View Document Text
Four Financial Management
WRAP PROGRAM BROCHURE
(APPENDIX 1 TO FIRM BROCHURE)
March 18, 2026
777 E. Eisenhower Pkwy., Suite 740
Ann Arbor, MI 48108
Phone: 734-272-4322
Fax: 734-369-3037
Website: www.fourfinancial.com
This wrap fee program brochure provides information about the qualifications and business
practices of Morman, Kaplan, Brilliant and Fransko, LLC dba Four Financial Management. If
you have any questions about the contents of this brochure, please contact us at (734) 272-4322.
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 Morman, Kaplan, Brilliant and Fransko, LLC dba Four Financial
Management is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this
site by a unique identifying number, known as a CRD number. The CRD number for the Firm is
284251.
ITEM 2 - MATERIAL CHANGES
We have the following material changes to report since our last annual update filing done on
February 25, 2025:
We have no pmaterial changes to report at this time.
Four Financial Management
Page 2
Appendix 1 – 3/18/2026
ITEM 3 - TABLE OF CONTENTS
Item 2. Material Changes .............................................................................................................2
Item 3. Table of Contents .............................................................................................................3
Item 4. Services, Fees and Compensation ...................................................................................4
Item 5. Account Requirements and Types of Clients ................................................................8
Item 6. Portfolio Manager Selection and Evaluation .................................................................8
Item 7. Client Information Provided to Portfolio Managers ..................................................13
Item 8. Client Contact with Portfolio Managers ......................................................................13
Item 9. Additional Information .................................................................................................13
Four Financial Management
Page 3
Appendix 1 – 3/18/2026
ITEM 4 - SERVICES, FEES AND COMPENSATION
Morman, Kaplan, Brilliant and Fransko, LLC dba Four Financial Management (“We”) is a
Michigan Limited Liability Company. We subsequently registered as a Michigan investment
adviser in 2016. Michael Kaplan (“Mr. Kaplan”), Alan Brilliant (“Mr. Brilliant”), David Fransko
(“Mr. Fransko”), and Stephen Morman (“Mr. Morman”) are the co-owners and members of the
firm. Each can act on the firm’s behalf.
SERVICES
We provide advisory services through certain wrap programs sponsored by LPL Financial LLC
(LPL), a registered investment advisor and broker-dealer. Below is a brief description of each
LPL program we use.
STRATEGIC WEALTH MANAGEMENT (SWM)
SWM offers us the flexibility to customize a portfolio for each client. Utilizing various security
types and investment strategies, we work with the client to formulate an individualized portfolio
on the SWM platform based upon his or her objectives, time frame, risk parameters and other
investment considerations. Once we have this information, we create an individualized portfolio
for the client. We regularly monitor the client’s portfolio and adjust it as determined by the stock
market and work events. Strategies employed include:
Asset Allocation - Asset Allocation is an investment strategy that aims to balance risk
and reward by apportioning a portfolio's assets according to an individual's goals, risk
tolerance and investment horizon among various asset classes. The asset classes typically
include equities, fixed-income, alternative investments, and cash and equivalents. Each
class has different levels of risk and return, so each will behave differently over time.
Income – Income strategy prioritizes the objective of dividends, interest and/or
distributions. Portfolios are customized to client objectives and cash flow needs.
Capital Preservation – Capital Preservation strategy prioritizes protection of principal and
reducing downside capital risk.
Tactical Growth – Tactical Growth is an active management strategy in which portfolio
positions are allocated to specific asset classes as a way to increase or decrease overall
portfolio risk and equity and/or bond exposure on a near term basis. The respective asset
classes are determined monthly, using a proprietary algorithm.
OPTIMUM MARKET PORTFOLIOS PROGRAM (OMP)
OMP offers clients the ability to participate in a professionally managed asset allocation program
using Optimum Funds shares. Under OMP, clients authorize LPL’s investment managers, on a
discretionary basis, to purchase and sell Optimum Funds pursuant to investment objectives
chosen by the client. We assist the client in determining the suitability of OMP for the client and
assist the client in setting an appropriate investment objective. We will have discretion to select
a mutual fund asset allocation portfolio designed by LPL consistent with the client’s investment
objective. LPL will have discretion to purchase and sell Optimum Funds pursuant to the portfolio
selected for the client. LPL will also have the authority to rebalance the account.
Optimum funds are mutual funds distributed by Delaware Distributors. Delaware distributors
hires multiple money managers within an asset class. LPL decides the % allocations of those
Four Financial Management
Page 4
Appendix 1 – 3/18/2026
funds depending on the investment objectives. Please note that LPL does not have any of their
own proprietary funds.
A minimum account value of $10,000 is required for OMP. In certain instances, LPL will permit
a lower minimum account size.
MANAGER ACCESS SELECT PROGRAM
Manager Access Select offers clients the ability to participate in the Separately Managed
Account Platform (the “SMA Platform”) or the Model Portfolio Platform (the “MP Platform”).
