INDEPENDENT FINANCIAL PARTNERS

FORM ADV PART 2A BROCHURE IFP ADVISORS, LLC, DOING BUSINESS AS INDEPENDENT FINANCIAL PARTNERS 3030 North Rocky Point Drive West, Suite 700 Tampa, FL 33607 813-341-0960 www.ifpartners.com Effective Date: November 2025 This Brochure provides information about the qualifications and business practices of IFP Advisors, LLC (“IFP”). If you have any questions about the contents of this Brochure, please contact us at the telephone number above. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. IFP is a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. The oral and written communications of an adviser provide you with information that you may use to determine whether to hire or retain an adviser. Additional information about IFP is available on the SEC’s website at www.adviserinfo.sec.gov.  _____________________________________________________________________________________________________________________ ITEM 2. MATERIAL CHANGES This is a new, service-specific Form ADV Part 2A prepared to describe IFP’s Family Office Services offering for high net worth and ultra-high-net-worth individuals and families. This brochure is derived from IFP’s primary Form ADV Part 2A but has been materially revised to (i) limit the scope of services described to Family Office Services, (ii) incorporate advisory services related to complex assets, including direct real estate advisory support, and (iii) tailor disclosures to the needs and risks of sophisticated private clients. Clients may obtain a copy of this Brochure at any time, without charge. [ 2 ]  ITEM 3. TABLE OF CONTENTS _____________________________________________________________________________________________________________________ ITEM 2. MATERIAL CHANGES ........................................................................................................................................................ 2 ITEM 4. ADVISORY BUSINESS ........................................................................................................................................................ 4 ITEM 5. FEES AND COMPENSATION ........................................................................................................................................... 6 ITEM 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ................................................................. 10 ITEM 7. TYPES OF CLIENTS ....................................................................................................................................................... 10 ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS .................................................... 10 ITEM 9. DISCIPLINARY INFORMATION ..................................................................................................................................... 21 ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ..................................................................... 21 ITEM 11. CODE OF ETHICS, PARTICIPATION IN CLIENT TRANSACTIONS AND PERSONAL TRADING ................ 23 ITEM 12. BROKERAGE PRACTICES ............................................................................................................................................. 24 ITEM 13. REVIEW OF ACCOUNTS ............................................................................................................................................... 36 ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION ........................................................................................... 37 ITEM 15. CUSTODY .......................................................................................................................................................................... 39 ITEM 16. INVESTMENT DISCRETION ......................................................................................................................................... 39 ITEM 17. VOTING CLIENT SECURITIES ...................................................................................................................................... 40 ITEM 18. FINANCIAL INFORMATION ......................................................................................................................................... 40 [ 3 ]  _____________________________________________________________________________________________________________________ ITEM 4. ADVISORY BUSINESS OVERVIEW IFP Advisors, LLC (“IFP”) has been registered as an investment adviser with the SEC since 2008. This Brochure describes IFP’s Family Office Services, which are offered as a specialized advisory engagement to select high net worth and ultra-high-net-worth clients, including multi-generational families, family offices, and related trusts and entities. Family Office Services are designed to provide coordinated, holistic advisory support across a client’s complex financial life. These services are broader in scope than traditional portfolio management and may include strategic oversight of both securities and non-securities assets held across multiple custodians, entities, and jurisdictions. TYPES OF ADVISORY SERVICES Real Estate Advisory Platform IFP Advisors has expanded its services to include a Real Estate Advisory Platform tailored to ultra-high-net-worth clients (generally those with net worth exceeding $100 million). Through this platform, we provide non-discretionary advice and asset management support for direct real estate investments held outside of traditional brokerage custodians. Clients typically hold real properties in their own name or through client-controlled entities (e.g. LLCs or trusts), and IFP serves as a consultant and co-manager alongside the client’s Investment Adviser Representative (IAR). Our services encompass strategic real estate portfolio construction and investment planning, sourcing and evaluating prospective property investments, coordinating third-party due diligence and underwriting, assisting with transaction negotiations and closings, and ongoing oversight of each property’s performance. We help monitor rental income, occupancy and lease events, capital expenditures, and the execution of each property’s business plan. Additionally, we coordinate with any third-party operating partners or property managers on the client’s behalf, and we provide periodic reporting on asset performance and value. Finally, we coordinate with the client’s third-party service providers, such as legal and tax advisors, to assist with refinancing opportunities, dispositions, or 1031 like-kind exchanges. All advice under this platform is provided on a non-discretionary basis – the client retains ultimate decision-making authority on each investment. Services may include, but are not limited to: • Strategic Real Estate Portfolio Construction & Investment Planning • Sourcing and Evaluating Prospective Property Investments • Coordinating Third-party Due Diligence and Underwriting • Assisting with Transaction Negotiations and Closings • Ongoing Oversight of each Property’s Performance • Management of Ancillary Accounts IFP’s Family Office Services are primarily non-discretionary in nature, except where clients separately engage IFP for discretionary investment management of securities portfolios under a written agreement Strategic Real Estate Portfolio Construction & Investment Planning IFP works with clients and their Investment Adviser Representative (IAR) to design and maintain a strategic real estate allocation aligned with the client’s overall investment objectives, liquidity needs, risk tolerance, tax considerations, and long-term wealth planning goals. This includes advising on target allocations by property type, geography, risk profile, and evaluating how direct real estate holdings integrate with the client’s broader balance sheet. Sourcing and Evaluating Prospective Property Investments. IFP assists clients in identifying and evaluating potential direct real estate investments that align with their stated objectives and portfolio strategy. This may include but is not limited to, sourcing opportunities through sponsor relationships, operating partners, off-market channels, or client-initiated ideas. IFP supports preliminary screening by reviewing property fundamentals, market dynamics, sponsor or operator capabilities, projected returns, and key risks. IFP will help clients compare opportunities and determine whether a prospective investment fits within the client’s overall real estate strategy. [ 4 ]  Coordinating Third-party Due Diligence and Underwriting. In collaboration with real estate sponsors, operating partners, third-party service providers, the client, and their IAR, IFP will assist in overseeing the real estate due diligence process. This may include reviewing work from inspectors, appraisers, engineers, surveyors, environmental consultants, legal counsel, tax advisors, and lenders. IFP assists in reviewing financial models and underwriting assumptions and identifying key risks and mitigants. While IFP does not replace third-party experts, we help clients synthesize findings, evaluate tradeoffs, and understand how diligence outcomes may impact investment decisions. Assisting with Transaction Negotiations and Closings IFP will support clients throughout the transaction execution process by coordinating with the client’s legal counsel, lenders, and other transaction participants in the review of deal structuring considerations and economic terms. This may include reviewing proposed terms within purchase agreements, financing structures, capital stack considerations, and closing timelines to alignment with the client’s investment objectives. All transaction decisions and approvals remain solely with the client and IFP is not acting as the client’s legal or tax advisor. Ongoing Oversight of each Property’s Performance Following acquisition, IFP provides ongoing, non-discretionary advisory support related to the monitoring of each property’s performance and operation. This includes reviewing operating results, capital expenditures, reserves, and progress against the property’s business plan. IFP coordinates with third-party operators or property managers, as applicable, to help clients stay informed and address material issues as they arise. IFP also assists with periodic performance and valuation reporting and collaboration with the client’s legal and tax advisors on refinancing opportunities, disposition decisions, and 1031 like-kind exchanges. Management of Ancillary Accounts IFP will provide discretionary investment management services for ancillary accounts established in connection with direct real estate investments. These ancillary accounts are generally maintained at a custodian for purposes such as holding working capital, reserving funds for anticipated capital expenditures, or managing excess cash