FOUNDATIONS INVESTMENT ADVISORS LLC

Firm Brochure (Part 2A of Form ADV) Foundations Investment Advisors, LLC 4050 East Cotton Center Blvd., Suite 40 Phoenix, AZ 85040 PHONE: 480-626-2979 FAX: 480-747-9661 Website: www.fiwealth.com This brochure provides information about the qualifications and business practices of Foundations Investment Advisors, LLC (“FOUNDATIONS” or the “Firm”). Being registered as a registered investment adviser does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at 480-626-2979 or by email at cco@fiwealth.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about Foundations Investment Advisors, LLC (IARD # 175083) is available on the SEC’s website at www.adviserinfo.sec.gov. September 4, 2025 Page | 1 Foundations Investment Advisors, LLC  Item 2: Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. Each year, we will ensure that you receive a summary of any material changes to this and subsequent brochures no later than thirty days after the changes have been updated. We will further provide you with our most recent brochure at any time at your request, without charge. You may request a copy of our most recent brochure by contacting us at (480) 626-2979 or by email at cco@fiwealth.com. Material Changes since the Last Update Since the most recent update of our Form ADV Part 2A, dated July 1, 2025, FOUNDATIONS has made the following material changes to this Brochure as summarized below and found in more detail under the following items: Item 4: Advisory Business: • Clarified description of the Firm’s principal ownership structure. • Removed reference to previously disclosed contractual COO relationship. • Added disclosure regarding appointment of Josh Cooksey as COO. • Added disclosure regarding upcoming CEO transition effective October 1, 2025. • Updated information regarding Asset Management Services. • Added information related to Third-Party Retirement Plan Provider Relationships. Item 5: Fees and Compensation: • Added clarification regarding how financial planning fees are assessed. Item 10: Other Financial Industry Activities and Affiliations: • Added clarification regarding the Firm's role with respect to insurance products. • Added disclosure regarding estate planning–related administrative services offered outside the Firm. Miscellaneous: • Updated the Firm’s Privacy Protection Policy. Full Brochure Available This Firm Brochure being delivered is the complete brochure for the Firm. Page | 2 Foundations Investment Advisors, LLC  Item 3: Table of Contents Item 2: Material Changes .................................................................................................................................... 2 Annual Update ...................................................................................................................................................................................... 2 Material Changes since the Last Update ..................................................................................................................................... 2 Full Brochure Available ..................................................................................................................................................................... 2 Item 3: Table of Contents .................................................................................................................................... 3 Item 4: Advisory Business .................................................................................................................................. 6 Firm Description .................................................................................................................................................................................. 6 Types of Advisory Services ............................................................................................................................................................... 7 Client Tailored Services and Client Imposed Restrictions ................................................................................................. 11 Client Assets Under Management .............................................................................................................................................. 12 Item 5: Fees and Compensation ..................................................................................................................... 13 Method of Compensation and Fee Schedule ........................................................................................................................... 13 Client Payment of Fees .................................................................................................................................................................... 14 Financial Planning ............................................................................................................................................................................ 14 Additional Client Fees Charged .................................................................................................................................................... 15 Prepayment of Client Fees ............................................................................................................................................................. 16 External Compensation for the Sale of Securities to Clients ............................................................................................. 16 Advice Related to Rollovers of an Employer-Sponsored Plan ....................................................................................... 16 Item 6: Performance-Based Fees ................................................................................................................... 17 Sharing of Capital Gains.................................................................................................................................................................. 17 Item 7: Types of Clients .................................................................................................................................... 17 Description .......................................................................................................................................................................................... 17 Account Minimums ........................................................................................................................................................................... 17 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................................ 18 Methods of Analysis and Investment Strategies ................................................................................................................... 18 Investment Strategy and Method of Analysis Material Risks .......................................................................................... 18 Security Specific Material Risks ................................................................................................................................................... 19 Item 9: Disciplinary Information ................................................................................................................... 22 Page | 3 Foundations Investment Advisors, LLC  Criminal or Civil Actions................................................................................................................................................................. 22 Administrative Enforcement Proceedings ............................................................................................................................... 22 Self-Regulatory Organization Enforcement Proceedings................................................................................................... 22 Item 10: Other Financial Industry Activities and Affiliations ................................................................ 22 Broker-Dealer or Representative Registration .................................................................................................................... 22 Futures or Commodity Registration ........................................................................................................................................ 22 Material Relationships Maintained by this Advisory Business and Conflicts of Interest .................................. 22 Affiliation with Alpha 1 Tax and Wealth Management, LLC........................................................................................... 26 Affiliation with Northern Alliance Financial, LLC ............................................................................................................... 27 Affiliation with Asset Preservation Tax & Retirement, LLC ........................................................................................... 27 Affiliation with Omega Wealth Private Capital, LLC.............................................................................................................. 28 Affiliation with Charter Law Group, LLC ................................................................................................................................ 28 Item 11: Code of Ethics, Participation or Interest in Client Transactions .......................................... 29 Code of Ethics Description ............................................................................................................................................................ 29 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest ................................................................................................................................................................ 30 Potential Restrictions and Conflicts Relating to Information Possessed or Provided By The Firm ........... 30 Item 12: Brokerage Practices ......................................................................................................................... 33 Factors Used to Select Broker-Dealers for Client Transactions ...................................................................................... 33 Aggregating Securities Transactions for Client Accounts .................................................................................................. 34 Trade Errors ....................................................................................................................................................................................... 34 Item 13: Review of Accounts .......................................................................................................................... 36 Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved .......... 36 Review of Client Accounts on Non-Periodic Basis................................................................................................................ 36 Content of Client Provided Reports and Frequency ............................................................................................................ 36 Item 14: Client Referrals and Other Compensation .............................................................................. 36 Economic benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest ......... 36 Advisory Firm Payments for Client Referrals......................................................................................................................... 37 Item 15: Custody ................................................................................................................................................ 39 Account Statements ......................................................................................................................................................................... 39 Standing Letters of Authorization .............................................................................................................................................. 39 Item 16: Investment Discretion ...................................................................................................................... 40 Discretionary Authority for Trading .......................................................................................................................................... 40 Page | 4 Foundations Investment Advisors, LLC  Item 17: Voting Client Securities ................................................................................................................... 40 Proxy Votes ......................................................................................................................................................................................... 40 Item 18: Financial Information ...................................................................................................................... 41 Balance Sheet ..................................................................................................................................................................................... 41 Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients ................................................................................................................................................................................................... 41 Bankruptcy Petitions during the Past Ten Years .................................................................................................................. 41 Miscellaneous ..................................................................................................................................................... 42 Class Action Suits .............................................................................................................................................................................. 42 Consent to Electronic Delivery .................................................................................................................................................... 42 Confidentiality and Privacy Notice ............................................................................................................................................. 