In the SMA Platform, we will assist the client in identifying a third party portfolio manager
(SMA Portfolio Manager) from a list of SMA Portfolio Managers made available by LPL, and
the SMA Portfolio Manager manages client’s assets on a discretionary basis. We will provide
initial and ongoing assistance regarding the SMA Portfolio Manager selection process. In the
MP Platform, clients authorize LPL to direct the investment and reinvestment of the assets in
their accounts, in accordance with the selected model portfolio provided by LPL’s Research
Department or a third-party investment advisor.
A minimum account value of $50,000 is required for Manager Access Select, however, in certain
instances, the minimum account size may be lower or higher.
FEES
For our portfolio management services, we charge an annualized management fee based on a
percentage of assets under management. Our management fee ranges from 0.25% to 1.50%. The
fee is negotiable, based on the amount of client assets under management and the complexity and
nature of the portfolio management services. The client may aggregate accounts to negotiate a
lower fee. The management fee is calculated and collected on a quarterly basis in advance,
except for the initial quarter of management.
The Optimum Market Portfolios’ program has a separate fee ranging from 0.025% to 0.15%. The
Manager Access Select Program’s has a separate program fee of 0.035% to 0.35%. Its managers
charge from 0.05% to 0.60%. These fees are in addition to our management fee.
The initial quarter’s fees will be prorated for the number of days’ services were provided during
the quarter. However, the initial quarter’s fees will be collected at the end of the quarter based on
the quarter-end account value. Thereafter, the management fee will be calculated on the
account’s previous quarter-end value as reported by the account’s custodian.
In a wrap account, clients pay a single annualized advisory fee for advisory services and
execution of transactions. Clients do not pay brokerage commissions, markups or transaction
charges for execution of transactions in addition to the advisory fee.
Although clients do not pay a transaction charges for trades in their accounts, clients should be
aware that we pay LPL Financial, LLC’s charges for certain transactions. The transaction
charges paid by us vary based on the type of transaction (e.g., mutual fund, equity or fixed
income security) and range from $0 to $40. Because we pay the transaction charges in program
accounts, there is a conflict of interest. Clients should understand that the cost to us of
transaction charges may be a factor that we consider when deciding which securities to select
and how frequently to place transactions in a program account.
In many instances, LPL makes available mutual funds in a SWM account that offer various
classes of shares, including shares designated as Class A Shares and shares designed for advisory
Four Financial Management
Page 5
Appendix 1 – 3/18/2026
programs, which can be titled, for example, as “Class I,” “institutional,” “investor,” “retail,”
“service,” “administrative” or “platform” share classes (“Platform Shares”). The Platform Share
class offered for a particular mutual fund in SWM in many cases will not be the least expensive
share class that the mutual fund makes available and was selected by LPL in certain cases
because the share class pays LPL compensation for the administrative and recordkeeping
services LPL provides to the mutual fund. Client should understand that another financial
services firm may offer the same mutual fund at a lower overall cost to the investor than is
available through SWM. In other instances, a mutual fund may offer only Class A Shares, but
another similar mutual fund may be available that offers Platform Shares. Class A Shares
typically pay LPL a 12b-1 fee for providing brokerage-related services to the mutual funds.
Platform Shares generally are not subject to 12b-1 fees. As a result of the different expenses of
the mutual fund share classes, it is generally more expensive for a client to own Class A Shares
than Platform Shares. An investor in Platform Shares will pay lower fees over time and keep
more of his or her investment returns than an investor who holds Class A Shares of the same
fund.
We have a financial incentive to recommend Class A Shares in cases where both Class A and
Platform Shares are available. Although the client will not be charged a transaction charge for
transactions, we pay LPL a per transaction charge for mutual fund purchases and sales in the
account. We generally do not pay transaction charges for Class A Share mutual fund transactions
accounts, but generally do pay transaction charges for Platform Share mutual fund transactions.
The cost to us of transaction charges generally may be a factor Advisor considers when deciding
which securities to select and whether or not to place transactions in the account.
The lack of transaction charges to our firm for Class A Share purchases and sales, together with
the fact that Platform Shares generally are less expensive for a client to own, presents a
significant conflict of interest between us and the client. Clients should understand this conflict
and consider the additional indirect expenses borne as a result of the mutual fund fees when
negotiating and discussing with us the advisory fee for management of an account.
Termination of Portfolio Management Services
A client may terminate the Investment Management Agreement for any reason at any time and,
within the first five (5) business days after signing the contract, without any cost or penalty.
Thereafter, the contract may be terminated at any time by giving seven (7) days' written notice.
To cancel the Agreement, the client must notify us in writing at Four Financial Management,
LLC, 777 E. Eisenhower Pkwy., Suite 740, Ann Arbor, MI 48108 and return any materials
received to that date. Because we charge in advance, any client that terminates his or her
contract within a quarter will receive a prorated refund of fees that is based on the amount of
time elapsed during the quarter. For example, if a client cancels 45 days in to a 90-day quarter,
the client will receive a refund of 50% of the fees (45 days divided by 90 days equal 50 percent).