generated from net income distributions. IFP exercises discretionary authority solely with respect to the investment of cash and cash-equivalent assets held in these ancillary accounts, in accordance with the client’s stated investment objectives, liquidity needs, and risk tolerance. Investments are typically limited to highly liquid, conservative instruments intended to preserve capital and maintain liquidity, such as money market funds, U.S. Treasury securities, or other short-term fixed income investments. IFP’s discretionary authority does not extend to real estate assets themselves, nor does it include authority over property operations, capital allocation decisions, or the timing or amount of capital contributions or distributions related to the underlying real estate investments. Clients retain full authority over all real estate-related decisions, including acquisitions, operations, property management, financings, funding of ancillary accounts, capital expenditures, and dispositions. Management of ancillary accounts is subject to the same compliance, reporting, and oversight framework applicable to IFP’s discretionary securities advisory services. Discretionary Authority IFP’s Family Office Services are primarily non-discretionary in nature. As part of Family Office Services, IFP provides non-discretionary advisory services for direct real estate investments held outside traditional brokerage custodians. Clients typically hold real estate through client-controlled entities. All real estate-related recommendations are advisory only and clients retain full decision-making authority. When managing ancillary investment accounts, clients retain sole authority over the amount of capital to be allocated to such accounts, including decisions regarding funding levels, withdrawals, and the timing of contributions or distributions in connection with their real estate investments. Ancillary accounts are typically held at a qualified third-party custodian in the client’s name or in the name of a client-controlled entity. Pursuant to the Real Estate Advisory Services Agreement, IFP will be granted discretionary authority to manage funds held within such ancillary accounts. This discretionary authority is limited solely to the selection, purchase, sale, and reallocation of securities and cash equivalents within the account and does not extend to deciding how much capital is allocated to the account or to making any real estate-related decisions. IFP’s management of ancillary accounts is intended to support the ownership and operation of client-owned real estate by managing liquidity, preserving capital, [ 5 ]  and maintaining funds for anticipated real estate-related obligations. All discretionary management of ancillary accounts is subject to the same compliance, reporting, and oversight framework applicable to IFP’s discretionary securities advisory services. Assets Under Advisement Assets associated with Family Office Services may include both securities and non-securities assets and may be reported as assets under advisement. For purposes of this ADV, as of 01/01/2026, IFP currently does not have Assets Under Advisement related to its Family Office Services offering. _____________________________________________________________________________________________________________________ ITEM 5. FEES AND COMPENSATION ASSET BASED FEE For our real estate advisory services, IFP charges a tiered asset-based management fee calculated as a percentage of total assets under advisement (“AUA”). IFP’s asset-based advisory fees are subject to applicable fee breakpoints based on a client’s aggregate AUA. For purposes of determining the applicable fee tier for a billing period, IFP uses the average daily AUA for the quarter. If the client’s average daily AUA for the applicable billing period meets or exceeds a breakpoint threshold, the corresponding fee rate applies to the entire average daily AUA for that billing period, rather than being applied on a graduated or marginal basis. Changes in AUA that affect the applicable fee tier are reflected through the average daily AUA calculation for the applicable billing period and are not applied retroactively to prior periods. The fee schedule is as follows: ASSETS UNDER ADVISEMENT (“AUA”) FEE (PERCENTAGE OF AUA) Less than $30,000,000 1.65% Greater than or equal to $30,000,000 but less than $60,000,000 1.25% Greater than or equal to $60,000,000 but less than $90,000,000 1.10% Greater than $90,000,000 1.00% VALUATION OF ASSETS Valuation of Direct Real Estate Assets: For purposes of calculating assets under advisement (“AUA”) with respect to Real Estate Investments consisting of direct real property interests or entity interests for which appraisal-based valuation is appropriate, each property shall initially be valued at the total purchase price stated in the fully executed purchase and sale agreement for such property, plus any cash or investment accounts connected to its management together with the value of any cash, cash equivalents, money-market instruments, and securities accounts maintained by or for the Client that are ancillary to, and used for, the ownership, operation, working capital, capital expenditures, or reserves of such property (collectively, “Ancillary Accounts”), minus any mortgage or line of credit secured by such property. Billing shall commence on the closing date. IFP charges asset-based advisory fees for its real estate advisory services, which are calculated and billed quarterly in arrears. Fees are based on the average daily value of AUA during the applicable billing period, determined in accordance with the valuation methodologies described below. Each property shall be revalued annually as of a valuation date not later than 30 days after the anniversary of the property’s closing date (or such other date as the parties may agree in writing) based on an independent appraisal. The appraiser shall be selected by IFP and shall be reasonably acceptable to the Client, provided that failure by the Client to object in writing within ten (10) business days after IFP’s notice of selection shall constitute acceptance. The discounted cash flow method shall be the default valuation methodology unless IFP and the Client agree in writing that another recognized valuation method is more appropriate for a particular property (e.g., cost approach for development assets or income-capitalization approach for stabilized properties). For purposes of calculating average daily AUA, the appraised or otherwise determined property value remains constant throughout the applicable period until updated by a subsequent valuation. [ 6 ]  Outstanding mortgages or other indebtedness associated with real estate investments are reflected based on actual loan balances, which generally change over time due to scheduled principal amortization. For fee calculation purposes, loan balances are updated as payments are made, and the resulting net equity value of each property is incorporated into the average daily AUA calculation. Valuation of Securities and Other Non-Appraised Investments: With respect to Real Estate Investments consisting of securities or investment interests that are not subject to the appraisal mechanism mentioned above, AUA shall be determined by reference to (i) for publicly traded securities, a weighted average valuation of the daily closing price on the principal exchange or trading venue; (ii) for other marketable instruments, a weighted average valuation of the daily closing value reported by the qualified custodian or the pricing source customarily used for such instruments; and (iii) for private pooled investment vehicles, including limited liability companies, limited partnerships, special-purpose entities, co-investment vehicles, and private real-estate funds, a daily weighted average valuation of the client’s pro rata portion of the capital account value, NAV, or other valuation reported by the manager, general partner, or administrator of such vehicle, as reflected in the quarterly, monthly, or event-driven valuation statements provided to the client. For the avoidance of doubt, any Ancillary Accounts comprised of securities or cash equivalents associated with such investments shall be included in AUA and valued in accordance to the above methodology. Notwithstanding anything to the contrary in the Primary Advisory Agreement, any cash, cash-equivalent, money-market, securities, working- capital, capital-expenditure, or reserve accounts that are ancillary to, and maintained for the ownership, operation, financing, or disposition of, the client’s Real Estate Investments shall be included in AUA and billed under the Real Estate Advisory Services Agreement, even if such accounts are maintained at or through a qualified custodian. IFP will avoid duplicative billing; to the extent any Ancillary Account is included in AUA and billed under the Real Estate Advisory Services Agreement, it shall not be billed under the Primary Advisory Agreement. Under the FORE agreement, Ancillary Accounts are subject to a differentiated billing structure relative to Accounts governed by IFP’s Advisory Account Form. In practice, this results in Ancillary Accounts being assessed at a generally higher fee level, reflecting their distinct servicing framework and economic profile. BILLING METHOD AND FREQUENCY IFP is generally compensated by fees calculated as a percentage of assets under advisement (“AUA fees”). Fees that are calculated as a percentage of AUA are charged quarterly in arrears, based upon the average daily balance of the AUA, including on money market and other cash equivalent assets, during the relevant billing period. When accounts are billed quarterly, they are billed primarily in the months of January, April, July, and October. The qualified custodians of IFP generally will debit the fees on a periodic basis from the account as disclosed in the client’s Real Estate Advisory Services Agreement. IFP generally uses average daily balance, in arrears. OTHER COSTS AND EXPENSES IFP’s advisory fee is exclusive of all other fees, costs, and expenses associated with the acquisition, ownership, financing, operation, improvement, and disposition of real estate investments. Clients will bear all actual and direct costs and expenses incurred in connection with their real estate holdings, whether incurred directly by the client, through a client- controlled entity, or through a third-party operator, sponsor, or service provider. These costs and expenses will reduce the client’s overall investment return and may be incurred in addition to IFP’s advisory fee. Such costs and expenses may include, but are not limited to, the following: Acquisition and Transaction Expenses • Real estate brokerage commissions or finder’s fees • Legal fees related to transaction structuring, negotiation, and