42 Page | 5 Foundations Investment Advisors, LLC  Item 4: Advisory Business Firm Description Foundations Investment Advisors, LLC, (“FOUNDATIONS” or “Advisor”) is a registered investment adviser based in Phoenix, Arizona. The Firm was formed as a limited liability company under the laws of the State of Arizona. Founded in 2015, FOUNDATIONS provides investment advisory services through a network of affiliated offices that provide advisory services under local “doing business as” or “dba” names. A complete list of approved affiliated dba names can be requested by contacting the Firm. A list of the 25 largest affiliate offices, as required by Form ADV, can be found in the information filed by FOUNDATIONS, IARD# 175083, on its Form ADV, Item 1B on the SEC’s website at www.adviserinfo.sec.gov. Investment advisory services may include, but are not limited to, determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning. Our investment advice is tailored to work with our clients’ financial goals, investment objectives and risk tolerances. to as your The investment advisory services of FOUNDATIONS are provided to you through an licensed and qualified individual who is an investment adviser appropriately “Investment Adviser representative of FOUNDATIONS (referred Representative” or “IAR” throughout this brochure). Your IAR may either be an employee of FOUNDATIONS or an independent contractor. IARs are free to negotiate the fees to be charged for the services provided within the parameters set by FOUNDATIONS, as disclosed in Item 5 – Fees and Compensation of this brochure. It is possible that different IARs may charge different fees for providing the same service to clients. The specific level of services you will receive and the fees you will be charged will be specified in your investment advisory agreement. Certain Associated Persons or IARs of Foundations are entitled to a portion of the advisory fees charged by Foundations. As used in this brochure, the words, “we,” “our,” and “us” refer to FOUNDATIONS and the words “you,” “your,” and “client” refer to you as either a client or prospective client of our Firm. In addition, you may see the term “Associated Person” throughout this brochure. As used in this brochure, our Associated Persons are our Firm’s officers, employees and all individuals providing investment advice on behalf of our Firm. FOUNDATIONS’ majority owner is through a trust controlled by Mr. Bryon Rice. In January 2022, Jarrod Florence, President of Magellan Financial and Insurance Services, became President of FOUNDATIONS. Magellan Financial and Insurance Services and FOUNDATIONS are under common ownership and control by Bryon Rice. Effective September 1, 2025, the Firm retained Josh Cooksey as Chief Operating Officer (“COO”) on a full-time basis. Page | 6 Foundations Investment Advisors, LLC  On September 4, 2025, FOUNDATIONS announced plans for current Chief Financial Officer (“CFO”), Kyle Mann, to take over Chief Executive Officer (“CEO”) responsibilities as of October 1, 2025. Current CEO and FOUNDATIONS founder, Bryon Rice, will be stepping down from the CEO position to dedicate more time to his original business, Magellan Financial and Insurance Services, which he co-founded in 2003. Mr. Mann will also continue to serve in his role as CFO. Please refer to Item 10 – Other Financial Industry Activities and Affiliations of this brochure for additional information. Types of Advisory Services Asset Management Services FOUNDATIONS provides investment advisory and portfolio management services on a continuing basis, which may include the review of client investment objectives and goals, recommending asset allocation strategies of managed assets among investment products such as cash, stocks, ETFs, mutual funds, bonds, and other liquid securities. Although we generally provide advice only on the products previously listed, we reserve the right to offer advice on any investment product (including, without limitation, interval funds; tender offer funds; closed end funds; interests in real estate funds, oil and gas funds, private equity funds, hedge funds, or venture funds, OTC securities; and other securities or investment products that are not available on any national securities exchange or futures/commodities exchange (or international equivalent)) that may be suitable for each client’s specific circumstances, needs, goals, objectives and risk tolerance. It is not our typical investment strategy to attempt to time the market, but we may increase cash holdings as deemed appropriate based on your risk tolerance and our expectations of market behavior. We may modify our investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. Our investment advice is tailored to meet our clients’ unique needs, investment objectives and risk tolerance. During your initial meeting with your IAR, you’re asked to complete a confidential client profile to help us understand your risk tolerance and long-term financial goals. A specific asset allocation strategy and suitability profile is crafted to focus on your specific goals and objectives. The confidential client profile defines your risk tolerance and investment objectives. Your information should be updated annually. You must appoint our Firm as your investment advisor of record on specified accounts (collectively, the “Account”). The Account consists only of separate account(s) held by qualified custodian(s) under your name. The qualified custodians maintain physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account. FOUNDATIONS provides discretionary and non-discretionary investment advisory Page | 7 Foundations Investment Advisors, LLC  services to its clients through various managed account programs. With discretionary authority, we make all decisions to buy, sell or hold securities, cash or other investments in the managed account in our sole discretion without consulting with you before implementing any transactions. You must provide us with written authorization to exercise this discretionary authority. Discretionary authority is limited. We do not have access to your funds and/or securities with the exception of having advisory fees deducted from your account and paid to us by the account custodian. Any fee deduction is done pursuant to your prior written authorization provided to the account custodian. You have the ability to place reasonable restrictions on the types of investments that may be purchased in an account. You may also place reasonable limitations on the discretionary power granted to us so long as the limitations are specifically set forth or included as an attachment to the client agreement. However, FOUNDATIONS retains the right to decline to enter into a management agreement with any client whose investment restrictions are contrary to the Firm’s investment strategies. (Please see Item 16 - Investment Discretion for additional information concerning discretionary authority.) As more fully described in Item 5 – Fees and Compensation below, the annual fee is assessed on a monthly or quarterly schedule, either in advance or in arrears, and calculated based upon the client's average daily balance calculated by the Custodian for the period, either monthly or quarterly. Before we assess any fees or provide formal advice, we will provide you with an Investment Advisory Agreement (“Agreement”) for your review, understanding and signature. The Agreement includes the terms and conditions under which your assets will be managed. Your execution of the Agreement authorizes our Firm to determine the specific securities, and the amount of securities to be purchased or sold for your account without your approval prior to each transaction. The Agreement will remain in effect between you and us until terminated by either party in writing according to the terms contained in the Agreement. In the event a conflict exists between the Agreement and our Form ADV, the Form ADV shall prevail. The Agreement will include schedules of the investment accounts you wish us to manage, the specific fees we propose to charge and how we propose to bill and collect those fees. Agreements may not be assigned without written client consent. Advisory accounts will be held primarily by Fidelity Investments, Charles Schwab & Co., Inc., BNY Mellon Pershing, or other qualified custodians as approved by FOUNDATIONS (each individually, a “Custodian”). The client must designate FOUNDATIONS as its Investment Adviser on their accounts. The client’s qualified Custodian will maintain actual custody of all client funds and securities. Custodians are also broker/dealers, and they may have different account fees, execution charges and capacities. Custodial services are based on several factors, which may include, but are not limited to: cost, expected level of asset safety, client confidentiality, communication and reporting requirements. In certain circumstances, the account Custodian can offer the option of charging execution Page | 8 Foundations Investment Advisors, LLC  fees based upon the level of assets maintained in the managed account (asset-based pricing) versus implementing a fee for each transaction executed (commission-based pricing). FOUNDATIONS only offers asset-based pricing. You should consider the cost/benefit analysis to determine if your particular circumstances would be better served in a commission-based fee account. Whether transaction-based pricing or asset- based pricing is in the best interest of an individual client may vary over the span of a client relationship in response to possible service provider contractual changes and/or overall market condition adjustments to our pricing structure. Important Disclosure(s) Regarding Fee Based Asset Management Accounts When making the determination of whether one of the advisory programs available through FOUNDATIONS is appropriate for your needs, you should bear in mind that fee- based accounts, when compared with commission-based accounts, often result in lower costs during periods when trading activity is heavier, such as the year an account is established. However, during periods when trading activity is lower, the fee-based account arrangements may result in a higher annual cost for transactions. Nevertheless, any trade execution charges, and independent manager fees are absorbed within the advisory fee that clients pay to FOUNDATIONS. In addition, the independent brokers and custodians we expect to utilize make a wide variety of investments available that do not incur any trading costs at all. Thus, depending on a number of factors, the total cost for transactions under a fee account versus a commission account can vary significantly. Factors which affect the total cost include account size, amount of turnover, type and quantities of securities purchased or sold, commission rates and your tax situation. It should also be noted that lower fees for comparable service may be available from other sources. You should discuss the advantages and disadvantages of fee-based and commission-based accounts with your IAR. The differences in the types of accounts available to clients creates a conflict of interest in that it incentivizes FOUNDATIONS to trade in the account less frequently and to select securities that are subject to waived or reduced transaction charges. FOUNDATIONS manages this conflict by strict adherence to our Code of Ethics and our fiduciary duty to always act in the best interest of our clients. When we are providing investment advice to accounts that are subject to ERISA regulations (or corresponding provisions of Internal Revenue Code (IRC) Section 4975), we are fiduciaries within the meaning of Title I of ERISA and the IRC which govern retirement accounts. This may create a conflict of interest, so we are subject to a special rule that requires us to act in your best interests. Sub-Advisory Investment Management Services for Advisers FOUNDATIONS offers investment sub-advisory services to unaffiliated registered investment advisers (“RIAs”). Unaffiliated RIAs may choose to engage FOUNDATIONS for investment management of some or all of their clients’ assets. FOUNDATIONS shall have day-to-day responsibility for the active discretionary management of the allocated assets through a limited power of attorney from the unaffiliated RIA’s client. The unaffiliated RIA shall continue to render investment advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment Page | 9 Foundations Investment Advisors, LLC  objectives. The unaffiliated RIAs may receive compensation for referring clients to FOUNDATIONS under a written sub-advisory or solicitation agreement, as required by applicable regulations. Use of Other Investment Advisory Firms as Sub-Advisers At its discretion, FOUNDATIONS may utilize other investment advisory firms as sub- advisers to assist us with the development and recommendation of appropriate investment options for your Account. In such cases the Agreement will designate both FOUNDATIONS and the unaffiliated sub-adviser as managers of the Account and the client will receive required disclosures about both firms. We review several factors when determining which sub-advisers and/or model portfolios are most suitable for clients. Additionally, IARs assigned to the account will meet with clients on a periodic basis to discuss potential changes in their personal or financial situation, suitability, and any new or revised restrictions to be applied to the account. The Firm may utilize independent third parties to assist in recommending and monitoring sub-advisers as necessary. Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss of this brochure for additional information on how we select a third-party service provider or sub-adviser. Third-Party Retirement Plan Provider Relationships Foundations and its IARs may assist clients and provide certain services with respect to employer-sponsored retirement plan solutions that are offered and managed by unaffiliated financial institutions. In such cases, Foundations does not act as a fiduciary or sub-adviser to the plan, nor does it exercise investment discretion over plan assets; such services are performed by unaffiliated third-party investment advisers, financial institutions, and/or plan fiduciaries An IAR of Foundations may be designated as a servicing representative to a plan and Foundations and the IAR would receive compensation for supporting the plan or assisting with participant education or enrollment. This creates a conflict of interest, as the IAR may have a financial incentive to recommend plan solutions that result in higher compensation to the IAR and/or Foundations. Clients are encouraged to review all available documents, options and ask questions before enrolling in any employer-sponsored plan and making any investment related decision concerning the Client’s allocation of assets within a plan. Educational Seminars/Workshops FOUNDATIONS occasionally provides seminars/workshops in areas such as financial planning, retirement planning, estate planning, college planning and charitable planning or other relevant financial topics. Seminars/workshops are always offered on an impersonal basis and do not focus on the individual needs of participants. No fees are charged for seminars. Please refer to Item 5 – Fees and Compensation and Item 10 – Other Financial Industry Activities and Affiliations for additional information. Page | 10 Foundations Investment Advisors, LLC  Conflicts of Interest Certain affiliations with other service providers, as well as FOUNDATIONS’ sub- advisory and profit-sharing agreements create material conflicts of interest because they provide FOUNDATIONS and/or its related persons with incentives to direct client assets in or with certain sub-advisors, and/or model providers, where there is an existing relationship and/or affiliation, or for which FOUNDATIONS or its affiliates provide advisory or sub-advisory services. Please refer to Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss and Item 10 – Other Financial Industry Activities and Affiliations for additional information related to these conflicts. Client Tailored Services and Client Imposed Restrictions The goals, objectives, risk tolerance and client-imposed restrictions for each client are documented in our client files. Investment strategies are created that seek to reflect the stated unique needs and investment objectives of the client. Clients may impose reasonable restrictions on investing in certain securities or types of securities with written notification. However, FOUNDATIONS retains the right to decline to enter into a management agreement with any client whose investment restrictions are contrary to the Firm’s investment strategies. Model portfolios used in connection with client accounts (hereafter “Accounts” or the “Accounts”), will be used to periodically monitor for drift versus target asset allocations and portfolio weightings. When market conditions or deposits to and withdrawals from Accounts cause assets to deviate over time from the model portfolio, and such deviations become materially significant (as determined by our parameters), then the Accounts will be rebalanced to align more closely with the model portfolio, provided the Accounts meets the minimum balance requirement for that particular model or strategy. FOUNDATIONS’ current approach to rebalancing employs an asymmetric rebalancing strategy, i.e., applying a percentage threshold for overweight assets, and a dollar threshold for underweight assets. Rebalancing occurs when assets are deemed materially overweight or underweight (taking into account