Please note that the prorated refund may be adjusted for additional deposits and withdrawals to
the advisory account within the termination quarter. If permitted by the client’s custodian, the
refund will be deposited into the client’s account; otherwise, the refund will be paid to the client
by company check mailed directly to the client within 30 days of termination notice receipt.
Four Financial Management
Page 6
Appendix 1 – 3/18/2026
Other Types of Fees and Charges
Program accounts will incur additional fees and charges from parties other than us as noted
below. These fees and charges are in addition to the advisory fee paid to us. We do not share in
any portion of these third-party fees.
LPL Financial, LLC, as the custodian and broker-dealer providing brokerage and execution
services on program accounts, will impose certain fees and charges. LPL Financial, LLC notifies
clients of these charges at account opening and makes a list of these fees and charges available
on its website at www.LPL.com. LPL Financial, LLC will deduct these fees and charges directly
from the client’s program account.
There are other fees and charges that are imposed by other third parties that apply to investments
in program accounts. Some of these fees and charges are described below.
If a client’s assets are invested in mutual funds or other pooled investment products, he or
she should be aware that there will be two layers of advisory fees and expenses for those
assets. The client will pay an advisory fee to the fund manager and other expenses as a
shareholder of the fund. The client will also pay us the advisory fee with respect to those
assets. Most of the mutual funds available in the program may be purchased directly.
Therefore, clients could generally avoid the second layer of fees by not using our
management services and by making their own investment decisions.
Certain mutual funds impose fees and charges such as contingent deferred sales charges,
early redemption fees and charges for frequent trading. These charges may apply if the client
transfers into or purchases such a fund with the applicable charges in a program account.
Although only no-load and load-waived mutual funds can be purchased in a program
account, the client should understand that some mutual funds pay asset-based sales charges
or service fees (e.g., 12b-1 fees) to the custodian with respect to account holdings.
If client holds a variable annuity as part of an account, there are mortality, expense and
administrative charges, fees for additional riders on the contract and charges for excessive
transfers within a calendar year imposed by the variable annuity sponsor.
Further information regarding fees assessed by a mutual fund or variable annuity is available in
the appropriate prospectus, which is available upon request from us or from the product sponsor
directly.
Other Important Considerations
The advisory fee is an ongoing wrap fee for investment advisory services, the execution of
transactions and other administrative and custodial services. The advisory fee may cost the
client more than purchasing the program services separately, for example, by paying an
advisory fee plus commissions for each transaction in the account. Factors that bear upon the
cost of the account in relation to the cost of the same services purchased separately include
the type and size of the account, historical and or expected size or number of trades for the
account, and number and range of supplementary advisory and client-related services
provided to the client.
The advisory fee also may cost the client more than if assets were held in a traditional
brokerage account. In a brokerage account, a client is charged a commission for each
Four Financial Management
Page 7
Appendix 1 – 3/18/2026
transaction, and the representative has no duty to provide ongoing advice with respect to the
account. If the client plans to follow a buy and hold strategy for the account or does not wish
to purchase ongoing investment advice or management services, the client should consider
opening a brokerage account rather than a program account.
When we recommend the program to the client, we receive compensation as a result of the
client’s participation in the program. This compensation includes the advisory fee and also
may include other compensation, such as bonuses, awards or other things of value offered by
LPL Financial, LLC to us or our associated persons. The amount of this compensation may
be more or less than what we would receive if the client participated in other LPL Financial,
LLC programs or programs of other investment advisors or paid separately for investment
advice, brokerage and other client services. Therefore, we may have a financial incentive to
recommend a program account over other programs and services.
The investment products available to be purchased in the program can be purchased by
clients outside of a program account, through broker-dealers or other investment firms not
affiliated with us.
RETIREMENT ROLLOVER CONFLICTS OF INTEREST
When we recommend you rollover a retirement account for us to manage, this creates a financial
incentive because we charge a fee for our services. We attempt to mitigate the conflict of interest
by acting in your best interest and applying an impartial conduct standard to all rollovers. Please
note that you are not under any obligation to roll over a retirement account to an account
managed by us.
ITEM 5 - ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS
We offer our services to individuals, high net worth individuals, trusts, charities and non-profit
groups, pension and profit-sharing plans, corporations, and other business entities. We do not
have a minimum account size requirement to become a client.
ITEM 6 - PORTFOLIO MANAGER SELECTION AND EVALUATION
In the SWM and OMP programs, we do not select, review or recommend other investment
advisors or portfolio managers. We, through our investment adviser representatives (“IAR”), are
responsible for the investment advice and management offered to clients. For more information
about the IAR managing the account, client should refer to the IAR’s Brochure Supplement
(ADV Part 2B), which the client should have received along with this Brochure at the time he or
she opened the account. By having our IARs act as the portfolio managers to the program there is
a conflict of interest because our evaluation of the IARs as the managers may not be objective.
We attempt to mitigate this conflict of interest by holding our IARs to the same standards to
which we would hold a non-affiliated portfolio manager. Additionally, we attempt to mitigate
this conflict of interest to the best of our ability by placing the client’s interest ahead of our own
through our fiduciary duty.