closing • Title insurance premiums, escrow or settlement fees, surveys, and recording fees • Transfer taxes and other governmental or regulatory charges • Due diligence expenses, including inspections, appraisals, environmental assessments, engineering reports, zoning reviews, and market studies [ 7 ]  Interest expense, loan servicing fees, reserve escrows, and administrative charges Financing and Leverage-Related Expenses • Loan origination, underwriting, commitment, and extension fees • Lender legal fees and third-party reports required by lenders • • Costs associated with refinancings, modifications, prepayment penalties, defeasance, or interest rate hedging arrangements Insurance premiums (including property, liability, flood, and casualty insurance) Insurance deductibles and self-insured retention amounts Ongoing Operating and Holding Expenses • Property management and leasing fees • Real estate taxes, special assessments, and governmental charges • • • Premium increases following claims • Specialty insurance (terrorism, cyber, builder’s risk, business interruption) • Utilities, repairs, maintenance, and common area expenses • Accounting, bookkeeping, audit, and tax preparation expenses related to property ownership Tenant, Leasing, and Vacancy-Related Costs • Tenant default, eviction, or workout-related legal costs • Lease restructuring, buyouts, or early termination payments • Vacancy carrying costs during lease-up periods Capital Expenditures and Improvement Costs • Tenant improvements, leasing incentives, and build-out costs • Capital repairs, renovations, redevelopment, and replacement reserves • Compliance-related upgrades, including environmental, safety, or accessibility requirements Administrative, Reporting, and Valuation Expenses • Costs associated with financial reporting and performance monitoring • Annual or periodic appraisals and valuation services • Entity-level expenses for client-controlled entities, including formation costs, annual filings, registered agent fees, and compliance expenses • Tax filing preparation and filing fees • Property tax appeals and consultant fees • Transfer, documentary, stamp, or gross receipts taxes • State or local business taxes applicable to operating entities Regulatory, Compliance, and Legal Risk Costs • Costs associated with regulatory compliance specific to the property (e.g., zoning variances, permitting, code enforcement actions) • Litigation-related expenses, including defense costs, settlements, or judgments related to property ownership or operations • Environmental remediation or monitoring costs, including ongoing compliance obligations or post-closing discovery issues Disposition and Exit-Related Expenses • Brokerage commissions and marketing costs • Legal and advisory fees related to sales, recapitalizations, or restructurings • Transfer taxes, recording fees, and closing costs upon disposition • Expenses related to 1031 like-kind exchanges, including qualified intermediary fees [ 8 ]  Capital Call and Liquidity Costs • Costs associated with capital calls, capital restructuring, or equity infusions • Short-term liquidity facilities or bridge financing costs • Fees related to guaranties, letters of credit, or credit enhancement Force Majeure and Extraordinary Event Costs • Disaster recovery and business continuity expenses • Costs related to pandemics, natural disasters, or governmental shutdowns • Emergency capital expenditures not otherwise budgeted Third-Party Operator, Sponsor, and Co-Investment Fees Clients may engage third-party real estate operators, sponsors, or operating partners pursuant to separate agreements. Such third parties may charge fees and expenses including, but not limited to: • Acquisition, origination, or sourcing fees • Asset management, property management, or development fees • Financing or refinancing fees • Construction or project management fees • Disposition fees • Performance-based compensation, including carried interest, promote, or incentive fees These third-party fees and expenses are separate from and in addition to IFP’s advisory fee and will reduce the client’s overall return. Clients should carefully review all agreements with third-party operators, sponsors, lenders, and service providers to fully understand the fees, expenses, and compensation arrangements applicable to their real estate investments. IFP does not receive, share in, or participate in any portion of the fees or compensation charged by third-party operators, sponsors, brokers, lenders, or service providers in connection with a client’s real estate investments. In addition, clients may incur other expenses related to regulatory compliance, legal proceedings, environmental matters, tenant defaults or vacancies, insurance claims or deductibles, tax structuring or appeals, technology and reporting systems, capital restructuring, extraordinary events, or other unforeseen circumstances arising from the ownership, financing, or operation of real estate. Such costs and expenses, whether anticipated or unanticipated, are borne solely by the client and are not included in IFP’s advisory fee. Product Fees Investments held in ancillary accounts, such as ETFs, private placements, and other investment products are subject to various other fees that are paid by those portfolios, but ultimately are borne by shareholders through lower returns than would likely be realized without those fees. These expenses may include investment advisory, administrative, distribution, transfer agent, custodial, legal, audit, and other customary fees related to investments in these investment vehicles. Additional information and product descriptions can be found in the prospectus for the applicable product. Conflicts and Incentives Asset-based fees create an incentive to increase assets under advisement. IFP mitigates this conflict through transparency, independent valuations, and non-discretionary decision-making. Because our fee is based on the valuation of the assets under advisement, we have an incentive to encourage clients to invest more in real estate and to maximize reported property values, which creates a potential conflict of interest. We mitigate this conflict in several ways: (1) clients are under no obligation to allocate any minimum amount to real estate; (2) advice is provided on a non-discretionary basis (for non-ancillary account assets) and clients make all final investment decisions; (3) when a readily observable market price or sponsor-provided valuation is not available, we engage independent third-party appraisers to provide periodic property valuations, rather than valuing the properties internally, in order to establish an objective advisory fee base; and (4) our tiered fee schedule provides some fee break [ 9 ]  for larger asset totals, aligning with clients’ interest in efficient pricing. IFP’s compensation for this service is strictly the asset-based advisory fee described above – we do not receive any performance-based fees, commissions, or referral compensation in connection with client real estate investments. Under the FORE agreement, Ancillary Accounts are subject to a differentiated billing structure relative to Accounts governed by IFP’s Advisory Account Form. In practice, this results in Ancillary Accounts being assessed at a generally higher fee level, reflecting their distinct servicing framework and economic profile. _____________________________________________________________________________________________________________________ ITEM 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT IFP does not typically charge performance-based fees for Family Office Services. Any such arrangements would be disclosed and agreed to in writing. _____________________________________________________________________________________________________________________ ITEM 7. TYPES OF CLIENTS IFP’s real estate advisory services are offered to ultra-high-net-worth individuals and families, including family offices, given the substantial capital and long investment horizons required. In general, this service is appropriate for clients with a net worth in excess of $100 million who wish to allocate a significant portfolio ($20 million or more is recommended) to direct real estate holdings. We may also serve trusts or entities (LLCs, partnerships) established by such individuals for owning real estate. _____________________________________________________________________________________________________________________ ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Family Office Services emphasize fundamental and qualitative analysis for complex and illiquid assets, including direct real estate. STRATEGY AND ANALYSIS METHODS Family Office Services emphasize fundamental, qualitative, and quantitative analysis for complex and illiquid assets, including direct real estate investments held outside traditional brokerage custodians. Real estate strategies are tailored to each client’s objectives, which may include income generation, long-term capital appreciation, inflation protection, tax efficiency, and diversification within the client’s overall balance sheet. TYPES OF REAL ESTATE INVESTMENTS Depending on client objectives, risk tolerance, liquidity needs, and time horizon, IFP may advise on direct investments across a range of real estate property types and strategies, including, but not limited, to: Industrial, logistics, and warehouse properties • Core and core-plus properties • Value-add or opportunistic properties • • Office, retail, and mixed-use properties • Multifamily and residential rental properties • Specialty or alternative real estate assets (such as self-storage, hospitality, land, or other niche property types) Investments may be structured as direct wholly owned properties, fractional interests, joint ventures, or co-investments alongside third-party operators or sponsors, depending on the opportunity and client preferences. INVESTMENT STRATEGIES – ANCILLARY ACCOUNTS When implementing investment advice to a client for ancillary accounts, IFP typically employs the following investment strategies: • Long-Term Purchases - Securities held at least a year. • Short-Term Purchases - Securities sold within a year. • Trading - Buying or selling a security for a client’s account. [ 10 ]  • Short Sales - Borrowing securities in anticipation of a price decline and returning an equal number of securities at some future time. • Margin Transactions - Investor pays for part of the purchase and borrows the rest from a brokerage firm; for example, investor buys $5,000 worth of stock in a margin account by paying for $2,500 and borrowing $2,500 from a brokerage firm. A client cannot borrow stock from an IAR. • Option Writing - Including covered options, uncovered options or spreading strategies. Note: options are contracts giving the purchaser