allocation parameters and size of the Account), and when sufficient cash has been accumulated. The intent of this process is to: participate in the potential momentum for appreciation (avoiding purchases of declining assets); control trading costs; and provide for efficient and timely rebalancing activity. FOUNDATIONS’ parameters and methodology for rebalancing are determined by, and may be changed at our discretion, and without notice to you. Page | 11 Foundations Investment Advisors, LLC  Client Assets Under Management As of December 31, 2024, FOUNDATIONS had the following Assets Under Management (“AUM”): Discretionary: Non-Discretionary: Total AUM: $7,111,671,856 $72,800,432 $7,184,472,288 Page | 12 Foundations Investment Advisors, LLC  Item 5: Fees and Compensation Method of Compensation and Fee Schedule The total annual advisory fees charged to the client are based on a percentage of AUM as follows: Assets Under Management $0 and above Maximum Annual Advisory Fee * 2.00% • *A $150 annual minimum management fee will be assessed on all accounts. For account values of less than $7,500, this may equate to be more than the maximum 2% as stated in this Form ADV and the Agreement. • The fee schedule may not be the actual fee charged, but the maximum fee charged. Sub-Adviser fees are included in the fee schedule above. • All accounts will also be assessed a $50 annual administrative and technology fee (ATF) at the end of the January billing cycle. This $50 fee also applies to non-discretionary and/or non-managed accounts. FOUNDATIONS, in its discretion, may negotiate fees based upon individual account criteria such as anticipated future assets, client’s unique circumstances, and additional services performed. Our fees may be higher or lower than fees charged by other financial professionals offering similar services or by FOUNDATIONS to other clients with similar investment and risk profiles. FOUNDATIONS reserves the right to modify its fee schedule in the future by providing you with 30 days advance notice of any modification. Fees are collected and charged either: (1) Arrears on either a monthly or quarterly basis as selected by the Client in their FOUNDATIONS’ investment advisory agreement. Fees for any partial period (month or quarter) will be prorated based upon the number of calendar days in the period (month or quarter) that the advisory agreement is in effect. When charging in arrears on either a monthly or quarterly billing cycle, fees are based on the average daily value of the assets of the period (month or quarter) just ended. The fee is calculated as follows: The Custodian will calculate the average daily value of the AUM of the period (month or quarter) just ended and will multiply that amount by the respective fraction of the annual advisory fee (i.e., 1/12 for monthly or 1/4 for quarterly.); or (2) Quarterly in advance as selected by the Client in their FOUNDATIONS’ investment advisory agreement. If advisory services are discontinued during a quarter, a prorated portion of that calendar quarter’s fees will be refunded to the Client. Fees are based on the value of the assets under management on the first day of the new quarter. For new accounts, the quarterly fee is prorated for the initial calendar quarter and paid at the time management activity begins. Page | 13 Foundations Investment Advisors, LLC  We directly debit your account(s) for the payment of our advisory and ATF fees. This ability to deduct our advisory fees from your accounts causes our Firm to exercise limited custody over your funds or securities for regulatory purposes. We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other independent, qualified custodian. Clients may also elect to have advisory fees billed directly. You will receive account statements from the independent, qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will reflect the credits and debits to your account, including the amount of our advisory fees deducted from your account(s) each billing period. You should carefully review account statements for accuracy. FOUNDATIONS may engage one or more sub-advisors to provide investment advisory services to certain client accounts, including delegating all investment authority to the sub-advisors. Certain sub-advisers may employ billing practices that differ from FOUNDATIONS typical billing practice of billing in arrears and based on the average daily balance for the period (typically monthly or quarterly). FOUNDATIONS will generally bill on those specific sub-advised client accounts consistent with the methodology used by the sub-advisor (for example, if the sub-advisor bills quarterly, in advance, based on the ending net asset value of the month just ended, FOUNDATIONS will bill in the same manner). In instances where billing practices may differ from the client's agreement with FOUNDATIONS, we will require a client to execute an amendment or fee addendum (hereinafter, a "Fee Addendum") to its client agreement detailing the billing practices and fee arrangement for those certain accounts managed by the sub-advisor. The Fee Addendum will also set forth whether FOUNDATIONS will bill the entire fee and remit a portion to the sub-advisor or if each of the sub-advisor and FOUNDATIONS (via the custodian) will separately bill the specific client accounts managed by the sub-advisor. The terms set forth in any Fee Addendum will be specific to the accounts managed by the sub-advisor referenced in the Fee Addendum and any other client accounts will be managed pursuant to the client agreement unchanged by the Fee Addendum. Clients are urged to compare the account statements received directly from the custodian to any performance report statements prepared by any sub-adviser. Discounts, not generally available to our advisory clients, may be offered to family members and associated persons of our Firm. The minimum account value is $5,000 for investment advisory services. Client Payment of Fees With written authorization, the independent, qualified Custodian holding your funds and securities will automatically deduct our fee from your account. These fees will be deducted monthly or quarterly either in advance or in arrears, as applicable. The authorization and method of payment and selected billing cycle will be documented in the Agreement. Financial Planning Financial planning services are charged through a fixed or hourly arrangement as agreed upon between the client and Investment Adviser Representative. Page | 14 Foundations Investment Advisors, LLC  Financial Planning fees are negotiable and vary depending upon the complexity of the client situation and services to be provided. Hourly fees range from $100-$500 per hour. Similar financial planning services may be available elsewhere for a lower cost to the client. Fixed fees may be charged for asset management or financial planning services. If asset management services are charged fixed fees, the fees will never be greater than the fees stated in the above fee schedule. Fixed fees typically range from $100 - $5,000 depending on the type of service, complexity and duration of the service provided. Clients shall be invoiced by FOUNDATIONS upon the completion of services, as agreed in writing. Clients who wish to terminate the planning process prior to completion may do so with written notice. Upon receipt of written notification, any earned fee (based on a reasonable and justifiable percentage of completion methodology) will immediately become due and payable. Additional Client Fees Charged In addition to advisory and ATF fees paid to FOUNDATIONS as explained above, clients may pay custodial service, account maintenance, transaction, and other fees associated with maintaining the account. These fees vary by broker and/or custodian. Clients should ask FOUNDATIONS for details on transaction fees or other custodial fees specific to their account, as these fees are not included in the annual advisory fee. FOUNDATIONS does not share in any portion of a custodian’s transaction or custodian fees. Additionally, registered investment companies (“RICs”) impose internal fees and expenses on clients. Clients may pay their proportionate share of the RICs’ distribution, internal management, investment advisory and administrative fees. These fees are in addition to the costs associated with the investment advisory services, ATF and custodian fees as described above. Complete details of such internal expenses are specified and disclosed in each RIC’s prospectus. Clients are strongly advised to review the prospectus(es) prior to investing in such securities. Mutual funds purchased or sold in broker-dealer accounts may generate transaction fees that would not exist if the purchase or sale were made directly with the mutual fund company. Mutual funds held in broker-dealer accounts also charge management fees. These mutual fund management fees may be more or less than the mutual fund management fees charged if the client held the mutual fund directly with the mutual fund company. Clients may purchase shares of mutual funds directly from the mutual fund issuer, its principal underwriter, or a distributor without purchasing the services of FOUNDATIONS or paying the advisory fee on such shares (but subject to any applicable sales charges). Certain mutual funds are offered to the public without a sales charge. In the case of mutual funds offered with a sales charge, the prevailing sales charge (as described in the mutual fund prospectus) may be more or less than the applicable advisory fee. When making direct purchases, clients would not receive FOUNDATIONS’ assistance in developing an investment strategy, selecting securities, monitoring performance of the account, and Page | 15 Foundations Investment Advisors, LLC  making changes as necessary. Please refer to Item 12 – Brokerage Practices of this brochure for additional information. Prepayment of Client Fees FOUNDATIONS does not require prepayment of fees. External Compensation for the Sale of Securities to Clients FOUNDATIONS does not receive any external compensation for the sale of securities to clients, nor do any of the IARs of FOUNDATIONS. Advice Related to Rollovers of an Employer-Sponsored Plan As a normal extension of financial advice, we provide education or recommendations related to the rollover of assets from an employer-sponsored retirement plan to an individual retirement account (“IRA”) that we may advise on and which may therefore result in additional advisory fees payable to us. This type of recommendation represents a conflict of interest for our Firm. If we make this type of recommendation, you are under no obligation to follow such advice. A plan participant leaving employment has several options: You may have the options of (1) maintaining your retirement plan as is, (2) rolling over your account to the employer’s new retirement plan, (3) taking a taxable distribution, or (4) rolling over your account to a new IRA. Each choice offers advantages and disadvantages, depending on desired investment options and services, fees and expenses, withdrawal options, required minimum distributions, tax treatment, and the investor's unique financial needs and retirement plans. The complexity of these choices may lead an investor to seek assistance from us. Prior to proceeding with any such action, we encourage you to contact us and your independent legal and/or tax professionals for more information. An Associated Person who recommends an investor roll over plan assets into an IRA may earn an asset-based fee as a result, but no compensation if assets are retained in the plan. Thus, we have an economic incentive to encourage an investor to roll plan assets into an IRA. In most cases, fees and expenses will increase to the investor as a result because the above-described fees will apply to assets rolled over to an IRA and outlined ongoing services will be extended to these assets. We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. We have to act in your best interests and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. Page | 16 Foundations Investment Advisors, LLC  Item 6: Performance-Based Fees Sharing of Capital Gains Fees are not based on a share of the capital gains or capital appreciation of managed assets. FOUNDATIONS does not use a performance-based fee structure because of the potential conflict of interest. Performance-based compensation may create an incentive for the adviser to recommend an investment that may carry a higher degree of risk to the client. Item 7: Types of Clients Description We offer investment advisory services to a wide variety of clients including, but not limited to, registered investment companies, individuals including those with high net worth, pension and profit-sharing plans, including plan participants, trusts, estates, 401(k) sponsor plans and Individual Retirement Accounts (IRA, SEP, ROTH IRA,) charitable organizations, corporations and other business entities, including sole proprietorships. Account Minimums The minimum account value is $5,000. Page | 17 Foundations Investment Advisors, LLC  Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies Security analysis methods used by FOUNDATIONS may include fundamental analysis, technical analysis, and cyclical analysis. Investing in securities involves risk of loss that clients should be prepared to bear. Fundamental analysis involves evaluating a stock using real data such as company revenues, earnings, return on equity, and profit margins to determine underlying value and potential growth. Technical analysis involves evaluating securities based on past prices and volume. Cyclical analysis involves analyzing the cycles of the market. Fundamental analysis may involve interest rate risk, market risk, business risk, and financial risk. Risks involved in technical analysis are inflation risk, reinvestment risk, and market risk. Cyclical analysis involves inflation risk, market risk, and currency risk. Other strategies may include long-term purchases, short-term purchases and trading. The main sources of information may include financial newspapers and magazines, inspection of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses and filings with the SEC, and company press releases. Investment Strategy and Method of Analysis Material Risks The investment strategy for a specific client is based upon the objectives stated by the client during consultations and documented in the Agreement. The client may change these objectives at any time. Each client’s Agreement contains information related to the client’s risk tolerance and any investment restrictions. Any other documentation as required by FOUNDATIONS that documents the client’s objectives and their desired investment strategy will be retained as part of the client’s file. As referenced in Item 4 of this brochure, FOUNDATIONS may utilize outside investment advisory companies as sub-advisers (each hereinafter a “Sub-Adviser” or collectively, the “Sub-Advisers”). Our analysis of Sub-Advisers involves the examination of their experience, expertise, investment philosophies, and past performance to determine if the Sub-Adviser has demonstrated an ability to invest over a period of time and in different economic conditions. We monitor the Sub-Advisers’ underlying holdings, strategies, concentrations, and leverage as part of our overall periodic risk assessment. Additionally, as part of our due diligence process, we survey the Sub-Advisers’ compliance and business enterprise risks. A risk of investing with a Sub-Adviser who has been successful in the past is that they may not be able to replicate that success in the future. In addition, we may have limited or no control over the underlying investments in a Sub-Advisers’ portfolio. There is also a risk that a Sub-Adviser may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our clients. Moreover, as we do not control the Sub-Advisers’ daily business and compliance operations, we may be unaware of the lack of internal controls necessary to prevent Page | 18 Foundations Investment Advisors, LLC  business, regulatory or reputational deficiencies. FOUNDATIONS currently has and may engage a Sub-Adviser where there are potential conflicts that might incline FOUNDATIONS to utilize such a Sub-Adviser when such use is not disinterested. In such instances, and in addition to the due diligence and analysis described above, FOUNDATIONS has established policies and procedures to help determine whether retaining such a Sub-Adviser would be in the best interest of clients. Please refer to Item 10 – Other Financial Industry Activities and Affiliations for additional information on the Firm’s conflicts of interests as they relate to Sub-Advisers. Security Specific Material Risks All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks: • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic and social conditions may trigger market events. • Inflation Risk: When any type of inflation is present, a dollar today will buy more than a dollar next year, because purchasing power is eroding at the rate of inflation. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. • ETF and Mutual Fund Risk: When investing in an ETF or mutual fund, you will bear additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds. You will also incur brokerage costs when purchasing ETFs. • Equity (stock) Risk: Common stocks are susceptible to general stock market fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change. If you held common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater risk than if you held preferred stocks and debt obligations of the issuer. Page | 19 Foundations Investment Advisors, LLC  about risks of trading cryptocurrency futures • Cryptocurrency-Linked Products Risk: Cryptocurrency-related products carry a substantial level of risk and are not suitable for all investors. Investments in cryptocurrencies are relatively new, highly speculative, and may be subject to extreme price volatility, illiquidity, and increased risk of loss, including your entire investment. Spot markets on which cryptocurrencies trade are relatively new and largely unregulated, and therefore, may be more exposed to fraud and security breaches than established, regulated exchanges for other financial assets or instruments. Some cryptocurrency-related products use futures contracts to attempt to duplicate the performance of an investment in cryptocurrency, which may result in unpredictable pricing, higher transaction costs, and performance that fails to track the price of the reference cryptocurrency as intended. Please at: read more https://www.sec.gov/oiea/investor-alerts-and-bulletins/ib_fundstrading. • Company Risk: When investing in stock positions, there is always a certain level of company or industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk and can be reduced through appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. • Fixed Income Risk: When investing in bonds, there is the risk that the issuer will default on the bond and be unable to make payments. Further, individuals who depend on set amounts of periodically paid income face the risk that inflation will erode their spending power. Fixed-income investors receive set, regular payments that face the same inflation risk. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. • Management Risk: Your investment with our Firm varies with the success and failure of our investment strategies, research, analysis and determination of portfolio securities. If our investment strategies do not produce the expected returns, the value of the investment will decrease. Page | 20 Foundations Investment Advisors, LLC  • Concentrated Position Risk: Certain Associated Persons may recommend that clients concentrate account assets in an industry or economic sector. In addition to the potential concentration of accounts in one or more sectors, certain accounts may, or may be advised to, hold concentrated positions in specific securities. Therefore, at times, an account may, or may be advised to, hold a relatively small number of securities positions, each representing a relatively large portion of assets in the account. As a result, the account will be subject to greater volatility than a more sector diversified portfolio. Investments in issuers within an industry or economic sector that experiences adverse economic, business, political conditions or other concerns will impact the value of such a portfolio more than if the portfolio’s investments were not so concentrated. A change in the value of a single investment within the portfolio will affect the overall value of the portfolio and will cause greater losses than it would in a portfolio that holds more diversified investments. • Artificial Intelligence Risk – Broadening use of artificial intelligence – or “AI” – including so-called generative artificial intelligence, presents investment and other risks. Artificial intelligence can yield anomalous and incorrect results because the technology is still in development, artificial intelligence algorithms or training methodologies are flawed, or datasets are limited, dated, overbroad, insufficient, or contain biased information. These same risks also can be expected to affect third-party providers of products, services and information that directly or indirectly use artificial intelligence. The full scope and complexity of how AI will affect U.S. and global markets and industries is not yet known and could accelerate rapidly in unexpected ways. National and international regulations may also develop in an attempt to monitor or limit the use of AI, which could hamper its usefulness, slow its rate of uptake, and reduce investment returns for companies in the AI industry or that seek to use AI in operating their businesses. Our strategies and investments may have unique and significant tax implications. Regardless of your account size or other factors, we strongly recommend that you continuously consult with a tax professional prior to and throughout the investing of your assets. Investing in securities involves risk of loss that clients should be prepared to bear. Although we manage your portfolio with strategies and in a manner consistent with your risk tolerances, there can be no guarantee that our efforts will be successful. You should be prepared to bear the risk of loss. All investments involve the risk of loss, including (among other things) loss of principal, a reduction in earnings (including interest, dividends, and other distributions), and the loss of future earnings. These risks include the risks stated above. Regardless of the methods of analysis or strategies suggested for your particular investment goals, you should carefully consider these risks, as the client should be able to bear all risks. Page | 21 Foundations Investment Advisors, LLC  Item 9: Disciplinary Information Criminal or Civil Actions There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of FOUNDATIONS’ business or the integrity of FOUNDATIONS’ management. Administrative Enforcement Proceedings Neither the Firm nor its management persons have been found to have committed any violations that require disclosure under the instructions for this subsection. Self-Regulatory Organization Enforcement Proceedings The Firm and its management have not been involved in any Self-Regulatory Organization enforcement proceedings related to past or present investment clients. Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration Neither FOUNDATIONS nor any of its employees are registered representatives of a broker-dealer. Futures or Commodity Registration Neither FOUNDATIONS nor its employees are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor. Material Relationships Maintained by this Advisory Business and Conflicts of Interest We are an independent registered investment adviser and only provide investment advisory services. We are not engaged in any other business activities and offer no other services except those described in this Disclosure Brochure. However, while we do not sell products or services other than investment advice, our representatives may sell other products or provide services outside of their role as investment adviser representatives with us. Conflicts of Interest Under federal and state law, when providing advisory services, FOUNDATIONS is a fiduciary and must fully disclose all material facts relating to the advisory relationship. As a fiduciary, the Firm seeks to avoid conflicts of interest or, at a minimum, make full disclosure to provide sufficiently specific facts for clients to understand and appreciate the risk associated with a conflict of interest. FOUNDATIONS continually monitors its advisory business to identify, manage and disclose conflicts of interest. Insurance Products Some of our investment adviser representatives are also licensed as insurance agents either independently or through Magellan Financial & Insurance Services, LLC (“Magellan”), an affiliated independent marketing organization and insurance general agency under common control with FOUNDATIONS. In addition to our services, your Page | 22 Foundations Investment Advisors, LLC  investment adviser representative may offer you insurance products in their separate capacity as an insurance agent. FOUNDATIONS does not recommend, sell, and/or provide investment advisory services with respect to insurance products regulated by state insurance law. Client portfolios are initially reviewed to determine the degree of market exposure compared to their risk profile and income needs. We may recommend that a portion of a client’s total portfolio may benefit from an insurance product that has features not available with a securities portfolio. Insurance products are only recommended to clients where we believe, after careful review, that the product is in each client’s best interest; insurance products are therefore not recommended to all clients. Your financial professional and/or Magellan will earn commission-based compensation for the sale of insurance products. The fees charged for the sale of insurance products are separate from our advisory fees. They do not offset regular advisory fees and are typically paid up-front, immediately upon the sale of the insurance product and are typically higher than the advisory fees charged by FOUNDATIONS. Such fees are paid by the insurance product issuer or sponsor and do not reduce your investment amount. FOUNDATIONS will not charge an advisory fee on any insurance products. The total commission-based compensation paid by insurance companies to Magellan and licensed insurance agents who are also investment adviser representatives with FOUNDATIONS is included within the total purchase price paid by the client for the insurance product. The commission rate varies based upon factors such as the type of insurance product being sold, the size of the insurance product, and the term of the insurance product. Combined, Magellan and the licensed insurance agents involved in the sale of an insurance product typically earn between 5% and 10% of the total purchase price of the insurance product. While most investment adviser representatives of FOUNDATIONS who are also licensed insurance agents work with Magellan to sell insurance products, some investment adviser representatives of FOUNDATIONS work with companies other than Magellan to sell insurance products. The range of combined commissions paid by insurance companies for the sale of insurance products by licensed insurance agents who work with a company other than Magellan may differ from the commission range provided above. This practice represents a conflict of interest because IARs providing investment advice on behalf of FOUNDATIONS who are insurance agents, as well as management persons of Magellan, have an incentive to recommend insurance products to clients for the purpose of generating higher commissions and revenues rather than solely based on client needs. Common ownership also represents a conflict of interest. There is an inherent interest in recommending insurance products through Magellan rather than a potentially less expensive competing insurance company. Estate Planning Services Certain individuals associated with FOUNDATIONS, in their separate capacities outside of the Firm, may assist clients with estate planning–related administrative services. These services typically involve assistance with organizing personal information, document gathering, and entering data into third-party estate planning platforms. These associated persons do not, and are not authorized to, provide legal advice or legal services. Any legal documents or recommendations are generated solely by the third-party platform Page | 23 Foundations Investment Advisors, LLC  provider and/or attorneys affiliated with that platform. These outside activities are not supervised by FOUNDATIONS, and clients are under no obligation to use such services or platforms. FOUNDATIONS does not generally provide estate planning services, and the Firm itself does not receive any direct or indirect compensation, referral fees, or commissions related to any provision of estate planning services. Money Managers and Product Sponsors firms) with whom we (including our investment Certain industry parties (such as broker-dealers, banks, and other investment management adviser representatives) invest client assets may provide marketing support, administrative reimbursements, or other non-cash benefits to FOUNDATIONS. These arrangements present a conflict of interest, as FOUNDATIONS is incentivized to recommend their products or services over potentially lower-cost or comparable alternatives. However, FOUNDATIONS believes that its recommendations are made in its clients’ best interests, based on each client’s investment objectives and the merits of the products and strategies considered. To address this conflict, FOUNDATIONS performs due diligence on third-party products and providers and periodically reviews available alternatives to help ensure ongoing alignment with client needs and objectives. Additionally, IARs will, on occasion, have an opportunity to attend a training event or participate in a due diligence visit where the money manager or product sponsor will cover the associated travel expenses such as airfare, hotel and meals. Training opportunities are often held at luxury resorts where amenities such as golf, spas and entertainment are provided. Such accommodations represent a conflict of interest that can influence the evaluation of the money manager or product sponsor based on factors other than the quality of services. Additional Compensation IARs of FOUNDATIONS can receive an economic benefit for providing advisory services from sources other than the client. Economic benefits include sales awards and gifts, an occasional meal, as well as entertainment such as a concert, show or sporting event. Such compensation is not directly related to the advice or services provided to a particular client, but it does create a conflict of interest that can influence the selection of services based on the compensation received. Service Agreements FOUNDATIONS has Service Agreements with Orion Advisor Services (“Orion”) and GeoWealth Management, LLC (“GeoWealth”) to provide trading, billing, data aggregation, reporting and operations solutions, as well as other advisor solutions, in conjunction with our custodians, Fidelity Investments, Schwab Advisor Services, BNY Mellon Pershing and other qualified custodians as approved by FOUNDATIONS. These agreements allow Orion and GeoWealth to perform certain trading, operational, data aggregation and other administrative duties with these custodians on our behalf. Page | 24 Foundations Investment Advisors, LLC  Affiliation with Magellan Financial & Insurance Services, LLC Magellan Financial & Insurance Services, LLC (“Magellan”) and FOUNDATIONS are under common ownership of Bryon Rice (who holds a majority interest in Magellan). Magellan provides coaching, consulting, training and insurance contracting services to financial advisers. Magellan’s focus is on client service and new business growth solutions. Magellan is not a registered investment adviser or broker-dealer. Magellan offers services to individuals that work within the financial services industry. Magellan has an insurance agency through which FOUNDATIONS IARs may offer life insurance, annuities and other insurance products in their separate capacity as insurance agents. Magellan will share with an insurance agent a portion of the overrides that Magellan receives from the insurance company for Magellan’s wholesaling activities associated with the sale of a fixed insurance product. Magellan offers special incentive compensation such as vacation trips to our IARs, acting in their separate capacity as an insurance agent, if they meet certain overall sales goals by placing fixed insurance products through Magellan. Magellan may make available to certain agents, forgivable loans to assist with business development and/or marketing expenses. Such loans may be entirely forgiven based upon the achievement of overall sales goals of fixed insurance products. The receipt of these various forms of compensation and benefits may affect the judgment of our IARs when recommending a particular fixed insurance products to advisory clients. Client should be aware that the receipt of additional incentive compensation itself creates a conflict of interest and will affect the independent judgment of our IARs when making recommendations about fixed insurance products in general or a particular annuity or insurance product offered by a certain insurance company or through Magellan. Magellan may sponsor FOUNDATIONS events (i.e., workshops, seminars, etc.) and FOUNDATIONS may market our advisory services and investments at Magellan events. Magellan may provide referrals to FOUNDATIONS and may refer FOUNDATIONS’ platforms, investment strategies and products to financial professionals using Magellan’s services. FOUNDATIONS may compensate Magellan for these non-client referral activities. Magellan, through a shared services arrangement, provides certain back-office and administrative support to FOUNDATIONS. FOUNDATIONS compensates Magellan for these services. In January 2020, Jarrod Florence became the President of Magellan after 13 years as that company’s Senior Vice President, Sales. Mr. Florence now serves concurrently as the President of both FOUNDATIONS and Magellan. Affiliation with Magellan Healthcare, LLC Magellan Healthcare, LLC (“MHL”) is a subsidiary of Magellan Financial & Insurance Services, LLC and provides education, healthcare insurance, supplemental plans, Medicare supplements and related services. IARs of FOUNDATIONS may refer clients to MHL for appropriate services. This practice represents a conflict of interest because FOUNDATIONS has an incentive to recommend the services of MHL for the purpose of generating higher revenues for an affiliated company, rather than solely based on client needs. There is an inherent conflict of interest in recommending the services of MHL rather than a potentially less expensive competing service provider. This conflict is Page | 25 Foundations Investment Advisors, LLC  mitigated by the IAR’s fiduciary duty to only act in the best interest of the client, both from an advisory perspective and from a supplemental insurance sales perspective, as required by applicable insurance regulations and carrier policies. Affiliation with Enhance Design Group, LLC Enhance Design Group, LLC (“EDG”) and FOUNDATIONS are under common ownership of Bryon Rice. EDG is in the business of designing and structuring insurance products and other investment strategies. Such insurance products and strategies may be sold by Magellan as well as other independent marketing organizations or offered by unaffiliated insurance carriers. Both Foundations and Magellan promote the use of EDG products where they are available to clients. This practice represents a conflict of interest because IARs providing investment advice on behalf of FOUNDATIONS who are insurance agents have an incentive to recommend insurance products designed by EDG to clients for the purpose of generating higher revenues for an affiliated company, rather than solely based on client needs. There is an inherent conflict of interest in recommending EDG designed insurance products rather than a potentially less expensive competing insurance product. This conflict is mitigated by the IAR’s fiduciary duty to only act in the best interest of the client, both from an advisory perspective, if the fixed insurance product is part of their overall investment strategies, and from an insurance sales perspective, as required by applicable insurance regulations and carrier policies. Recommendations or Selections of Other Investment Advisors and Conflicts of Interest FOUNDATIONS, in providing the services agreed upon with the client, may retain an investment adviser registered under applicable securities laws, as a Sub-Adviser to manage all or a portion of the managed assets in the client's account (hereinafter, the “Sub-Adviser”). If this occurs, FOUNDATIONS will be responsible for the continuing supervision of the client's account, and the actions of the Sub-Adviser in connection with the client's account and the managed assets. FOUNDATIONS will also be responsible for the payment of any advisory fee or other charges of the Sub-Adviser with respect to the managed assets unless or except as specifically authorized in advance by the client. FOUNDATIONS agrees that upon proper notice by the client, FOUNDATIONS will refrain from the appointment of, or terminate as permitted under applicable contracts, any Sub-Adviser appointed pursuant to this authority. We have a conflict of interest when we utilize third-party Sub-Advisers that have agreed to share a portion of their advisory fee with us and have met the conditions of our due diligence review. There may be other third-party Sub-Advisers that may be suitable for you which may be more or less costly. No guarantees can be made that your financial goals or objectives will be achieved. Further, no guarantees of performance can be offered. This conflict of interest is primarily mitigated by our ongoing due diligence of our third-party Sub-Advisers and our limits on advisory compensation to the schedule set forth in Item 5 – Fees and Compensation. Affiliation with Alpha 1 Tax and Wealth Management, LLC Bryon Rice is the co-owner and CEO of Alpha 1 Tax and Wealth Management, LLC dba Alpha 1 Tax and Wealth Management (“ALPHA 1”). ALPHA 1 is a limited liability company formed in the State of Colorado in April of 2018. ALPHA 1’s associated persons, including Page | 26 Foundations Investment Advisors, LLC  Mr. Rice are licensed insurance agents. ALPHA 1 is affiliated with Magellan through common ownership and control. As noted above, Magellan is also an insurance agency. Magellan, ALPHA 1, it associated persons, including Mr. Rice, receive commission-based compensation for effecting transactions in insurance products they may recommend. Clients of FOUNDATIONS, Magellan or ALPHA 1 are under no obligation to purchase insurance products through any of these entities or persons affiliated with any of these entities. As noted in Item 4, Bryon Rice is the principal owner of FOUNDATIONS. ALPHA 1 is also affiliated with FOUNDATIONS through common ownership and control. Certain FOUNDATIONS IARs may market their investment advisory services through ALPHA 1. Mr. Rice may receive economic benefit as a result of his roles and ownership interests in FOUNDATIONS, Magellan and ALPHA 1. Affiliation with Northern Alliance Financial, LLC Bryon Rice is the co-owner of Northern Alliance Financial, LLC (“NAF”). NAF is a limited liability company formed in the State of Maine in August of 2022. NAF’s associated persons, including Mr. Rice are licensed insurance agents. NAF is affiliated with Magellan through common ownership and control. As noted above, Magellan is also an insurance agency. Magellan, NAF and its associated persons, including Mr. Rice, receive commission-based compensation for effecting transactions in insurance products they may recommend. Clients of FOUNDATIONS, Magellan or NAF are under no obligation to purchase insurance products through any of these entities or persons affiliated with any of these entities. As noted in Item 4, Bryon Rice is the principal owner of FOUNDATIONS. NAF is also affiliated with FOUNDATIONS through common ownership and control. Certain FOUNDATIONS IARs may market their investment advisory services through NAF. Mr. Rice may receive economic benefit as a result of his roles and ownership interests in FOUNDATIONS, Magellan and NAF. Affiliation with Asset Preservation Tax & Retirement, LLC Bryon Rice is the co-owner of Asset Preservation Tax & Retirement, LLC dba Asset Preservation Wealth & Tax (“APWT”). APWT is a limited liability company formed in the State of Arizona in August of 2014. APWT’s associated persons, including Mr. Rice are licensed insurance agents. APWT is affiliated with Magellan through common ownership and control. As noted above, Magellan is also an insurance agency. Magellan, APWT and its associated persons, including Mr. Rice, receive commission-based compensation for effecting transactions in insurance products they may recommend. Clients of FOUNDATIONS, Magellan or APWT are under no obligation to purchase insurance products through any of these entities or persons affiliated with any of these entities. As noted in Item 4, Bryon Rice is the principal owner of FOUNDATIONS. APWT is also affiliated with FOUNDATIONS through common ownership and control. Certain FOUNDATIONS IARs may market their investment advisory services through APWT. Page | 27 Foundations Investment Advisors, LLC  Mr. Rice may receive economic benefit as a result of his roles and ownership interests in FOUNDATIONS, Magellan and APWT. Affiliation with Omega Wealth Private Capital, LLC Messrs. Rice, Florence and Kyle Mann (the Firm’s CFO) each own a non-controlling, minority interest in Omega Wealth Private Capital LLC (“OWPC”), a registered investment adviser based in Cincinnati, Ohio and, in such capacity, they may introduce OWPC and its clients to certain service providers or refer OWPC and its clients to certain investment products or strategies. Because of their interests in FOUNDATIONS, they may have an incentive to make such introductions or referrals with respect to service providers, products or strategies that FOUNDATIONS has an interest in or with whom it has a relationship. Affiliation with Charter Law Group, LLC FOUNDATIONS is under common control with Charter Law Group, LLC (“CLG”), formally known as Foundations Legal, LLC, through Mr. Rice’s majority ownership of CLG, as of August 1, 2024. CLG is a professional services company providing legal services related to wealth management and estate planning. CLG is not a registered investment adviser or broker-dealer. CLG is focused on providing trust and estate services to retail clients and may receive client referrals from certain FOUNDATIONS IARs. CLG also shares office space and certain employees with FOUNDATIONS. This presents a conflict of interest, as the two entities are under common control. This conflict is addressed by FOUNDATIONS’ adoption of its Code of Ethics, which requires that all FOUNDATIONS Associated Persons place the interest of clients ahead of their own. Clients of FOUNDATIONS are also free to choose their legal professionals for trust and estate planning services and are under no obligation to utilize the services offered through any related entities or persons associated with FOUNDATIONS. Page | 28 Foundations Investment Advisors, LLC  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Description The employees of FOUNDATIONS have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth guidelines and standards of conduct expected of our Associated Persons and addresses potential conflicts that may arise. The Code defines acceptable behavior for our Associated Persons and reflects our goal to protect your interests at all times and to demonstrate our commitment to our fiduciary duties of honesty, good faith and fair dealing with you. All of our Associated Persons are expected to understand and strictly follow these guidelines. Our Code of Ethics also requires that our Associated Persons submit reports of their personal account holdings and transactions to a qualified representative of our Firm who will review these reports on a periodic basis. Persons associated with our Firm are also required to report any violations of the Code. Additionally, we maintain and enforce written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about you or your account holdings by persons associated with our Firm. Our Firm or persons associated with our Firm may buy or sell securities or hold a position identical to clients. It is our policy that no Associated Person will put his/her interests before a client’s interest. If our Firm is considering purchasing or selling most types of securities (with certain limited exceptions) (each, a “Reportable Security”) on behalf of a client account, no Designated Access Person (a sub-set of Access Persons that typically includes the members of the Firm’s investment committee (as constituted from time to time), the members of the Firm’s trading team, and certain other persons that may be materially involved with or have material access to the Firm’s trading activities) involved in the day-to-day management of our Firm’s portfolios that has knowledge of, or access, to, trade information, including traders and Investment Committee members or those living in the Designated Access Person’s household, may knowingly effect a transaction in that Reportable Security prior to the client purchase or sale having been completed by our Firm, or until a decision has been made not to purchase or sell the Reportable Security on behalf of the client account in accordance with our Firm’s clearance policy. Designated Access Persons are prohibited from knowingly transacting in Reportable Securities, before or at a better price than, a client of our Firm who has transacted in the same security. We prohibit all Associated Persons from trading on non-public information and from sharing such information. Associated Persons may not invest in an initial public offering (IPO), private placement or other limited offerings for their own accounts or those of related household members without prior approval from the Firm’s Chief Compliance Officer or designee. Every Associated Person who has access to client accounts must submit a report of all personal securities holdings at the time of affiliation with us and annually thereafter. Such reports must contain current information (not older than 45 days). Holding reports must contain the following information: • The title and type of security; Page | 29 Foundations Investment Advisors, LLC  • The security symbol or CUSIP number; • The number of shares and the principal amount of each reportable security; • The name of any broker, dealer, or bank with which the Associated Person maintains an account; • The date the report was submitted. The Code applies to “access” persons. “Access” persons are Associated Persons of the Firm including persons who have access to non-public information regarding any client’s purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to clients, or who have access to such recommendations that are non-public. Associated Persons who violate the Code may be subject to remedial action, including, but not limited to: profit disgorgement, fines, suspension, or dismissal. Associated Persons are required to promptly notify the Compliance Department of any potential violation of the Code of which they become aware and are also required to certify their compliance with the Code on an annual basis. The Firm will provide a copy of the Code of Ethics to any client or prospective client upon request. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest FOUNDATIONS does not maintain a firm proprietary trading account and does not have a material financial interest in any securities it recommends. As such, FOUNDATIONS does not believe this activity presents a related conflict of interest. Potential Restrictions and Conflicts Relating to Information Possessed or Provided By The Firm Availability of Proprietary Information In connection with its activities, certain FOUNDATIONS personnel and/or affiliated persons, at times will receive information regarding proposed investment activities for FOUNDATIONS or its clients that is not generally available to the public. There will be no obligation on the part of FOUNDATIONS to make available for use by a client, or to effect transactions on behalf of a client on the basis of, any such information. In many cases, such persons will be prohibited from disclosing or using such information for their own benefit or for the benefit of any other person, including clients. Similarly, one or more clients may have, as a result of receiving client reports or otherwise, access to information regarding FOUNDATIONS’ transactions or views that are not available to other clients and may act on such information through accounts managed by persons other than FOUNDATIONS. Such transactions could negatively impact clients through market movements or by decreasing the pool of available securities or liquidity. Clients may also be adversely affected by cash flows and market movements arising from purchase and sale transactions, as well as increases of capital in, and withdrawals of capital from, Accounts of other clients. These effects can be more pronounced in thinly traded securities and less liquid markets. A potential conflict of interest may arise as a result of the portfolio manager’s day-to-day management of an Account. Because of their Page | 30 Foundations Investment Advisors, LLC  role in managing client Accounts, the portfolio managers know the size, timing and possible market impact of a client’s trades. It is possible that the portfolio managers could use this information, or other information, including material non-public information (“MNPI”), about and learned from the investments made by the client to the advantage of other clients or Affiliate clients they manage and to the possible detriment of a client. Material Non-Public Information/Insider Trading From time to time, FOUNDATIONS personnel and/or related persons may come into possession of MNPI which, if disclosed, might affect an investor’s decision to buy, sell or hold a security. FOUNDATIONS personnel and/or related persons may obtain such information through FOUNDATIONS’ investment management activities or through their outside activities. Under applicable law, FOUNDATIONS personnel and/or related persons generally will be prohibited from improperly disclosing or using such information for their personal benefit or for the benefit of any other person, regardless of whether that person is a client. Accordingly, should a FOUNDATIONS employee come into possession of MNPI, he or she generally will be prohibited from communicating such information to, or using such information for the benefit of, clients, which could limit the ability of clients to buy, sell or hold certain investments, thereby limiting the investment opportunities or exit strategies available to clients. In addition, holdings in the securities or other instruments of an issuer by FOUNDATIONS or its affiliates may affect the ability of a client to make certain acquisitions of or enter into certain transactions with such issuer. FOUNDATIONS shall have no obligation or responsibility to disclose such information to, or use such information for the benefit of, any person (including clients). We have implemented procedures, including those described herein relating to information barriers, that are designed to control the flow of and prohibit the misuse of such information (e.g., illegal securities trading based on the information) by FOUNDATIONS, our employees and on behalf of our clients. Similarly, no employee who is aware of MNPI that relates to any other company or entity in circumstances in which such person is deemed to be an insider or is otherwise subject to restrictions under federal securities laws may buy or sell securities of that company or otherwise take advantage of, or pass on to others, such MNPI in violation of applicable law. Information Barriers To control the flow of MNPI within the FOUNDATIONS organization and to prevent its misuse, FOUNDATIONS has established policies and procedures that are designed to control receipt of MNPI and, where appropriate, erect information barriers. These information barriers include, as dictated by the applicable facts and circumstances, the physical, technological and operational separation (“walling off”), of certain of business units or personnel with knowledge of the size, timing and possible market impact of client’s trades, as well as other policies and procedures designed to prevent the unauthorized access to, or dissemination of, MNPI. Information barriers have been established between certain groups of designated personnel who often have access to confidential information, including MNPI, and other Associated Persons who have access to such information on a limited basis. The purpose of these information barriers is, among other things, to limit the receipt of MNPI to such personnel who often have access Page | 31 Foundations Investment Advisors, LLC  to confidential information, such that the investment activities of the rest of FOUNDATIONS are not otherwise restricted because the designated personnel may have MNPI that would be imputed to the rest of FOUNDATIONS in the absence of an information barrier. FOUNDATIONS has established and is expected to continue to establish additional information barriers when appropriate, including in connection with certain investments or business units. Other Trading Restrictions In addition, FOUNDATIONS maintains certain restricted lists of securities and issuers that are subject to certain trading restrictions due to FOUNDATIONS’ and its affiliates’ business activities. We generally will restrict trading in an issuer’s securities if the issuer is on a restricted list or if we otherwise have MNPI about that issuer. In some situations, we may restrict clients from trading in a particular issuer’s securities to allow FOUNDATIONS or its affiliates to receive MNPI on behalf of other clients or Affiliate clients. An Account may be unable to buy or sell certain securities until the restriction is lifted, which could disadvantage the Account. In some situations, FOUNDATIONS could be restricted from making (or divesting of), investments in respect of some clients but not others. In some cases, we may not initiate or recommend certain types of transactions or may otherwise restrict or limit our advice relating to certain securities if a security is restricted due to MNPI or if we are seeking to limit receipt of MNPI. In addition, FOUNDATIONS will, in many cases, rely on public information in connection with the valuation of certain securities when another business unit within FOUNDATIONS or one of its affiliates may be otherwise in possession of MNPI suggesting that such valuations may be inaccurate. Page | 32 Foundations Investment Advisors, LLC  Item 12: Brokerage Practices Factors Used to Select Broker-Dealers for Client Transactions FOUNDATIONS primarily recommends Fidelity Investments (“Fidelity”), Pershing Advisor Services, LLC (“Pershing”), and Schwab Advisor Services as Custodians. Schwab Advisor Services is a division of Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer, member SIPC. Fidelity, Pershing, and Schwab are each an unaffiliated SEC-registered broker-dealer and FINRA member. Each Custodian offers services to independent investment advisors which include custody of securities, trade execution, clearance and settlement of transactions. Directed Brokerage FOUNDATIONS does not accept directed brokerage arrangements. Clients participating in our asset management programs are required to use one of our approved Custodians. Best Execution Investment advisers who manage or supervise client portfolios on a discretionary basis have a fiduciary obligation of best execution. The Custodian maintains custody of all funds and securities. We believe that the Custodian selected by FOUNDATIONS will provide quality execution services for you at competitive prices. Price is not the sole factor we consider in evaluating best execution. We also consider the quality of the brokerage services provided by the Custodian, including the value of research provided, the Firm's reputation, execution capabilities, commission rates, reporting capabilities, and responsiveness to our clients and our Firm. In recognition of the value of research services and additional brokerage products and services each Custodian provides, you may pay higher commissions and/or trading costs than those that may be available elsewhere. FOUNDATIONS may also recommend/require that clients establish brokerage accounts with Schwab to maintain custody of clients’ assets and to effect trades for their accounts. The final decision to custody assets with Schwab is at the discretion of the Advisor’s clients, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. FOUNDATIONS is independently owned and operated and not affiliated with Schwab. Schwab provides FOUNDATIONS with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the advisor’s clients’ assets are maintained in accounts at Schwab Advisor Services. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, 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. From time to time and for a limited time period, Foundations is also eligible to receive from Schwab, reimbursements of certain expenses incurred as a result of account transitions for new client accounts, up to an aggregated dollar amount upon meeting certain thresholds. For FOUNDATIONS client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through Page | 33 Foundations Investment Advisors, LLC  commissions or other transaction-related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab also makes available to FOUNDATIONS other products and services that benefit FOUNDATIONS but may not benefit its clients’ accounts. (Please see the disclosure under Item 14 – Client Referrals and Other Compensation below.) Research and Other Soft Dollar Benefits FOUNDATIONS recommends our Custodians based on the proven integrity and financial responsibility of these companies, best execution of orders at reasonable commission rates, and quality of client service. We are independently owned and operated and do not receive fees or commissions from any custodian or broker-dealer, although FOUNDATIONS may receive additional benefits from our Custodians such as electronic delivery of client information, electronic trading platforms, institutional trading support, proprietary and/or third-party research, continuing education, practice management advice, and other services provided by custodians for the benefit of investment advisory clients. (Please see the disclosure under Item 14 below.) The receipt of additional benefits may give us an incentive to require that you maintain your account with our Custodians based on our interest in receiving these services rather than your interest in receiving the best value and the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that our selection of custodians and brokers is in the best interests of our clients. Our belief is primarily supported by the scope and quality of services our Custodians provide to our clients and not services that benefit only us. Additionally, these benefits are offered to all investment advisers that use our Custodians for brokerage and execution services and not just our firm. To mitigate the existence of this conflict, we remain aware of current charges levied by custodians, and we conduct, at minimum on an annual basis, a best execution review considering the full range and quality of our Custodians’ services, including execution quality, commission rate, the value of research provided, financial strength and responsiveness to our requests for trade data and other information. Our obligation is not necessarily to get the lowest price but to obtain the best qualitative execution. FOUNDATIONS may receive similar benefits and services from other custodians with which it has a contractual relationship. Aggregating Securities Transactions for Client Accounts When FOUNDATIONS buys or sells the same security for two or more clients (including our personal accounts), we may place concurrent orders to be executed together as a single “block” in order to facilitate orderly and efficient execution. Each client account will be charged or credited with the average price per unit. We receive no additional compensation or remuneration of any kind because we aggregate client transactions, and no client is favored over any other client. Trade Errors Even with our best efforts and controls, trade errors may happen. All trade errors will be Page | 34 Foundations Investment Advisors, LLC  brought to the attention of the Portfolio Manager and the Compliance Team immediately upon discovery. We will work to formulate the best resolution for the client. In the event of a trade error, errors will be corrected before the current day market close (if possible) and no later than next market close date and with the intent to make the client whole. Ideally, when possible, trade errors will be moved from the client’s account to either our trade error account with the broker/dealer that executed the trade or that broker/dealer’s trade error account, depending upon which party is responsible for the error. In cases in which we are responsible for the error, all losses will be paid by us, and all gains will be retained by the custodian. In cases in which the broker/dealer is responsible for the error, we will follow the procedures of the broker/dealer with respect to any gains or losses in the trade error account. Please be advised that any trade errors that result from inaccurate instructions provided by the client remain the client’s financial responsibility. Page | 35 Foundations Investment Advisors, LLC  Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Account reviews are performed at least annually by the IAR assigned to the account. Account reviews are performed more frequently when market conditions dictate. Any recommendations regarding the Account that occur when an IAR meets with a client are subject to the fiduciary duty described in Item 10 - “Conflicts of Interest”. As part of the investment management service for Accounts, and as described in Item 4 under “Rebalancing”, the model portfolios used in connection with the Accounts will be used to periodically monitor for drift. Market conditions and other factors will likely cause your Account to deviate over time from the model portfolio. When such deviations become materially significant (as determined by FOUNDATIONS’ parameters), then your Account will be rebalanced to align it more closely with the model portfolio, provided your Account meets the minimum balance requirements as described in Item 5 - “Methods of Compensation and Fee Schedule.” Review of Client Accounts on Non-Periodic Basis Other conditions that may trigger a review of clients’ accounts are changes in the tax laws, new investment information, and changes in a client's own