In the Manager Access Select Program, we select the managers based on performance compared
to an appropriate index selected according to the client’s recommended asset allocation. For
example, if a client is invested in an all-stock portfolio, the manager will be compared to the
S&P 500 Index. We review the managers’ performance information annually.
Four Financial Management
Page 8
Appendix 1 – 3/18/2026
LPL Financial, LLC performs certain administrative services for us, including generation of
quarterly performance reports for program accounts. The client will receive an individual
quarterly performance report, which provides performance information on a time-weighted basis.
The performance reports are intended to inform clients on how their investments have performed
for a period, both on an absolute basis and as compared to leading investment indices.
METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
Depending on the portfolio chosen we use a combination of asset allocation, tactical asset
allocation, and technical analysis. Most model portfolios are designed for long term investment,
but some model portfolios hold securities for much shorter time periods. The following is a
description of each type of analysis and investment strategy.
Asset Allocation is an investment strategy that aims to balance risk and reward by apportioning a
portfolio's assets according to an individual's goals, risk tolerance and investment horizon among
various asset classes. The asset classes typically include equities, fixed-income, alternative
investments, and cash and equivalents. Each class has different levels of risk and return, so each
will behave differently over time. Any asset allocation advice provided by us is based on a
number of factors, including the client’s investment objectives, risk tolerances, asset class
preferences, time horizons, liquidity needs, expected returns and an assessment of current
economic and market views expressed by economists, analysts, banks and securities firms.
Tactical Asset Allocation is an active management portfolio strategy that rebalances the
percentage of assets held in various categories in order to take advantage of market pricing
anomalies or strong market sectors. This strategy is designed to allow portfolio managers to
create extra value by taking advantage of certain situations in the marketplace. It is a moderately
active strategy because portfolio managers return to the portfolio's original strategic asset mix
when desired short-term profits are achieved. The risk associated with this strategy is that the
portfolio could be over-exposed to an underperforming market segment.
Technical Analysis is a method of evaluating securities by analyzing statistics generated by
market activity, such as past prices and volume. Technical analysts do not attempt to measure a
security's intrinsic value, but instead use charts and other tools to identify patterns that can
suggest future activity. The risk associated with technical analysis is that there is no broad
consensus among technical traders on the best method of identifying future price movements.
We purchase securities with the expectation that the value of those securities will grow over a
relatively long period of time, generally greater than one year. The risk associated with using a
long-term purchase strategy is that it generally assumes the financial markets will go up in the
long-term, which may not be the case. There is also the risk that the segment of the market that
the client is invested in, or perhaps just that client’s particular investment, will go down over
time even if the overall financial markets advance. Purchasing investments long-term may create
an opportunity cost by "locking-up" assets that may be better utilized in the short-term in other
investments.
We also purchase securities with the expectation that they will be sold within a relatively short
period of time, generally less than one year, to take advantage of the securities' short-term price
fluctuations. The risk associated with using a short-term purchase strategy is that it generally
assumes that we can predict how financial markets will perform in the short-term, which may be
very difficult and will incur a disproportionately higher amount of transaction costs compared to
Four Financial Management
Page 9
Appendix 1 – 3/18/2026
long-term trading. There are many factors that can affect financial market performance in the
short term, such as short-term interest rate changes and cyclical earnings announcements, but
may have a smaller impact over longer periods of time.
It is important to note that no methodology or investment strategy is guaranteed to be successful
or profitable. It is also important that clients understand the concept and risks inherent in
exchanging an investment from one position to another. Some investment decisions result in
profit and others in losses. Our firm and your representative cannot guarantee that the objectives
of any investment program will be achieved. Furthermore, it is important that each client
understands that the exchange of shares of one mutual fund for shares of another mutual fund is
treated as a sale for federal income tax purposes, and that capital gains or losses may be realized
unless he or she is eligible for tax deferral under a qualified retirement plan.
All investments bear different types and degrees of risk and investing in securities involves risk
of loss that clients should be prepared to bear. While we use investment strategies that are
designed to provide appropriate investment diversification, some investments have significantly
greater risks than others. Obtaining higher rates of return on investments entails accepting higher
levels of risk. Recommended investment strategies seek to balance risks and rewards to achieve
investment objectives. Clients should ask questions about risks they do not understand; we
would be pleased to discuss them.
The account investment management is determined by the stated investment objectives of the
client (i.e., current income, balanced, growth and income, growth and maximum growth). Our
representatives are responsible for developing and determining the investment strategies that will
be used when managing a client's accounts. This strategy is based on the client's individual
financial situation, goals, and objectives. Our representatives are responsible for monitoring
clients' portfolios and, when appropriate, reallocating the portfolios based on changing market
conditions, changes in a client's individual circumstances, or other factors. If the account is
managed on a non-discretionary basis, the representative will consult the client prior to
reallocating securities in his or her account. Reallocations are implemented in discretionary
accounts without prior notice to clients.
If a client's individual situation changes, he or she should notify his or her representative, who
will assist the client in revising the current portfolio or prepare an updated client profile so that
the representative can determine if a different model portfolio would be appropriate to the client's
new situation.