the right to buy or sell a security, such as stocks, at a fixed price within a specific period of time. • Strategic/Tactical Asset Allocation - Asset allocation is the combination of several different types of investments; typically, stocks, bonds and cash equivalents among various asset classes so a client’s investments are diversified. The objective of asset allocation is to develop an investment plan that will help the client, as an investor, reach his or her financial goals, while seeking to limit risks. • Strategic Timing - Strategic timing is designed to reduce risks in bear markets (when markets are decreasing in value). This is a trend-following strategy that involves holding total cash positions during bear markets and fully invested positions during bull markets. METHODS OF ANALYSIS IFP’s analysis of real estate investments generally includes a combination of financial modeling, market analysis, and qualitative review. This may include: • Review of historical and projected financial performance, including net operating income (NOI), cash flow, and capital expenditure assumptions • Discounted cash flow (DCF) analysis and sensitivity testing • Review of comparable sales, rental rates, and prevailing market capitalization rates • Assessment of local and regional market conditions, supply and demand dynamics, and macroeconomic trends • Evaluation of property-specific factors such as location, physical condition, tenant quality, lease structure, rollover schedules, and regulatory considerations • Review of the experience, alignment, and incentives of third-party operators, sponsors, or property managers, where applicable IFP may coordinate with or rely upon third-party professionals including, but not limited to, appraisers, engineers, environmental consultants, legal counsel, and tax advisors, as part of the due diligence and evaluation process. When managing ancillary accounts, IFP typically uses one or more of the following methods of analysis to formulate investment advice or manage a client’s account: • Charting: In this type of technical analysis, IFP reviews charts of market and security activity in an attempt to identify when the market is moving up or down and to predict how long the trend will last and when that trend might reverse. • Fundamental analysis: IFP evaluates economic and financial factors to determine if a security is underpriced, overpriced or fairly priced. Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. • Technical analysis: IFP analyzes past market movements and apply that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company. This presents a risk against the overall market to predict the price movement of the security. • Quantitative analysis: IFP uses mathematical models to obtain more accurate measurements of a company’s quantifiable data, such as the value of some share price or earnings per share and predict changes to that data. A risk in using quantitative analysis is that the models used will be based on assumptions that prove to be incorrect. • Qualitative Analysis: IFP evaluates non-quantifiable factors and attempt to predict changes to share price based on that data. [ 11 ]  • Cyclical: This method of analysis focuses on the investments sensitive to business cycles and whose performance is strongly tied to the overall economy. For example, cyclical companies tend to make products or provide services that are in lower demand during downturns in the economy and higher demand during upswings. Examples include the automobile, steel and the housing industries. The stock price of a cyclical company will often rise just before an economic upturn begins and fall just before a downturn begins. Investors in cyclical stocks try to make the largest gains by buying the stock at the bottom of a business cycle, just before a turnaround begins. • Asset allocation: IFP attempts to identify an appropriate ratio of asset classes that are consistent with the client’s investment objectives and risk tolerance. USE OF LEVERAGE Many real estate investments involve the use of debt financing. Leverage may be employed to enhance returns, manage capital efficiency, or facilitate portfolio construction; however, the use of leverage also increases risk. In advising clients, IFP considers factors such as loan-to-value ratios, debt service coverage, interest rate structure (fixed versus floating), maturity profiles, refinancing risk, and the potential impact of leverage under adverse market conditions. The appropriate use of leverage varies by property type, investment strategy, and market environment. While leverage may magnify gains, it can also magnify losses and increase the risk of foreclosure or capital impairment. Clients retain full discretion over whether and how leverage is utilized in connection with any real estate investment. INVESTMENT HORIZON AND ASSET MANAGEMENT APPROACH Direct real estate investments are generally considered long-term and illiquid in nature. The strategy typically emphasizes buy-and-hold ownership with active asset management to seek to enhance value over time through leasing, operational improvements, capital investments, or strategic repositioning. Real estate investments are not intended to be traded frequently and may require extended holding periods before liquidity events such as refinancing or sale occur. NON-DISCRETIONARY IMPLEMENTATION All real estate investment recommendations are non-discretionary – we present opportunities and our analysis to the client, and the client makes the ultimate investment decision. We do not have authority to purchase or sell properties without client approval. RISK OF LOSS – REAL ESTATE Investments in direct real estate involve significant risks, including the potential loss of principal. Real estate investments are illiquid, complex, and subject to factors beyond the client’s control. While IFP provides non-discretionary advisory services related to real estate investments, there can be no assurance that any investment objectives will be achieved. Market and Economic Risks: The value and performance of real estate investments are affected by general and local economic conditions, including changes in interest rates, inflation, employment levels, consumer demand, and capital market conditions. Adverse economic developments at the global, national, regional, or local level may reduce property values, rental income, or the availability of financing and may negatively impact the ability to refinance or sell a property on favorable terms. Illiquidity and Exit Risk: Direct real estate investments are inherently illiquid. Clients may be unable to sell or refinance a property at a desired time or price, or at all. Market conditions, lender requirements, or property-specific factors may delay or prevent a sale or refinancing, which may result in prolonged holding periods, delayed liquidity events, or realized losses. Valuation Risk: The valuation of direct real estate is inherently subjective and based on assumptions that may not be realized. Appraisals and other valuation methodologies rely on estimates regarding market conditions, the amount and timing of cash flows, capitalization rates, discount rates, and comparable transactions, which may differ from actual results. As a result, stated property values may not reflect the price that could be obtained in an actual sale, particularly during periods of market stress or limited transaction activity. Inaccurate or delayed valuations may affect investment decisions, reported performance, fee calculations, financing terms, or the timing and pricing of transactions. Leverage and Financing Risk: Many real estate investments involve the use of debt. Leverage may amplify gains but also magnifies losses and increases the risk of foreclosure. Financing may include variable interest rates, balloon payments, [ 12 ]  lender approval rights, restrictive covenants, or cash sweep provisions. Adverse changes in interest rates, property performance, or credit markets may impair a property’s ability to service debt or be refinanced. In stressed market conditions, financing may become unavailable or available only on less favorable terms, which could require additional capital contributions or result in the loss of a property. Operating and Tenant Risks: Operating results depend on the ability to attract and retain tenants at expected rental rates. Risks include tenant defaults, non-renewals, lease rollovers, tenant concentration, and increased vacancy. A property’s performance may also be adversely affected by the financial condition, creditworthiness, or business prospects of its tenants, including tenants operating in industries subject to cyclical or structural decline. Properties may require significant leasing concessions, tenant improvements, capital expenditures, or extended lease-up periods to maintain occupancy, which may reduce cash flow, delay distributions, or impair investment returns. Property Management and Execution Risk: The performance of real estate investments depends on effective property management and execution of the applicable business plan. Clients may rely on third-party property managers, operators, contractors, or joint venture partners whose performance may be suboptimal or inconsistent with expectations. Operational challenges, including cost overruns, construction delays, labor shortages, supply chain disruptions, inadequate maintenance, or failure to implement leasing or capital improvement plans, may adversely affect a property’s operating results, cash flow, or value. There can be no assurance that deficiencies in management or execution will be timely identified or successfully remedied. Joint Venture and Co-Ownership Risk: Some real estate investments may involve joint ventures, co-investments, or partial ownership interests. In such cases, clients may lack full control over management decisions, financing, capital expenditures, refinancing, or the timing and terms of a sale or other exit. Conflicts may arise among co-owners or operating partners due to differing investment objectives, time horizons, liquidity needs, or financial capacity. Such disagreements may delay or prevent actions that a client would otherwise prefer to take and may adversely affect investment performance or realizable value. Environmental and Regulatory Risk: Real estate investments are subject to complex and evolving zoning, land use, environmental, and building regulations at the federal, state, and local levels. Changes in zoning classifications, permitted uses, density restrictions, environmental standards, or development approvals may limit the current or future use of a property, delay or prevent redevelopment or expansion plans, increase compliance costs, or reduce property value. Environmental laws and regulations may impose liability for the investigation, remediation, or