations For clients participating in the Betterment TAMP, Betterment Securities, a registered broker- dealer, member SIPC, will be the qualified custodian for client accounts using Betterment LLC and/or Betterment Institutional. Clients will open the account with Betterment Securities by entering into an account agreement directly with them. While we do not open the account for you, we may assist you in doing so. SafisLife is independently owned and operated and not affiliated with Betterment. Client’s Custody and Brokerage Costs For client accounts that Betterment Securities maintains, Betterment Securities generally does not charge separately for custody services. It is instead compensated as part of the Betterment Institutional platform fee, which is a percentage of the dollar amount of assets in the account in lieu of commissions. SafisLife has determined that having Betterment Securities execute trades is consistent with its duty to seek “best execution” of trades (see above). Soft Dollar Arrangements While SafisLife has no formal soft dollars program in which soft dollars are used to pay for third party services, SafisLife may receive research, products, or other services from its broker/dealer in connection with client securities transactions (“soft dollar benefits”) consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended, and may consider these benefits in recommending brokers. There can be no assurance that any particular client will benefit from any particular soft dollar research or other benefits. SafisLife benefits by not having to produce or pay for the research, products or services, and SafisLife will have an incentive to recommend a broker dealer based on receiving research or services. Clients should be aware that SafisLife’s acceptance of soft dollar benefits may result in higher commissions charged to the client. Institutional Trading and Custody Services Betterment Securities serves as broker-dealer to Betterment Institutional, an investment and advice platform serving independent investment advisory firms. Betterment Institutional also offers available various support services, which may not be available to its retail customers. Some of those services help SafisLife manage or administer client accounts, while others help us manage and grow our business. Betterment Institutional’s support services are generally available on an unsolicited basis (SafisLife does not have to request these services) and at no additional charge to SafisLife. Page 18  Item 12: Brokerage Practices Other Products and Services Betterment Institutional also makes available to SafisLife other products and services that benefit SafisLife but may not directly benefit the client or client accounts. These products and services assist SafisLife in managing and administering client accounts, such as software and technology that may: ▪ Assist with back-office functions, recordkeeping, and client reporting of our accounts. ▪ Provide access to client account data (such as duplicate trade confirmations and account statements). ▪ Provide pricing and other market data. ▪ Assist with back-office functions, recordkeeping, and client reporting. The custodian may also provide other benefits such as educational events or occasional business entertainment of SafisLife personnel. In evaluating whether to recommend that clients custody their assets at the custodian, SafisLife may take into account the availability of some of the foregoing products and services and other arrangements as part of the total mix of factors it considers, and not solely the nature, cost or quality of custody and brokerage services provided by the custodian, which creates a conflict of interest. The Firm’s Interest in Custodian’s Services The availability of these services from Betterment Institutional benefits SafisLife because we do not have to produce or purchase them. In addition, SafisLife does not have to pay an additional fee for Betterment Securities’ services, although these services may be contingent upon SafisLife committing a certain amount of assets to Betterment Securities for custody. SafisLife has an incentive to have clients maintain their accounts with Betterment Securities based on SafisLife’s interest in receiving Betterment Institutional’s and Betterment Securities’ services that benefit our business rather than based on clients’ interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. However, the availability to us of Betterment Institutional’s and Betterment Securities’ products and services is not based on SafisLife giving particular investment advice, such as buying particular securities for its clients. Moreover, SafisLife believes that use of Betterment Securities as custodian and broker-dealer is in the clients’ best interests and consistent with SafisLife’s fiduciary duty. SafisLife’s selection of Betterment Securities is primarily supported by the scope, quality, and price of services (described above) rather than Betterment Institutional’s and Betterment Securities’ services that benefit SafisLife directly. As part of its fiduciary duties to clients, SafisLife endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by SafisLife or its related persons in and of itself creates a conflict of interest and indirectly influences SafisLife’s recommendation of broker-dealers for custody and brokerage services. Page 19  Item 12: Brokerage Practices B. Aggregating Securities Transactions for Client Accounts Best Execution SAFISLife is recommending Betterment’s wrap fee program and therefore Betterment’s trading and advisory fees are wrapped into one all-inclusive fee from Betterment, which is in addition to SAFISLife’s advisory fee. Page 20  Item 13: Review of Accounts Item 13: Review of Accounts A. Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved For those clients to whom SafisLife provides investment management services, SafisLife monitors those portfolios as part of an ongoing process while regular account reviews are conducted on at least an annual basis. All investment advisory clients are encouraged to discuss their needs, goals, and objectives with SafisLife and to keep SafisLife informed of any changes thereto. SafisLife contacts ongoing investment advisory clients at least annually to review its previous services and/or recommendations and to discuss the impact resulting from any changes in the client’s financial situation and/or investment objectives. B. Review of Client Accounts on Non-Periodic Basis SafisLife may perform ad hoc reviews on an as-needed basis if there have been material changes in the client’s investment objectives or risk tolerance, or a material change in how SafisLife formulates investment advice. C. Content of Client-Provided Reports and Frequency The client’s independent custodian provides account statements directly to the client no less frequently than quarterly. Clients should compare the account statements they receive from their custodian with those they receive from SafisLife. The custodian’s statement is the official record of the client’s securities account and supersedes any statements or reports created on behalf of the client by SafisLife. Page 21  Item 14: Client Referrals and Other Compensation Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest Please refer to the disclosures in Items 10 and 12 regarding referrals to affiliates and third-party service providers and benefits the firm receives from its custodian(s). SafisLife may receive economic benefits for referring clients to affiliate and third-party service providers. You are under no obligation to utilize any service provider recommended to you by SafisLife or its affiliates. The firm may from time to time receive expense reimbursement for travel and/or marketing expenses from distributors of investment and/or insurance products. Travel expense reimbursements are typically a result of attendance at due diligence and/or investment training events hosted by product sponsors. Marketing expense reimbursements are typically the result of informal expense sharing arrangements in which product sponsors may underwrite costs incurred for marketing, such as advertising, publishing, and seminar expenses. Although receipt of these travel and marketing expense reimbursements are not predicated upon specific sales quotas, the product sponsor reimbursements are typically made by those sponsors for whom sales have been made or it is anticipated sales will be made. This creates a conflict of interest in that there is an incentive to recommend certain products and investments based on the receipt of this compensation instead of what is the in best interest of our clients. We attempt to control for this conflict by always basing investment decisions on the individual needs of our clients. B. Advisory Firm Payments for Client Referrals Employees of SafisLife’s affiliate, FORUM Credit Union, may recommend to clients our firm’s financial services and receive a referral fee. The receipt of such compensation creates a conflict of interest in that FORUM Credit Union has an economic interest to recommend our firm. Please be advised that the payment of a referral fee does not increase the client’s advisory fee paid to the firm. Page 22  Item 15: Custody Item 15: Custody SafisLife is considered to have custody of client assets for purposes of the Advisers Act for the following reasons: ▪ The client authorizes us to instruct their custodian to deduct our advisory fees directly from the client’s account. ▪ Our authority to direct client requests, utilizing standing instructions, for wire transfer of funds for first-party money movement and third-party money movement (checks and/or journals, ACH, Fed-wires). The firm has elected to meet the SEC’s seven conditions to avoid the surprise custody exam, as outlined below: 1. The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. 2. The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. 3. The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization, and provides a transfer of funds notice to the client promptly after each transfer. 4. The client has the ability to terminate or change the instruction to the client’s qualified custodian. 5. The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. 6. The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. 7. The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. Individual advisory clients will receive at least quarterly account statements directly from their custodian containing a description of all activity, cash balances, and portfolio holdings in their accounts. SafisLife urges its clients to compare the account balance(s) shown on their account statements to the quarter-end balance(s) on their custodian's monthly statement. The custodian’s statement is the official record of the account. Page 23  Item 16: Investment Discretion Item 16: Investment Discretion Clients may grant a limited power of attorney to SafisLife with respect to trading activity in their accounts by signing the appropriate custodian limited power of attorney form. In those cases, SafisLife will exercise full discretion as to the selection of portfolios. Page 24  Item 17: Voting Client Securities Item 17: Voting Client Securities SafisLife does not take discretion with respect to voting proxies on behalf of its clients. SafisLife will endeavor to make recommendations to clients on voting proxies regarding shareholder vote, consent, election or similar actions solicited by, or with respect to, issuers of securities beneficially held as part of SafisLife supervised and/or managed assets. In no event will SafisLife take discretion with respect to voting proxies on behalf of its clients. Except as required by applicable law, SafisLife will not be obligated to render advice or take any action on behalf of clients with respect to assets presently or formerly held in their accounts that become the subject of any legal proceedings, including bankruptcies. From time to time, securities held in the accounts of clients will be the subject of class action lawsuits. SafisLife has no obligation to determine if securities held by the client are subject to a pending or resolved class action lawsuit. SafisLife also has no duty to evaluate a client’s eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, SafisLife has no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients. Where SafisLife receives written or electronic notice of a class action lawsuit, settlement, or verdict affecting securities owned by a client, it will forward all notices, proof of claim forms, and other materials to the client. Electronic mail is acceptable where appropriate and where the client has authorized contact in this manner. Page 25  Item 18: Financial Information Item 18: Financial Information A. Balance Sheet SafisLife does not require the prepayment of fees of $1200 or more, six months or more in advance, and as such is not required to file a balance sheet. B. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients SafisLife does not have any financial issues that would impair its ability to provide services to clients. C. Bankruptcy Petitions During the Past Ten Years There is nothing to report on this item. Page 26