We use several types of securities in client portfolios including, but not limited to, mutual funds,
stocks, bonds, government issued securities, money market funds and also the following:
Alternative Strategy Mutual Funds. Certain mutual funds available in the program invest
primarily in alternative investments or strategies. Investing in alternative investments or
strategies may not be suitable for all investors and involves special risks, such as risks
associated with commodities, real estate, leverage, selling securities short, the use of
derivatives, potential adverse market forces, regulatory changes and potential illiquidity.
There are special risks associated with mutual funds that invest principally in real estate
securities, such as sensitivity to changes in real estate values and interest rates and price
volatility because of the fund’s concentration in the real estate industry.
Four Financial Management
Page 10
Appendix 1 – 3/18/2026
Closed-End Funds. Clients should be aware that closed-end funds available within the
program are not readily marketable. In an effort to provide investor liquidity, the funds
may offer to repurchase a certain percentage of shares at net asset value on a periodic
basis. Thus, clients may be unable to liquidate all or a portion of their shares in these
types of funds.
Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are
legally classified as open-end mutual funds or UITs. However, they differ from
traditional mutual funds, in particular because ETF shares are listed on a securities
exchange. Shares can be bought and sold throughout the trading day like shares of other
publicly traded companies. ETF shares may trade at a discount or premium to their net
asset value. This difference between the bid price and the ask price is often referred to as
the “spread.” The spread varies over time based on the ETF’s trading volume and market
liquidity and is generally lower if the ETF has a lot of trading volume and market
liquidity and higher if the ETF has little trading volume and market liquidity. Although
many ETFs are registered as investment companies under the Investment Company Act
of 1940 like traditional mutual funds, some ETFs, especially those that invest in
commodities, are not registered as investment companies.
Exchange-Traded Notes (ETNs). An ETN is a senior unsecured debt obligation designed
to track the total return of an underlying market index or other benchmark. ETNs may be
linked to a variety of assets, including commodity futures, foreign currency and equities.
ETNs are similar to ETFs because they are listed on an exchange and can typically be
bought or sold throughout the trading day. However, an ETN is not a mutual fund and
does not have a net asset value; the ETN trades at the prevailing market price. Some of
the more common risks of an ETN include the following: the repayment of the principal,
interest (if any), and the payment of any returns at maturity or upon redemption are
dependent upon the ETN issuer’s ability to pay; the trading price of the ETN in the
secondary market may be adversely impacted if the issuer’s credit rating is downgraded;
and the index or asset class for performance replication in an ETN may or may not be
concentrated in a specific sector, asset class or country and may therefore carry specific
risks.
Leveraged and Inverse ETFs, ETNs and Mutual Funds. Leveraged ETFs, ETNs and
mutual funds, sometimes labeled “ultra” or “2x” for example, are designed to provide a
multiple of the underlying index's return, typically on a daily basis. Inverse products are
designed to provide the opposite of the return of the underlying index, typically on a daily
basis. These products are different from and can be riskier than traditional ETFs, ETNs
and mutual funds. Although these products are designed to provide returns that generally
correspond to the underlying index, they may not be able to exactly replicate the
performance of the index because of fund expenses and other factors. This is referred to
as tracking error. Continual re-setting of returns within the product may add to the
underlying costs and increase the tracking error. As a result, this may prevent these
products from achieving their investment objective. In addition, compounding of the
returns can produce a divergence from the underlying index over time, especially for
leveraged products. In highly volatile markets with large positive and negative swings,
return distortions are magnified over time. Because of these distortions, these products
should be actively monitored, as frequently as daily, and are generally not appropriate as
Four Financial Management
Page 11
Appendix 1 – 3/18/2026
an intermediate or long-term holding. To accomplish their objectives, these products use
a range of strategies, including swaps, futures contracts and other derivatives. These
products may not be diversified and can be based on commodities or currencies. These
products may have higher expense ratios and be less tax-efficient than more traditional
ETFs, ETNs and mutual funds.
Options. Certain types of option trading are permitted in order to generate income or
hedge a security held in the program account; namely, the selling (writing) of covered
call options or the purchasing of put options on a security held in the program account.
Clients should be aware that the use of options involves additional risks. The risks of
covered call writing include the potential for the market to rise sharply. In this situation,
the security may be called away and the program account will no longer hold the security.
The risk of buying long puts is limited to the loss of the premium paid for the purchase of
the put if the option is not exercised or otherwise sold by the program account.