monitoring of hazardous or toxic substances, regardless of fault or prior ownership. Compliance obligations may arise from conditions that are not discovered during due diligence or that result from changes in regulatory standards over time. Future or retroactive legislative, regulatory, or judicial developments may impose additional restrictions, require costly modifications, or adversely affect the economic performance or marketability of a property. Insurance and Casualty Risk: Properties are subject to risks of loss from fire, flooding, hurricanes, earthquakes, severe weather, terrorism, or other catastrophic events. Insurance coverage may be unavailable, insufficient, subject to high deductibles, or increasingly costly. In the event of an uninsured or underinsured loss, or delays in insurance recovery, a property may suffer material damage, business interruption, or permanent impairment of value. Tax and Structuring Risk: The tax treatment of real estate investments is complex and subject to change. Property tax reassessments, changes in tax laws, regulations, or interpretations, or adverse tax determinations may reduce after- tax returns. For clients pursuing tax-deferred exchanges under Sections 1031 or 1033, strict timing and structural requirements apply, and there is no assurance that a transaction will qualify for tax deferral. Extraordinary and Systemic Risks: Extraordinary events, including pandemics, public health emergencies, geopolitical events, terrorism, natural disasters, or governmental actions, may disrupt economic activity, tenant operations, supply chains, labor availability, or capital markets. Such events may result in government restrictions, moratoria, emergency regulations, or changes in enforcement practices that adversely affect rent collection, leasing, evictions, development activities, or financing availability. These effects may be prolonged, unpredictable, and materially adverse to real estate values and cash flows. [ 13 ]  Concentration Risk: Clients may allocate a significant portion of their investable assets to one or more real estate properties, geographic regions, or property types. Such concentration increases exposure to localized economic, regulatory, environmental, or market-specific risks, and adverse developments affecting a single asset or market may have a disproportionate impact on the client’s overall portfolio. Liquidity Mismatch and Insufficient Capital Reserves: Direct real estate investments are illiquid and may not generate consistent, sufficient, or timely cash flows to meet a client’s liquidity needs. Property-level cash flows may fluctuate due to vacancies, tenant defaults, capital expenditures, debt service requirements, or unexpected operating expenses. As a result, cash distributions, if any, may be irregular, delayed, or suspended. In certain circumstances, properties may require additional capital contributions to fund operating shortfalls, leasing costs, capital improvements, debt obligations, or compliance requirements. If adequate reserves are not maintained, or if adverse conditions persist, clients may be required to contribute additional capital from other personal or portfolio assets. There can be no assurance that sufficient liquidity will be available when needed, or that additional capital contributions will be recoverable. Counterparty and Service Provider Risk: Real estate investments typically depend on third parties, including property managers, operating partners, tenants, lenders, contractors, insurers, and other service providers. The performance and financial condition of these parties are outside of IFP’s control. The failure, insolvency, misconduct, negligence, or underperformance of any such party may adversely affect a property’s operations, cash flow, financing arrangements, regulatory compliance, or value. In addition, errors, delays, fraud, or operational failures by third parties may result in increased expenses, disrupted operations, tenant dissatisfaction, legal disputes, uninsured losses, or delays in executing a property’s business plan. While clients may conduct diligence on and monitor third-party relationships, there can be no assurance that such parties will perform as expected or that losses resulting from their actions or omissions will be recoverable. Technology and Operational Systems Risk: Property operations, financial reporting, recordkeeping, and communications may rely on technology systems, data providers, and third-party platforms used by clients, property managers, operators, lenders, or service providers. Disruptions, cyber incidents, data breaches, system failures, or data inaccuracies may impair reporting accuracy, delay transactions, disrupt operations, or adversely affect decision-making related to real estate investments. In addition, reliance on third-party technology systems limits the ability to control or fully mitigate operational or cybersecurity risks, and there can be no assurance that such systems will remain secure, available, or accurate at all times. Government Action and Force Majeure Risk: Government actions at the federal, state, or local level—including changes in laws, regulations, moratoria, emergency orders, or enforcement practices—may restrict property operations, rent collection, development activities, leasing, or eviction remedies. Such actions may be implemented rapidly, may apply retroactively, and may remain in effect for extended or indeterminate periods. In addition, force majeure events beyond the control of property owners, including pandemics, natural disasters, labor disruptions, or geopolitical events, may materially disrupt operations, increase costs, reduce revenues, or adversely affect the financial performance and value of real estate investments. Custody and Safekeeping Risk: IFP does not take custody of client assets in connection with direct real estate advisory services. Clients hold title to real estate assets directly or through client-controlled entities, such as limited liability companies or trusts, and retain full authority over all investment and ownership decisions. Notwithstanding the foregoing, the safekeeping of real estate assets involves practical and operational risks. Title documents, ownership records, loan agreements, and other legal instruments may be maintained by third parties including, but not limited to, lenders, title companies, property managers, or legal counsel. Errors, delays, fraud, or failures by such third parties could impair ownership rights, delay transactions, or result in financial loss. In addition, property-level cash flows are typically held in operating accounts controlled by the client, a property manager, or a third-party operator. Clients are subject to the risk of loss arising from the misuse, misappropriation, insolvency, or operational failures of such third parties. While clients may implement controls, audits, or oversight procedures, there can be no assurance that such measures will prevent loss. The risks described above are not intended to be an exhaustive list of all potential risks associated with direct real estate [ 14 ]  investments. Additional risks and uncertainties, including risks specific to particular properties, markets, strategies, or structures, may arise. Investing in real estate involves a risk of loss, and clients should be prepared to bear such risks, including the possible loss of capital RISK OF LOSS – ANCILLARY ACCOUNTS Investing in securities involves a risk of loss that a client should be prepared to bear, including loss of the original principal. However, a client should be aware that past performance of any security is not necessarily indicative of future results. Therefore, clients should not assume that future performance of a specific investment or investment strategy will be profitable. IFP does not provide representation or guarantee that client goals will be achieved. Investing in securities involves risk of loss. Further, depending on the different types of investments, there are varying degrees of risk. There are several factors that impact the type and magnitude of risk, including market risk; product and issuer risk; interest-rate risk; call/redemption risk; reinvestment risk; counterparty credit risk; business risk; currency risk; political risk; legal risk; regulatory risk; solvency risk; etc. Clients should evaluate what their risk tolerance is in order to develop an investment strategy and/or financial plan that is appropriate in light of their investment objectives, time horizon, liquidity, cash flow needs, etc. The risks specified below are a partial list of risks but are intended to provide “inquiry notice” for the client to discuss all material risks more fully with his or her IAR. • MARKET RISK. Either the market, or the value of an individual company, goes down, resulting in a decrease in the value of client investments. This is often in reaction to tangible and intangible events and conditions. Political, economic and/or social conditions will sometimes trigger market events. This is referred to as systemic risk. • MARKET VOLATILITY: Future price movements are inevitable. While IFP seeks to effectively project the long-term value of investments, IFP may not be able to do so, and prices may change in both a material and negative way. • INVESTMENT ACTIVITIES: The performance of any investment is subject to incorrect and unforeseen, negative changes in value. Several factors may impact value such as economic, political, competitive, technological and other conditions (including acts of terrorism and war). The impacts may be more limited to a particular investment or may have a broader impact. The securities markets may be volatile, which may adversely affect IFP’s ability to achieve positive returns. • ACCURACY OF PUBLIC INFORMATION: IFP conducts research and collect information from various public sources, and there is a risk that those public sources may be wrong. IFP cannot assess the completeness or accuracy of such information. • VALUATION OF INVESTMENTS: While IFP endeavors to assess the proper values of investment, IFP’s assumptions and conclusions may be significantly different than the market valuation at any point in time. • MARKET OR INTEREST RATE RISK: The price of most fixed income securities tends to move in the opposite direction of the change in interest rates. If IFP sells a fixed income security before the maturity date, because of the inverse correlation between interest rates and price, an increase in interest rates would probably result in a loss of principal. • INFLATION RISK: Inflation risk results from the variation in the value of cash flows from a security due to inflation, which reduces the purchasing power of the cash flow. • 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. • PRODUCT-SPECIFIC RISKS • LIQUIDITY RISK: Investments may not be able to be readily converted into cash. This risk is much more pronounced with Alternative Investment such as Privately Placed Securities, Interval Funds, Structured Products, Thinly Traded/OTC securities and other complex securities. • EQUITY (STOCK) MARKET RISK: Common stocks are susceptible to fluctuations and to volatile increases/ decreases in value in relation to changes in confidence or market perceptions. Investors holding common stock (or common stock equivalents) of any issuer are generally exposed to greater risk than if they hold preferred stock or debt obligations of the issuer. [ 15 ]  • COMPANY RISK: There is always a certain level of company or industry specific risk when investing in stock positions. This is referred to as unsystematic risk and can be reduced through appropriate diversification. There is the risk that a company can perform poorly or that its value can be reduced based on factors specific to it or its industry (e.g., employee strike and unfavorable media attention). • OPTIONS RISK: • Options on securities are subject to greater fluctuations in value than investing in the underlying securities. Purchasing and writing put or call options are highly specialized activities and involve greater than ordinary investment risk. Puts and calls are the right to sell or buy a specified amount of an underlying asset at a set price within a set time. • Protective Options (Call Writing, Protective Puts, etc.) - Clients should understand they would have a tax obligation at year-end. • FIXED INCOME RISK • Investing in bonds involves the risk that the issuer will default on the bond and be unable to make payments. In addition, individuals depending on set amounts of periodically paid income face the risk that inflation will erode spending power. Fixed income investors receive set, regular payments that face the same inflation risk. INVESTMENT COMPANY, INSURANCE AND OTHER PUBLICLY REGISTERED POOLED FUNDS, GENERALLY Overall Fund Risk • Clients need to remember that past performance is no guarantee of future results. All funds carry some level of risk. Clients may lose some or all of the money they invest, including the principal because the securities held by a fund goes up and down in value. Dividend or interest payments may also fluctuate, or stop completely, as market conditions change. • Before clients invest, they should read a fund’s prospectus and shareholder reports to learn about its investment strategy and the potential risks. Funds with higher rates of return may take risks that are beyond their comfort level and are inconsistent with their financial goals. While past performance does not necessarily predict future returns, it can tell you how volatile (or stable) a fund has been over a period of time. Generally, the more volatile a fund, the higher the investment risk. If clients need their money to meet a financial goal in the near-term, they probably can’t afford the risk of investing in a fund with a volatile history because they will not have enough time to “ride out” any declines in the stock market. ETF And Mutual Fund Risk • Exchange traded fund (“ETF”) and mutual fund investments bear additional expenses based on a pro rata share of operating expenses, including potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities held by the ETF or mutual fund. Clients also incur brokerage costs when purchasing ETFs. Mutual Funds Risk Mutual funds can offer the advantages of diversification and professional management. However, as with other investment choices, investing in mutual funds involves risk and fees and taxes that will diminish a fund’s returns. Mutual funds also have features that are disadvantageous, such as: • Costs despite Negative Returns: Clients must pay sales charges, annual fees, and other expenses) regardless of how the fund performs. And, depending on the timing of their investment, clients may also have to pay taxes on any capital gains distribution they receive— even if the fund proceeded to perform poorly after they bought shares. Such distribution can occur even if the distribution remains in the accounts and is not actually physically distributed to the client. • Lack of Control: Investors typically cannot ascertain the exact composition of a fund’s portfolio at any given time, nor can they directly influence which securities the fund manager buys and sells or the timing of those trades. • Price Uncertainty: with an individual stock, clients can obtain real-time (or close to real-time) pricing information with relative ease by checking financial websites or by calling their IAR. Clients can also monitor how a stock’s price [ 16 ]  changes from hour to hour. But with a mutual fund, the price a client purchases or redeem shares for will typically depend on the fund’s net asset value (“NAV”), which is generally an end-of-day price, which the fund might not calculate until many hours after the client has placed the order. In general, mutual funds must calculate their NAV at least once every business day, typically after the major U.S. exchanges close. The following is a list of some general risks associated with investing in mutual funds: • Country Risk: The possibility that political events (e.g., war, national elections, etc.), financial problems (rising inflation; government default), or natural disasters (an earthquake; a poor harvest) will weaken a country’s economy and cause investments in that country to decline. • Currency Risk: The possibility that returns could be reduced for Americans investing in foreign securities because of • • • a rise in the value of the U.S. dollar against foreign currencies (also called exchange-rate risk). Income Risk: The possibility that a fixed-income fund’s dividends will decline as a result of falling overall interest rates. Industry Risk: The possibility that a group of stocks in a single industry will decline in price due to developments in that industry. Inflation Risk: The possibility that increases in the cost of living will reduce or eliminate a fund’s real inflation- adjusted returns. • Manager Risk: The possibility that an actively managed mutual fund’s Investment Adviser will fail to execute the fund’s investment strategy effectively, resulting in the failure of stated objectives. • Market Risk: The possibility that stock fund or bond fund prices overall will decline over short or even extended periods. Stock and bond markets tend to move in cycles, with periods when prices rise and other periods when prices fall. • Principal Risk: The possibility that an investment will go down in value, or “lose money,” from the original or invested amount. Bond Fund Risk Bond funds generally have higher risks than money market funds, largely because they typically pursue strategies aimed at producing higher yields than the risks associated with money market funds. Risks include: • Call Risk: The possibility that falling interest rates will cause a bond issuer to redeem—or call—its high-yielding bond before the bond’s maturity date. • • Credit Risk: The possibility that companies or other issuers whose bonds are owned by the fund may fail to pay their debts (including the debt owed to holders of their bonds). Credit risk, however, is less of a factor for bond funds that invest in insured bonds or U.S. Treasury bonds. By contrast, those funds that invest in the bonds of companies with poor credit ratings generally will be subject to higher risk. Interest Rate Risk: The risk that the market value of the bonds will go down when interest rates go up. Because of this, clients can lose money in any bond fund, including those that invest only in insured bonds or Treasury bonds. • Prepayment Risk: The chance that a bond will be paid off early. For example, if interest rates fall, a bond issuer may decide to pay off (or “retire”) its debt and issue new bonds that pay a lower rate. When this happens, the fund may not be able to reinvest the proceeds in an investment with as high a return or yield. Fixed Income Call Option Risk Many fixed income securities can be “called” or retired by the issuer. That creates a risk of negatively impacting the projected cash flow, reducing capital appreciation potential and increasing reinvestment risk due to the lower interest rates then being experienced. Stock Fund Risk Although a stock fund’s value can rise and fall quickly over the short-term, historically stocks have performed better over the long-term than other types of investments — including corporate bonds, government bonds and treasury securities. Overall, “market risk” poses the greatest potential danger for investors in stocks funds. Stock prices can fluctuate for a broad variety of reasons, such as the overall strength of the economy or demand for particular products or services. [ 17 ]  Not all stock funds are the same. For example: • Growth funds focus on stocks that may not pay a regular dividend but have the potential for large capital gains. • • Income funds invest in stocks that pay regular dividends. Index funds aim to achieve the same return as a particular market index, such as the S&P 500 Composite Stock Price Index, by investing in all — or perhaps a representative sample — of the companies included in an index. • Sector funds may specialize in a particular industry segment, such as technology or consumer products stocks. Management Risk Clients’ investments also vary with the success and failure of IFP’s investment strategies, research, analysis and determination of portfolio securities. If any particular product’s/issuer’s portfolio manager is ineffective or sub-optimal, the performance of the instrument/investment will not produce the expected returns and the value of the investments will decrease. Insurance Securities Risk The rate of return on variable insurance products is not stable, but varies with the stock, bond and money market subaccounts that clients choose as investment options. There is no guarantee that clients will earn any return on their investment and there is a risk that they will lose money. Before clients consider purchasing a variable product, they should make sure they fully understand all of its terms. Carefully read the prospectus. Some of the major risks include: Liquidity and Early Withdrawal Risk: There may be surrender charges for withdrawals within a specified period, which can be as long as six to eight years (and up to 15 years for Equity Indexes Annuities). Any withdrawals before a client reaches the age of 59 ½ are generally subject to a 10 percent income tax penalty in addition to any gain being taxed as ordinary income. Sales and Surrender Charges: Asset-based sales charges or surrender charges exist but normally decline and eventually are eliminated the longer clients hold their shares. For example, a surrender charge could start at 7 percent in