situation. Content of Client Provided Reports and Frequency Clients receive account statements no less than quarterly for managed accounts from the Custodian. Account reports may be issued by FOUNDATIONS. Clients receive confirmations of each transaction in their account from the Custodian and an additional statement during any month in which a transaction occurs. Item 14: Client Referrals and Other Compensation Economic benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest As disclosed under Item 12 above, FOUNDATIONS may recommend/require clients to establish brokerage accounts with Schwab. Schwab also makes available to FOUNDATIONS other products and services that benefit FOUNDATIONS but may not benefit its clients’ accounts. These benefits may include national, regional or FOUNDATIONS-specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits may include occasional business entertainment of personnel of FOUNDATIONS by Schwab Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these Page | 36 Foundations Investment Advisors, LLC  products and services assist FOUNDATIONS in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of FOUNDATIONS fees from its clients’ accounts, and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of FOUNDATIONS accounts, including accounts not maintained at Schwab Advisor Services. Schwab Advisor Services also makes available to FOUNDATIONS other services intended to generally benefit only FOUNDATIONS that help our Firm manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services rendered to FOUNDATIONS by independent third parties, in certain circumstances; up to a one time aggregated agreed upon amount. Schwab Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to FOUNDATIONS once the value of our clients’ assets in accounts at Schwab reaches certain thresholds. The availability of these services from Schwab benefits us because we do not have to produce or purchase them. The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This presents a conflict of interest. While, as a fiduciary, FOUNDATIONS endeavors to act in its clients’ best interests, FOUNDATIONS’ recommendation/requirement that clients maintain their assets in accounts at Schwab may be based in part on the benefit to FOUNDATIONS of the availability of some of the foregoing products and services and other arrangements and not solely on the nature, cost or quality of custody and brokerage services provided by in the aggregate our selection or Schwab. We believe, however, that taken recommendation of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the overall scope, quality, and price of Schwab’s services (see “How we select brokers/ custodians") and not the Schwab services that benefit only us. Advisory Firm Payments for Client Referrals FOUNDATIONS may enter into “Promoter” relationships. Promoters refer prospective clients to FOUNDATIONS. FOUNDATIONS pays a referral fee to the referring party typically based on a portion of the management fees charged by FOUNDATIONS and memorialized in a written agreement. In all cases, FOUNDATIONS will comply with the Page | 37 Foundations Investment Advisors, LLC  rule(s) established by the SEC and state regulators, as applicable. If a referred prospective client enters into an investment advisory agreement with FOUNDATIONS, a referral fee is paid to the referring party. The referral relationship will not result in clients being charged any fees over and above the normal advisory fees charged for the advisory services provided. FOUNDATIONS will pay the referring party their share of the total fee. The Agreement between Foundations and a promoter requires that they be appropriately registered under federal and state securities laws where applicable and not subject to statutory disqualification. Clients receive all related agreements and disclosures prior to or at the time of entering into an Investment Advisory Agreement with FOUNDATIONS. Page | 38 Foundations Investment Advisors, LLC  Item 15: Custody Account Statements We directly debit your account(s) for the payment of our advisory and ATF fees. This ability to deduct our advisory fees from your accounts causes our Firm to exercise limited custody over your funds or securities. We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other independent, qualified custodian. You will receive account statements from the independent, qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will indicate the amount of our advisory and ATF fees deducted from your account(s) each billing period. You should carefully review account statements for accuracy. Clients are urged to compare the account statements received directly from their custodians to any performance report statements prepared by FOUNDATIONS. Standing Letters of Authorization Some clients may execute limited powers of attorney or other standing letters of authorization that permit FOUNDATIONS to transfer money from their account with the client’s independent qualified Custodian to third parties. This authorization to direct the Custodian may be deemed to cause our Firm to exercise limited custody over your funds or securities and for regulatory reporting purposes, we are required to keep track of the number of clients and accounts for which we may have this ability. We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other independent, qualified custodian. You will receive account statements from the independent, qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will indicate any transfers that may have taken place within your account(s) each billing period. You should carefully review account statements for accuracy. Page | 39 Foundations Investment Advisors, LLC  Item 16: Investment Discretion Discretionary Authority for Trading The Agreement grants us the authority to decide what securities are bought or sold in your account(s) and the authority to implement those decisions without being required to obtain your approval. You have the right to place reasonable restrictions on your accounts. You may also place reasonable limitations on the discretionary power granted to us so long as the limitations are specifically set forth or included as an attachment to the client agreement. However, FOUNDATIONS retains the right to decline to enter into a management agreement with any client whose investment restrictions are contrary to the Firm’s investment strategies. Please refer to Item 4 – Advisory Business of this Brochure for more information. Item 17: Voting Client Securities Proxy Votes FOUNDATIONS does not generally vote proxies on securities held in client accounts. Clients are expected to receive and vote their own proxies directly from the custodian or transfer agent. FOUNDATIONS will vote proxies only if expressly authorized in a client agreement. Even in such cases, FOUNDATIONS may decline to vote if it believes, in its sole discretion, that a conflict of interest exists. Page | 40 Foundations Investment Advisors, LLC  Item 18: Financial Information Balance Sheet A balance sheet is not required to be provided because FOUNDATIONS does not serve as a Custodian for client funds or securities and FOUNDATIONS does not require prepayment of fees of more than $1,200 per client and six months or more in advance. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients FOUNDATIONS is not subject to a financial condition that is reasonably likely to impair our ability to meet contractual commitments to our clients. Bankruptcy Petitions during the Past Ten Years FOUNDATIONS has not been the subject of a bankruptcy petition at any time. Page | 41 Foundations Investment Advisors, LLC  Miscellaneous Class Action Suits A class action is a procedural device used in litigation to determine the rights of and remedies, if any, for large numbers of people whose cases involve common questions of law and/or fact. Class action suits frequently arise against companies that publicly issue securities, including securities recommended by investment advisers to clients. With respect to class action suits and claims, you (or your agent) will have the responsibility for class actions or bankruptcies, involving securities purchased for or held in your account. We do not provide such services and are not obligated to forward copies of class action notices we may receive to you or your agents. Consent to Electronic Delivery FOUNDATIONS supports the execution and delivery of electronic records as much as possible and pursuant to applicable law. We believe that doing so will provide a faster and more reliable vehicle for document retention, delivery of disclosure documents (including this brochure), and customer service. Therefore, we have begun to seek consent from our clients, institutional relationships, and vendors for electronic delivery. Confidentiality and Privacy Notice FOUNDATIONS views protecting its customers’ private information as a top priority and, pursuant to the requirements of the Gramm-Leach-Bliley Act, the Firm has instituted policies and procedures to ensure that customer information is kept private and secure. FOUNDATIONS does not disclose any nonpublic personal information about its customers or former customers to any nonaffiliated third parties. In the course of servicing a client account, FOUNDATIONS may share some information with its service transfer agents, custodians, broker-dealers, providers, such as sub-advisers, accountants, lawyers and affiliated third parties in order to provide services to clients. FOUNDATIONS restricts internal access to nonpublic personal information about its clients to those employees who need to know that information to provide products or services to the client. FOUNDATIONS maintains physical and procedural safeguards that comply with state and federal standards to guard a client’s nonpublic personal information and ensure its integrity and confidentiality. As emphasized above, it has always been and will always be the Firm’s policy never to sell information about current or former customers or their accounts to anyone. It is also the Firm’s policy not to share information unless required to process a transaction, at the request of the client, or as required by law. The form of FOUNDATIONS’ privacy policy notice is as follows and is provided to each of FOUNDATIONS’ clients prior to, or contemporaneously with, the execution of the Advisory Agreement: Page | 42 Foundations Investment Advisors, LLC  FOUNDATIONS INVESTMENT ADVISORS, LLC PRIVACY PROTECTION POLICY Effective Date: July 18, 2025 Background Regulation S-P (“Reg S-P”), issued pursuant to the Graham-Leach-Bliley Act, requires registered investment advisors to adopt and implement policies and procedures that are reasonably designed to protect the confidentiality of nonpublic personal records. Reg S-P applies to “consumer records”, meaning records regarding any individuals, families, or households obtaining financial products or services primarily for personal, family, or household purposes (“Consumers”). Reg S-P does not explicitly apply to the records of companies, investors in private funds (“Investors”), or individual agents or employees of the Company acting in a business capacity (“Supervised Persons”), but corresponding Federal Trade Commission rules may impose similar disclosure and safeguarding obligations. Foundations Investment Advisors, LLC (the “Company”) is committed to protecting the confidentiality of all of the nonpublic personal information of Consumers who have or will have an ongoing relationship with the Company (“Customers”) as well as Investors, prospective Investors, and Supervised Persons (such information, “Personal Information”). Reg S-P requires the Company to provide its Customers with notices describing the Company’s privacy policies and procedures. These privacy notices must be delivered to all new Customers upon inception of an arrangement, and at least annually thereafter. Reg S-P does not require distribution of privacy notices to companies, to Investors, or to Supervised Persons, but the Company provides initial and annual privacy notices to all Investors as a best practice. Additional disclosures required pursuant to Reg S-P may be found in the Privacy Notice in Appendix A. Guiding Principles The Company will seek to limit the collection of all Personal Information to that which is reasonably necessary for legitimate business purposes. The Company will not disclose Personal Information except in accordance with these policies and procedures, as permitted or required by law, or as authorized in writing by the Customer or Investor. The Company will never sell any Personal Information. With respect to all Personal Information, the Company will strive to: (a) ensure the security and confidentiality of the information; (b) protect against anticipated threats and hazards to the security and integrity of the information; and (c) protect against unauthorized access to, or improper use of, the information. 43  Risk Considerations In developing these policies and procedures, the Company considered the material risks associated with privacy protection. This analysis included risks such as: • Company trade secrets and Personal Information are not protected from unauthorized access by Supervised Persons or third-party service providers; • Personal Information is not recorded accurately or protected from inadvertent alteration or destruction; • Personal Information can be accessed, copied, or destroyed by physical or electronic intrusions; • False or misleading disclosures are made to Customers or Investors about the use or protection of Personal Information; • Third-party service providers have adopted inadequate policies and procedures to protect Personal Information; • Company uses information obtained from affiliates for marketing purposes without ensuring that affected individuals have been given adequate notice and an opportunity to opt out; and • Company fails to comply with applicable state or other applicable privacy laws. The Company has established the following guidelines to mitigate these risks. Policies and Procedures What this Policy Covers This Policy covers the Company’s use and treatment of Personal Information (which includes personal data, and may also be referred to as personally identifiable information (PII)): • that the Company may collect when a Customer, Investor, or prospective Customer or Investor (each, a “Covered Person”) accesses the Company’s website in any manner or engages the Company’s investment advisory services (collectively, the “Services”); • provided to the Company as described below; and • unless a Covered Person is notified that another policy applies. By accessing or engaging the Company’s Services, each Covered Person acknowledges and agrees that they consent to the practices and policies outlined in this Policy. This Policy also explains a Covered Person’s choices about how the Company uses information about the Covered Person. A Covered Person’s choices include how they can object to certain uses of information about the Covered Person and how they can access and update certain information about the Covered Person. 