Structured Products. Structured products are securities derived from another asset, such
as a security or a basket of securities, an index, a commodity, a debt issuance, or a
foreign currency. Structured products frequently limit the upside participation in the
reference asset. Structured products are senior unsecured debt of the issuing bank and
subject to the credit risk associated with that bank. This credit risk exists whether or not
the investment held in the account offers principal protection. The creditworthiness of the
issuing bank does not affect or enhance the likely performance of the investment other
than the ability of the issuing bank to meet its obligations. Any payments due at maturity
are dependent on the issuing bank's ability to pay. In addition, the trading price of the
security in the secondary market, if there is one, may be adversely impacted if the issuing
bank's credit rating is downgraded. Some structured products offer full protection of the
principal invested, while others offer only partial or no protection. Investors may be
sacrificing a higher yield to obtain the principal guarantee. In addition, the principal
guarantee relates to nominal principal and does not offer inflation protection. An investor
in a structured product never has a claim on the underlying investment, whether the
underlying investment is a security, zero coupon bond, or option. There may be little or
no secondary market for the securities and information regarding independent market
pricing for the securities may be limited. This is true even if the product has a ticker
symbol or has been approved for listing on an exchange. Tax treatment of structured
products may be different from other investments held in the account (e.g., income may
be taxed as ordinary income even though payment is not received until maturity).
Structured CDs that are insured by the FDIC are subject to applicable FDIC limits.
Variable Annuities. If a client purchases a variable annuity that is part of the program, he
or she will receive a prospectus and should rely solely on the disclosure contained in the
prospectus with respect to the terms and conditions of the variable annuity. Clients
should also be aware that certain riders purchased with a variable annuity may limit the
investment options and the ability to manage the subaccounts.
PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
We do not charge any performance-based fees (fees based on a share of capital gains on or
capital appreciation of the assets of a client) or perform side-by-side management.
Four Financial Management
Page 12
Appendix 1 – 3/18/2026
VOTING CLIENT SECURITIES
We do not accept authority to vote client securities. Clients retain the right to vote all proxies that
are solicited for securities held in the account. Clients will receive proxies or other solicitations
from the custodian of assets. If clients have questions regarding the solicitation, they should
contact us or the contact person that the issuer identifies in the proxy materials. In addition, we
do not accept authority to act with respect to legal proceedings relating to securities held in the
account.
ITEM 7 - CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS
In our wrap program, we are responsible for account management; there is no separate portfolio
manager involved. We obtain the necessary financial data from the client and assist the client in
setting an appropriate investment objective for the account. We obtain this information by having
the client complete an advisory agreement and other documentation. Clients are encouraged to
contact us if there have been any changes in their financial situation or investment objectives or
if they wish to impose any reasonable restrictions on the management of the account or
reasonably modify existing restrictions. Each client should be aware that the investment
objective selected for the program is an overall objective for the entire account and may be
inconsistent with a particular holding and the account’s performance at any time. Each client
should also be aware that achievement of the stated investment objective is a long-term goal for
the account.
ITEM 8 - CLIENT CONTACT WITH PORTFOLIO MANAGERS
Clients should contact us at any time with questions regarding program accounts.
ITEM 9 - ADDITIONAL INFORMATION
DISCIPLINARY INFORMATION
A registered investment adviser is required to disclose all material facts regarding any legal or
disciplinary events within the past 10 years that would be material to a client's evaluation of the
adviser or the integrity of its management. We have no information applicable to this Item
because we have not been the subject of any administrative, civil, criminal or regulatory
proceedings.
OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Our associates are licensed as registered representatives and investment adviser representatives
of LPL Financial, LLC, a full-service broker/dealer and member FINRA/SIPC and registered
investment adviser. In this capacity, they can affect securities transactions and may receive
separate yet customary compensation for effecting any securities transactions. Our associates
may spend the majority of their time involved in all or a portion of these activities.
This could present a potential conflict of interest if the client elects to implement our
recommendations and also selects our associates to execute those transactions. In this case, our
associates could receive both fees as advisor representatives and commissions as registered
representatives or investment adviser representatives. As registered representatives, they could
also receive compensation from mutual fund sales loads, 12(b)-1 distribution fees, variable
annuity sales commissions or trail commissions. The 12(b)-1 distribution fees, sales charges and
other fee arrangements will be disclosed to a client upon request and are typically described in
Four Financial Management
Page 13
Appendix 1 – 3/18/2026
the applicable fund or annuity prospectus. Any fees or other compensation received by our
associates in their separate capacities as registered representatives will be received to the extent
permitted by applicable law.
Because of these compensation arrangements, a conflict of interest could exist in connection with
our associates recommending particular investments for a client’s account. Clients have sole
discretion whether to implement any or all of the associated persons’ recommendations. In
addition, clients are free to select any broker/dealer they wish to implement recommendations.
Our owners also own Kaplan, Brilliant, and Fransko, LLC dba Provizr, a Michigan registered
investment adviser. Provizr pays them fees that are separate from the fees described above. This
is a conflict of interest because the additional fee creates a financial incentive to recommend the
other adviser’s services. However, we attempt to mitigate any conflicts of interest to the best of
our ability by placing the clients’ interests ahead of our own, through our fiduciary duty and by
informing clients that they are never obligated to recommended services through us or our
owners.
Our owners may be independent insurance agents (Life, Long term Care and Health) and they
may recommend these services to clients. This other business activity pays our associates
commissions that are separate from the fees described above. This is a conflict of interest
because the commissions give our associates a financial incentive to recommend and sell clients
the insurance products. However, our associates attempt to mitigate any conflicts of interest to
the best of their ability by placing the clients’ interests ahead of their own, through their
fiduciary duty and by informing clients that they are never obligated to purchase recommended
insurance through them.