the first year and decline by 1 percent per year until it reaches zero. That is one reason why variable insurance products are generally not suitable for short-term time horizons Fees and Expenses – There are a variety of fees and expenses that can reach 2% and more such as: • Mortality and expense risk charges; • Administrative fees; • Underlying fund expenses; and • Charges for any special features or riders. Bonus Credits: Some products offer bonus credits that can add a specified percentage to the amount invested ranging from 1 percent to 5 percent for each premium payment. Bonus credits, however, are usually not free. To fund them, insurance companies typically impose high mortality and expense charges and lengthy surrender charge periods. Guarantees: Insurance companies provide a number of specific guarantees. For example, they may guarantee a death benefit or an annuity payout option that can provide income for life. These guarantees are only as good as the insurance company that offers them. Market Risk: The possibility exists that stock fund or bond fund prices overall will decline over short or even extended periods. Stock and bond markets tend to move in cycles, with periods when prices rise and other periods when prices fall. Principal Risk: The possibility that an investment will go down in value, or “lose money,” from the original or invested amount. This risk may entail a partial or complete loss of principal. Private Placements These investments have a high degree of risk. It is possible for clients to experience total loss or a substantial loss of investment. In the absence of a public market for these securities, there is lack of liquidity and an expected investment time horizon usually in excess of five years. There are no guarantees that they will receive a distribution and payments of distributions will decrease or diminish their interest. [ 18 ]  Such products are generally speculative investments, which means they have a very high risk, and should therefore not be a product used by investors who have a more moderate risk tolerance in the same account. However, it is conceivable, if the customer consents and agrees with a different investment objective (via, e.g., a Subscription Agreement) for certain investments than the investment objective generally agreed upon in the Investor Policy Statement or the suitability information contained in the account application, then investments that represent a very small percentage of the overall portfolio could be used in a limited fashion, provided they are only used a non-discretionary basis, and such riskier investments are assigned to a separate account that reflects that investment objective. An application-way subscription in private placements, even if linked to the custodian/Pershing platform for networking purposes, should suffice for the purpose of determining separate account status. Investing in alternative investments are not suitable for all clients, and are intended for experienced and sophisticated investors who are willing to bear the high economic risks of the investment, which can include: • Loss of all or a substantial portion of the investment due to leveraging, short-selling or other speculative investment practices; • Lack of a business plan to results in value creation or that is not implemented as intended, which are considered greater in risk than for established companies; • Lack of liquidity in that there may be no secondary market for the securities and none is expected to develop; • Volatility of returns; • Restrictions on selling/transferring the securities (no market permitted unless or until registered); • Absence of information regarding valuations and pricing; • Delays in tax reporting; and • Less regulation and higher fees than mutual funds. IFP disallows IARs to exercise discretion over private placements. IARs may advise on such investments but may not engage in the transaction without client application/subscription. Other Alternative Investments Alternative Investments (“Alts”) refer to a broad category of non-traditional investment assets that may include, but are not limited to, private equity, hedge funds, real estate, private credit, venture capital, commodities, and structured products. These investments often differ from traditional asset classes such as stocks, bonds, or mutual funds in terms of structure, liquidity, valuation, and regulatory oversight. Alternative Investments may be subject to unique and substantial risks including, but not limited to, illiquidity, lack of transparency, limited performance history, use of leverage, valuation complexity, higher fees, and potential for loss of principal. They may also be less regulated than public markets, resulting in different investor protections. Clients should understand that Alternative Investments may not be suitable for all investors and should be evaluated in light of their overall investment objectives, risk tolerance, and time horizon. IFP may recommend or facilitate access to such investments only where appropriate, and clients should review all offering documents and disclosures carefully before investing. Structured Product Risk • An investor in a structured product never has a claim on the underlying investment, whether a security, zero coupon bond, or option. This could cause little or no secondary market for the securities and information regarding independent market pricing for the securities will be limited. Some of the associated risks include: • Structured products are complex investments that are not suitable for all investors. Structured products are unsecured obligations of the issuer that pay a return based on an underlying asset. • Structured products are the obligation of the issuer and the ability to provide a return is based on the credit worthiness of the issuer. This means that there is credit risk with the product and it may provide no returns, including total loss of principal if the issuer is not able to pay its obligations. • Any principal protection (whether full or partial) stated in the prospectus is based solely on the credit worthiness of the issuer and only if held to maturity. • Call or “Knock In” risks exists if the product is called away/redeemed. • Structured products may have limited or no trading on secondary markets. This means the position may have to be held until maturity. If there is a market for the structured product it is likely the product would have to be sold for [ 19 ]  lower than the principal amount invested. • The underlying asset or index may be proprietary to the issuer. This adds a layer of complexity as clients must understand how the index works to understand how returns will be calculated. • Tax treatment on certain structured products may not be the same as more traditional investments. Clients may have to pay income tax on increases even if no payment is received, this is typically referred to as “phantom income”. Clients should consult with their personal tax advisor regarding taxation of structured products. • Certain structured products provide FDIC insurance. This FDIC insurance is only applicable to the principal amount invested and not to any gains or income payments. This insurance is available up to the applicable federal amount. It does not protect against negative performance of the asset. It will only apply in the case of insolvency according to the process and procedures of the Federal Deposit Insurance Corporation. More information can be found on https://www.fdic.gov/. • Certain structured products will have a call feature, allowing the issuer to “call” the investment back from the investor. The terms of any call feature should be fully understood and can be found in the prospectus. • Early termination provisions can be found in the prospectus if they apply. These features allow the issuer to end the investment early under specified circumstances. This usually will lead to a lower payout than what would be received at maturity or in the case of a call provision. Interval Funds Interval funds are alternative investments that make periodic repurchase offers to shareholders according to a schedule set by the fund. Interval funds are not traded on an exchange and differ from mutual funds and other publicly traded funds, including by providing far less liquidity. There are special risks associated with interval funds, including: • Shares of the Interval Fund are unlikely to be listed on a public exchange; • No secondary market is expected to develop for the Interval Fund’s shares • Liquidity for the Interval Fund’s shares will be provided only through periodic offers by the Interval Fund (e.g., quarterly repurchase offers); • There is no guarantee that an investor will be able to sell all the shares that the investor desires to sell in the repurchase offer; Investing in the Interval Fund’s shares may be speculative and involves a high degree of risk; and • An investor should consider an investment in the Interval Fund to be of limited liquidity; • • As with all securities, an investor should carefully read the Prospectus prior to investing, which, in the case of Interval Funds, may include particular and significant risks related to leverage. Investments in Non-US Securities From time to time, IFP may invest and trade a portion of its assets into non-U.S. securities and other assets, which will give rise to risks relating to political, social, legal, currency, regulatory and economic developments abroad. Different laws, regulations and market practices may also increase the risk. Miscellaneous Risks There are too many risks to enumerate specifically. Thus, the foregoing risks do not purport to be a complete compendium of the risks of any particular investment; they are general risks that should guide the initial evaluation of any prospective investment. Clients and prospective clients are encouraged to read the prospectus and offering documents, as applicable, for any prospective and current investment, and discuss them with their IAR vis-à- vis their investment objectives, risk tolerance, liquidity needs, investment time horizon, risk/reward preferences, capital reserves, etc. _____________________________________________________________________________________________________________________ ITEM 9. DISCIPLINARY INFORMATION IFP is required to disclose disciplinary actions against the firm. The detailed information for the actions below can also be found on IFP’s Form ADV Part 1 on the SEC’s website at www.sec.gov. IFP discloses the following disciplinary information: [ 20 ]  1. On January 13, of 2012, IFP agreed to and signed a Stipulation and Consent Order with the State of Florida Office of Financial Regulation that IFP and two of its IARs engaged in investment advisory business in the state of Florida without being properly registered. IFP paid a $20,000 fine and paid $10,000 fines on behalf of each IAR. 2. On October 7, 2013, IFP agreed to and paid an Administrative Penalty in the amount of $2,500 to the State of California, Department of Business Oversight for failing to properly register an IAR in the State of California. 