44  The Company does not knowingly collect or solicit Personal Information from any individual under the age of 16 or knowingly allow such individuals to engage the Company’s Services. Neither this Policy nor the Company’s website or Services are directed to such individuals. What Information is Collected about Customers a. What is Personal Information: The term “Personal Information” as used in this policy means any information that identifies a Covered Person as an individual or relates to an identifiable person, including Personal Information. The kinds of Personal Information that the Company may collect depends on the nature of the relationship between the Company and the Covered Person. This information may include a Covered Person’s name, job title, and contact details, such as the Covered Person’s address, email address and telephone number. In addition to the information stated above, the Company may collect certain information about a Covered Person’s use of the Company’s online services, for example, the Company may capture a Covered Person’s IP address, operating system, or browser. b. Information provided to the Company: The Company receives and stores any information a Covered Person knowingly provides, as well as additional information collected through a Covered Person’s use of the Company’s website. A Covered Person can choose not to provide the Company with certain information, but then a Covered Person may not be able to engage the Company’s Services, take advantage of some of the Company’s online features, or receive reports or other communications from the Company. Unless another policy applies, the Company may also collect and use information submitted through any support or customer portal related to the Services. If a Covered Person has provided the Company with a means of contacting the Covered Person for particular purposes, the Company may use such means to communicate with the Covered Person for that purpose. If a Covered Person previously provided the Company with their contact information but no longer wishes to receive such communications, a Covered Person can indicate their preference by sending an email to compliance@fiwealth.com. c. Personal Information the Company receives from other sources: The Company may receive Personal Information about a Covered Person from: • other persons engaging the Services of the Company (e.g., if a Customer’s name, phone number and/or email address is mentioned by another Covered Person or provided as a reference); and • third-party service providers (e.g., if a broker or other investment adviser used by a Covered Person engages the Company’s Services for the Covered Person’s account, the Company will receive a Covered Person’s information in order to onboard the Covered Person’s account). The information the Company receives depends on the policies and procedures of that third- party service provider. A Covered Person is responsible for checking the privacy policies and notices of these third-party service providers to understand what data may be disclosed. 45  How the Company Uses the Personal Information it Collects The purposes for which the Company uses the Personal Information of a Covered Person depend in part on the Services provided to the Covered Person, how the Covered Person engages with the Company, and any preferences the Covered Person has communicated to the Company. The Company may use Personal Information of a Covered Person: • to provide the Services requested; • to communicate with a Covered Person (e.g., to deliver any reports or communications, information on new or additional Services or offerings, market updates, etc.); • for security (e.g., to authenticate the identity and authority of a Covered Person, verify accounts and activity, monitor suspicious or fraudulent activity, etc.); • to provide ancillary services and support relating to the Company’s Services to the Covered Person, as applicable; • to operate and maintain the Services being provided; • to process any requests by a Covered Person; • to protect the Company’s legitimate business interests and legal rights; and • with a Covered Person’s consent (i.e., for any purpose not listed above, the Company may use the Personal Information of a Covered Person where the Covered Person has given the Company consent to do so). Protecting Confidential Information Supervised Persons will maintain the confidentiality of the Personal Information acquired in connection with their employment, with particular care being taken regarding Personal Information. Improper use of the Company’s proprietary information, including Personal Information of any Covered Person, is cause for disciplinary action, up to and including termination of employment for cause and referral to the appropriate civil and criminal legal authorities. Consequently, all Supervised Persons are required to sign and adhere to a confidentiality agreement covering these and other matters. Personal Information will be restricted to the Supervised Persons who have a need to know such information. All requests by third parties to review this Privacy Policy, the Company’s Compliance Manual, compliance testing results, correspondence between Company and regulators and other compliance related documents should be forwarded to the Chief Compliance Officer (“CCO”). Supervised persons are not authorized to respond to such requests without prior approval of the CCO. 46  Disclosure of Personal Information Personal Information of a Covered Person may only be provided to third parties under the following circumstances: • To broker-dealers opening brokerage accounts; • To accountants, lawyers, and other professional advisers as directed in writing by the Covered Person; • To specific family members as directed in writing by the Covered Person, or as authorized by law; • To third-party service providers, as necessary, to service the Covered Person’s account(s); and • To governmental or regulatory authorities and any other persons as required by law. Supervised Persons should take responsible precautions to confirm the identity of any persons requesting Personal Information of a Covered Person. Supervised Persons must be careful to avoid disclosures to identify thieves, who may use certain Personal Information of a Covered Person, such as social security number, to convince a Supervised Person to divulge additional Personal Information. Any contacts with suspected identity thieves must be reported promptly to the CCO. To the extent practicable, Supervised Persons will seek to remove nonessential Personal Information of a Covered Person from the information disclosed to third parties. Social security numbers included in any distributed lists or reports must be encrypted. Personal Information of Covered Persons may be accessed by the Company’s outside service providers, such as accountants, lawyers, consultants, and administrators. The Company may review such service providers’ privacy policies to ensure that Personal Information is not used or distributed inappropriately. Regulation S-AM: Under Regulation S-AM, we are prohibited from using eligibility information that we receive from an affiliate to make a marketing solicitation unless: (1) the potential marketing use of that information has been clearly, conspicuously, and concisely disclosed to the Covered Person; (2) the Covered Person has been provided a reasonable opportunity and a simple method to opt out of receiving the marketing solicitations; and (3) the Covered Person has not opted out. We may also disclose the following information to companies that perform marketing services on our behalf or to other financial institutions with which we have joint marketing agreements: • Information we receive from Covered Persons on applications or other forms, such as the Covered Person’s name, address, social security number, assets, and income; • Information about a Covered Person’s transactions with us, our affiliates, or others, such as the Covered Person’s account balance, payment history, parties to transactions, and credit card usage; and 47  • Information we receive from a consumer reporting agency, such as a Covered Person’s creditworthiness and credit history. Regulation S-ID: Regulation S-ID requires the Company to have an Identity Theft Protection Program (ITPP) that controls reasonably foreseeable risks to Covered Persons or to the safety and soundness of the Company from identity theft. The Company has developed an ITPP designed to adequately identify and detect potential red flags to prevent and mitigate identity theft. Access to the Company’s Premises The Company’s premises will be locked outside of normal business hours. Meetings with Covered Persons should be held in conference rooms or other locations where Personal Information is not available or audible to others. Visitors to the Company’s offices will not be left unattended in a manner that will permit unauthorized access to proprietary information of the Company or Personal Information. On an annual basis, the CCO assesses whether information security risks associated with the Company’s physical office have changed in material ways. The Chief Operating Officer and/or Chief Financial Officer and the CCO will work together to address any newly identified vulnerabilities. Information Stored in Hard Copy Formats The Company has implemented the following procedures to protect Personal Information of Covered Persons stored in hard copy formats: • To the extent practicable, Personal Information will be kept in lockable filing cabinets; • All Personal Information, as well as the Company’s proprietary information, should be locked up at the end of each workday; • Documents containing Personal Information must never be left unattended in public spaces, such as lobbies or conference rooms; • Documents being printed, copied, or faxed must not be left unattended; • Supervised Persons will exercise due caution when emailing, mailing, or faxing, documents containing Personal Information to ensure that the documents are sent to intended recipients; and • Supervised Persons may only remove documents containing Personal Information from the Company’s premises for legitimate business purposes. Any documents taken off premises must be handled with appropriate care and returned as soon as practicable. 48  Responding to Privacy Breaches If any Supervised Person becomes aware of an actual or suspected privacy breach, including any improper disclosure of Personal Information, that Supervised Person must promptly notify the CCO. Upon becoming aware of an actual or suspected privacy breach, the CCO will investigate the situation and take the following actions, as appropriate: • To the extent possible, identify the Personal Information that was disclosed and the improper recipients; • Notify any appropriate members of senior management; • Take any action necessary to prevent further improper disclosures; • Take any action necessary to reduce the potential harm from improper disclosures that have already occurred; • As applicable, discuss the issue with legal counsel, and consider discussing the issues with the regulatory authorities and/or law enforcement officials; • Assess notification requirements imposed by applicable state and national regulatory authorities and/or law enforcement officials; • Evaluate the need to notify affected Covered Persons, and make any such notifications; • Collect, prepare, and retain documentation associated with the inadvertent disclosure and Company response(s); and • Evaluate the need for changes to the Company privacy protection policies and procedures in light of the breach. Privacy and Protection Training The CCO or his/her delegate will ensure that all new Supervised Persons have received, reviewed, and understand their obligations to protect Personal Information of Covered Persons. The CCO will remind all Supervised Persons of their privacy protection obligations as part of the Company’s annual compliance training. If the Program appears to be functioning well and has not undergone material changes, then this reminder might appropriately take the form of broadly-distributed annual email. The CCO may provide training more frequently and/or in person to individuals or groups if: • Company’s policies and procedures, or the threats to Personal Information, change in a material way; • Company experiences a privacy breach; and/or • One or more Supervised Persons do not appear to understand their obligations regarding privacy protection. 49  Closed or Inactive Accounts If you decide to close your account(s) or become an inactive Covered Person, our Privacy Policy will continue to apply to you. Changes to this Policy The Company is committed to complying with data privacy laws in every jurisdiction it does business. As such, the Company may amend this Policy from time to time. Use of Personal Information of any Covered Person the Company collects now is subject to the Policy in effect at the time such information is used. If the Company makes changes in the way it uses Personal Information, the Company shall notify its Customers. 50  Appendix A Effective Date: July 18, 2025 FACTS WHAT DOES ADVISER FOUNDATIONS INVESTMENT ADVISORS, LLC (“FIA”) DO WITH YOUR PERSONAL INFORMATION? WHY? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. The types of personal information we collect and share depend on the product or service you have with us. This information can include: ▪ Social security number ▪ Income ▪ Assets WHAT? ▪ Risk tolerance ▪ Wire/bank transfer instructions ▪ Transaction history When you are no longer our customer, we continue to share information about you as described in this notice. HOW? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons FIA chooses to share; and whether you can limit this sharing. Reasons we can share your personal information Does FIA Share? Can you limit this sharing? Yes No For our everyday business purposes - such as to process your transactions, maintain your account(s) or respond to court orders and legal investigations. Yes No For our marketing purposes - to offer our products and services to you. For joint marketing with other financial companies Yes* No Yes No For our affiliates' everyday business purposes - information about your transactions and experiences. No Not Applicable For our affiliates' everyday business purposes – information about your creditworthiness. For our affiliates to market to you Yes Yes For nonaffiliates to market to you Yes Yes Questions? Please call us at: +1.480.626.2979 or visit our website: www.fiwealth.com 51  Page 2 Who we are Who is providing this notice? Foundations Investment Advisors, LLC What we do How does FIA protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We collect your personal information, for example, when you Seek financial advice; How does FIA collect my personal information? ▪ Enter into an investment advisory contract; ▪ ▪ Make deposits or withdrawals from your account; ▪ Tell us about your investment or retirement portfolio; or ▪ Give us your employment history. We also collect your personal information from other companies. Federal law gives you the right to limit only ▪ sharing for affiliates’ everyday business purposes—information about your creditworthiness Why can't I limit all sharing? ▪ affiliates from using your information to market to you ▪ sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. Definitions Companies related by common ownership or control. They can be financial and nonfinancial companies. ▪ Our affiliates include companies with a common corporate identity, including the Affiliates following: Magellan Financial & Insurance Services, LLC; Magellan Healthcare, LLC; Charter Law Group, LLC; Alpha 1 Tax and Wealth Management, LLC; Asset Preservation Tax & Retirement, LLC; Northern Alliance Financial, LLC; Omega Wealth Private Capital, LLC; and Enhance Design Group, LLC. Companies not related by common ownership or control. They can be financial and nonfinancial companies. Nonaffiliates ▪ Other than Joint Marketing as included below, FIA does not share with nonaffiliates so they can market to you. FIA conducts its business through a network of licensed investment adviser representatives, many of whom are also state licensed insurance agents. Joint Marketing ▪ FIA services may be discussed and marketed to you concurrently with other non- securities financial products (Note: FIA is not a licensed insurance company and does not provide investment advice about or recommend any insurance products). Other important information A copy of this privacy notice is available upon request by contacting +1.480.626.2979 or compliance@fiwealth.com. 52