Finally, our owners may provide tax preparation services through Four Financial Tax Services.
They may recommend these services to clients. This other business activity pays them fees that
are separate from the investment management fees described above. This is a conflict of interest
because the tax preparation fees give them a financial incentive to recommend the tax
preparation services. However, they attempt to mitigate any conflicts of interest to the best of
their ability by placing the clients’ interests ahead of their own, through their fiduciary duty and
by informing clients that they are never obligated to purchase recommended tax preparation
services through them.
CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL
TRADING
Our Approach to Conflicts of Interest
Conflicts of interest that may arise in the course of providing investment management services
are described throughout this brochure, as are some of our policies and procedures designed to
address specific conflicts of interest, including our Code of Ethics and personal trading practices.
We have a compliance program in place that is intended to identify, mitigate and, in some
instances, prevent actual and potential conflicts of interest, ensure compliance with legal and
regulatory requirements and ensure compliance with client investment guidelines and
restrictions. Our compliance program includes written policies and procedures that we believe
are reasonably designed to prevent violations of applicable law and regulations.
Four Financial Management
Page 14
Appendix 1 – 3/18/2026
Code of Ethics
According to the Investment Advisers Act of 1940, an investment advisor is considered a
fiduciary and has a fiduciary duty to clients. The applicant has established a Code of Ethics to
comply with the requirements of Section 204(A)-1 of the Investment Advisors Act of 1940 that
reflects fiduciary obligations and those of its supervised persons and requires compliance with
federal securities laws. Our Code of Ethics covers all individuals that are classified as
“supervised persons”. All employees, officers, directors and investment advisor representatives
are classified as supervised persons. We require our supervised persons to consistently act in
their clients' best interests in all advisory activities. We impose certain requirements on our
affiliates and supervised persons to ensure that they meet our fiduciary responsibilities to our
clients. The standard of conduct required is higher than ordinarily required and encountered in
commercial business.
This section is only intended to provide current and potential clients with a description of our
Code of Ethics. If a client wishes to review the Code of Ethics in its entirety, he or she may
request a copy in writing, and we will promptly provide a copy.
Participation or Interest in Client Transactions
In the event that LPL Financial, LLC, our broker/dealer, executes securities transactions through
LPL Financial, LLC on behalf of a client or a client's representative, the representative may
receive advisory fees and broker/dealer commissions for the sale of securities placed under our
management. The receipt of compensation from a variety of sources may be considered to be a
conflict of interest. We encourage each client to review this ADV closely and discuss any
potential conflicts of interest with his or her representative.
We will process brokerage security transactions through LPL Financial, LLC so long as we
determine that executing the transactions through our broker/dealer fulfills our duty of best
execution. We consider certain factors when selecting a broker/dealer and determining the
reasonableness of commissions. Please refer to the section titled “Brokerage Practices” for more
information.
Policy Regarding Engaging in Agency Cross Transactions in Advisory Accounts
It is our policy to prohibit representatives from engaging in agency cross transactions where
representatives act as brokers for both buying and selling a single security between two different
clients for which the representatives receive compensation in the form of an agency commission
or principal mark-up for the trades. Should we adopt a different policy in this area, we will
observe all rules and regulations in accordance with the disclosure and consent requirements of
Section 206(3) of the Advisers Act. Additionally, we are aware that these transactions can only
occur if we can ensure that we meet our duty of best execution for the client.
Policy Regarding Engaging in Principal Trading Involving Advisory Accounts
We do not permit principal transactions to be affected in advisory accounts.
Personal Trading
We and our associates may recommend securities to buy or sell or hold a position in securities
identical to the securities recommended to a client at or about the same time that we, our
Four Financial Management
Page 15
Appendix 1 – 3/18/2026
associates or a related person buys or sells the same securities for their own or a related person’s
account. It is our policy that no supervised person will put his or her interest before a client's
interests. Our firm and our representatives may not trade ahead of any client or trade in a way
that would cause the supervised person to obtain a better price than the price a client would
obtain.
Our Pre-Clearance and Restricted Securities Policy
Due to our affiliation with other investment companies, investment advisors, and broker dealers,
LPL Financial, LLC, on our behalf, maintains a Restricted and Pre-Clearance Equity List, which
may limit our firm and the representative's ability to transact in certain equities on a client's
behalf in a discretionary advisory program. A client's representative may not be able to place
certain transactions or may experience delays in submitting certain transactions on a client's
behalf based on any pre-clearance or pre-approval requirements implemented by the firm. A
client may receive a worse price than what he or she might receive if he or she had placed the
transaction through another investment advisor representative not affiliated with LPL Financial,
LLC and not subject to any trading restrictions. These trading restrictions are subject to change
without notice.
REVIEW OF ACCOUNTS
Frequency of Account Reviews
Mr. Kaplan, Mr. Brilliant, Mr. Fransko, and Mr. Morman or an Associate, make a reasonable
attempt to meet with clients, either in person or by telephone, on an annual basis to discuss and
review their accounts.
All accounts will be reviewed at least annually by one or more of Mr. Kaplan, Mr. Brilliant, Mr.
Fransko, Mr. Morman or an Associate to ascertain standards of suitability and investment objective.
Review Triggers
The calendar is the triggering factor. Factors triggering an account review may include material
market, economic or political events, and significant changes in a client's financial or personal
situation or performance of a client's account in general.
Reports and Account Statements
Each client will receive at least quarterly statements from the account custodian or clearing firm.
These statements will show any activity in the account, fees paid, as well as period ending
position balances.
To the extent that a client receives performance reports from his or her representative, we urge
the client to compare performance reports received with account statements received from the
custodian. Inquiries or concerns regarding the account, including performance reports, should be
directed to the investment advisor firm at the phone number listed on the account statement.
Each representative then decides whether to provide these reports to his or her clients.
Performance information provided by a representative is believed to be accurate but cannot be
guaranteed. A client's representative may or may not include variable annuity account position
information within performance reports. Neither our firm nor a client's representative can
guarantee the accuracy of fund values, securities and other information obtained from third
parties.
Four Financial Management
Page 16
Appendix 1 – 3/18/2026
CLIENT REFERRALS AND OTHER COMPENSATION
We do not pay for client referrals or use solicitors.
Our representatives may receive incentives to join and remain affiliated with our current
broker/dealer, LPL Financial, LLC, through certain compensation arrangements that could
include bonuses, enhanced pay-outs, forgivable loans or business transition loans. In addition,
we may recommend the services of SEI to our clients, in which SEI will charge the client and a
portion of that fee will be paid to us. The receipt of such compensation may be considered to be
a conflict of interest. We encourage each client to review this ADV closely and discuss any
potential conflicts of interest with his or her representative.
FINANCIAL INFORMATION
We do not have any financial impairment that will preclude us from meeting our contractual
commitments to our clients. We do not serve as a custodian for clients' funds or securities. At no
time will fees of more than $500 be charged six or more months in advance by our firm or a
client's representative. We have established policies and procedures designed to prevent the
collection of fees greater than $500 six or more months in advance. As such, a balance sheet is
not required to be provided at this time.
Also, we have not been the subject of a bankruptcy proceeding.
CUSTODY
LPL Financial, LLC is the qualified custodian and maintains custody of client funds and
securities in a separate account for each client under his or her name. LPL Financial, LLC as a
qualified custodian sends account statements showing all transactions, positions, and all deposits
and withdrawals of principal and income. LPL Financial, LLC sends account statements monthly
when the account has had activity or quarterly if there has been no activity. Clients should
carefully review those account statements.
Although most securities available in program accounts are held in custody at LPL Financial,
LLC, there are certain securities managed as part of the account that are held by third parties, and
not at LPL Financial, LLC. For example, variable annuities, hedge funds and managed futures
are often held directly with the investment sponsor. For those outside positions, clients will
receive confirmations and statements directly from the investment sponsor.
For outside positions that are not held in custody at LPL Financial, LLC, LPL Financial, LLC
may receive information such as the number of shares held and market value from the
investment sponsor and display that information on statements and reports prepared by LPL
Financial, LLC. This information may also be used to calculate performance in performance
reports prepared by LPL Financial, LLC. Although we believe that the information provided by
LPL Financial, LLC is accurate, we recommend that clients refer to the statements and reports
received directly from the investment sponsor and compare them with the information provided
in any statements or reports from LPL Financial, LLC. The statements and reports provided by
LPL Financial, LLC with respect to outside positions should not replace the statements and
reports received directly from the investment sponsor.
The SEC issued a no-action letter (“Letter”) with respect to the Rule 206(4)-2 (“Custody Rule”)
under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on
the Custody Rule as well as clarified that an adviser who has the power to disburse client funds
Four Financial Management
Page 17
Appendix 1 – 3/18/2026
to a third party under a standing letter of instruction (“SLOA”) is deemed to have custody. As
such, our firm has adopted the following safeguards in conjunction with our custodian LPL
Financial:
- The client provides an instruction to the qualified custodian, in writing, that includes the
client’s signature, the third party’s name and either the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
- The client authorizes the investment adviser, in writing, either on the qualified
custodian’s form or separately, to direct transfers to the third party either on a specified
schedule or from time to time.
- The client’s qualified custodian performs appropriate verification of the instruction, such
as a signature review or other method to verify the client’s authorization and provides a
transfer of funds notice to the client promptly after each transfer.
- The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
- The investment adviser has no authority or ability to designate or change the identity of
the third party, the address or any other information about the third party contained in the
client’s instruction.
- The investment adviser maintains records showing that the third party is not a related
party of the investment adviser or located at the same address as the investment adviser.
- The client’s qualified custodian sends the client, in writing, an initial notice confirming
the instruction and an annual notice reconfirming the instruction.
Four Financial Management
Page 18
Appendix 1 – 3/18/2026