3. On December 3, 2013, IFP agreed to and signed a Cease-and-Desist Order with the State of Oregon, Department of Consumer and Business Services, Division of Finance and Corporate Securities for failing to properly license an IAR who had a place of business in the state of Oregon. IFP paid a $3,600 fine. 4. On August 10, 2022 IFP agreed to and signed a cease and desist order from the Securities and Exchange Commission in relation to a cherry-picking scheme from a formerly employed adviser in California. The order prevents IFP from committing or causing any violations and any future violations of Advisers Act Sections 206(2) and 206(4) and Rule 206(4)-7 promulgated thereunder. IFP paid a civil money penalty in the amount of $400,000 to the Securities and Exchange Commission. _____________________________________________________________________________________________________________________ ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS AFFILIATION WITH IFP SECURITIES IFP is under common ownership with a registered broker-dealer, IFP Securities, LLC. IFP Securities, LLC and IFP Advisors, LLC are owned by IFP Group, LLC. In other words, IFP’s direct, majority owner is IFP Group, LLC, and indirect owner, through IFP Group, is WKW Enterprises. IAR’s acting in their separate capacities as Registered Representatives of IFP Securities, LLC, sell, for commissions, general securities products including but not limited to stocks, bonds, mutual funds, exchange-traded funds, alternative investments, variable annuity and variable life products to clients. As such, IARs have the availability to suggest that clients implement investment advice by purchasing securities products through a commission-based IFP account in addition to an advisory account. Such dual compensation is against IFP policy. Nevertheless, in the event that clients elect to purchase commission-based products through IFP Securities, LLC., IFP and a client’s IAR, in the capacity as IFP Registered Representatives, will receive the normal and customary commission compensation in connection with the specific product purchased. This presents a conflict of interest, as it gives the IAR an incentive to recommend investment products on the compensation received, rather than on the client’s needs. Clients are free to implement investment advice through any broker-dealer or product sponsor they select. However, clients should understand that, due to certain regulatory constraints, their IAR must place all purchases and sales of securities products in commission-based brokerage accounts through IFP Securities, LLC or other IFP approved institutions (qualified custodians/clearing firms). IFP strives to ensure that such brokerage accounts for investment advisory clients do not have commission-based products in them. If a client’s account is charged an AUM fee, IFP policy requires IARs ensure that a commission is not also charged, which means any products that might otherwise have an embedded commission should be structured as an adviser-class product, and equities and other listed products should only be assessed a transaction (“ticket”, unless a Wrap Fee structure applies) fee.1 For accounts managed by IFP and held and custodied at Pershing, IFP’s affiliated broker-dealer, IFP Securities, LLC, will act as the introducing broker for transactions in these accounts and will be paid a ticket charge for each transaction out of a client’s non-wrap accounts. IFP Securities, LLC essentially pays a portion of each ticket charge to the clearing firm, Pershing, and keeps the remaining portion of the ticket charge paid by the client. Although this retained revenue from the ticket charge is not retained by the IAR servicing the client’s account, this is a conflict of interest for IFP because of the additional compensation. AFFILIATION WITH IFP INSURANCE GROUP IFP is under common ownership with IFP Insurance Group, LLC (IFP Insurance Group), a licensed insurance agency. IFP and IFP Insurance Group are owned by IFP Group, LLC. Some IAR’s are licensed life insurance agents with IFP Insurance Group and sell insurance products to clients. Therefore, the IAR, in the capacity as a licensed life agent, is 1A possible “aging” analysis may occur for securities assets originally purchased when the account was not under an investment advisory arrangement, as otherwise described herein, which would be, in any case, subject to a Regulation Best Interest analysis. [ 21 ]  able to implement insurance recommendations for clients when electing to receive this service. In this event, IARs, in their separate capacities as licensed insurance agents, will receive separate and typical commission compensation for insurance and/or annuity sales.2 This presents a conflict of interest, as it gives a client’s IAR an incentive to recommend investment products on the compensation received, rather than on the client’s needs OTHER OUTSIDE BUSINESS ACTIVITIES Certain IARs have other business activities and offer other professional services, such as tax preparation, accounting, legal, real estate, employee benefits consulting, business advisory services (e.g., succession and exit planning) or have other businesses, that are outside business activities from their registration as an IAR of IFP. Aside from conducting an initial conflicts-of-interest check, such services are outside the scope of IFP’s business, and the IARs with such outside business activities are fully responsible for them since they are not activities provided by IFP. IARs engaging in these other outside business activities do so independently of their registration with IFP. _____________________________________________________________________________________________________________________ ITEM 11. CODE OF ETHICS, PARTICIPATION IN CLIENT TRANSACTIONS AND PERSONAL TRADING CODE OF ETHICS An investment adviser is considered a fiduciary as defined under the Investment Advisers Act of 1940, as amended. As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act in the Best Interest of each of IFP’s clients. IFP, its employees, and its IARs have a fiduciary duty to all advisory clients. To assist IFP employees and IARs in meeting these obligations, IFP has adopted standards of business conduct that are outlined in the Code of Ethics. IFP requires its supervised persons to conduct business with integrity and to comply with federal and state securities laws. IFP has established a Code of Ethics which IARs and those people defined as Access Persons will read and then execute an acknowledgment stating that they understand and agree to comply with IFP’s Code of Ethics. The Code of Ethics addresses matters such as the prohibition against trading on the basis is non-public information, Conflicts of Interest, Personal Securities transactions, etc. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS IARs have the availability to recommend to investment current or prospective clients the purchase or sale of securities in which IFP, its affiliates, the IAR and/or other clients also have a position or interest. Because the Code of Ethics in some circumstances would permit Employees, IARs and affiliated accounts to invest in the same securities as the client, there is a possibility that employees, IARs or affiliated accounts might benefit from market activity in their accounts with a security also held by the client.3 Therefore, a conflict of interest exists when IFP and its 2For variable insurance/annuity products, the general policy prohibition against dual compensation applies. 3IFP has a Restricted Period applicable to its IARs. Accordingly, the current general policy prohibits any IAR (and other individuals in scope such as spouses, children and financial dependents) from trading during the period of 3 days prior to a client order, and through the period of 3 days after the respective client order. As some background for the Restricted Period is the fact that there are difficulties operationally and from a supervisory perspective to ensure that IARs do not receive a better price than customers as more fully explained below. IARs may not trade in the same day as the client in securities (unless mutual funds and certain other securities exempted within the industry standards applicable to Codes of Ethics regulations governing investment advisers). In the case of block transactions, the IAR must ensure that he/she places the client’s execution price as “preferenced” over the execution price of the IAR. In that way, the IAR may receive an equal price as clients if all clients whose orders were handled by IFP’s advisory clearing platform providers (Fidelity, Schwab, and Pershing/Pershing Advisory Services/PAS), provided all such orders for entire day get filled as the average daily price, or the IAR price is worse than all IFP clients for the entire day. IFP understands each of its advisory clearing platforms provides aggregated and allocated orders with each block at average daily price, so there should generally not be a possibility to receive a better price than a client with the same block trade assuming there are no “partial fills” or the existence of multiple block transactions. However, there is a challenge if there are multiple block orders that occur during the same day. This means that if multiple block orders occur within 1 day, the IAR is obligated to consider the execution price of all such client block orders, and the IAR may receive no better price than all clients who received an order execution on a particular day. Considering the difficulties in ensuring such price preference to all clients, amongst the possibility of multiple block orders, the possibility of “partial fills and the ability for IAR to provide allocation instructions directly to certain Qualified Custodians/clearing firms, as well as the possibility disparate prices may exist from one block to another, and one partial block price to another, IFP’s policy prohibits IARs from placing their orders same day as a client. The only possible exception would be if IFP/IAR can demonstrate that the foregoing price assurance/leveling occurs. Such exceptions to the general policy of disallowing IAR to input their own orders in the same block with clients would require advance approval/clearance by a registered principal of IFP (Transaction Supervision Team), and if cleared, then IFP and the IAR must ensure after the executions for the entire day, the IAR receives no better price than all client on the respective day for the same respective securities and comparable preferenced prices related to its derivatives. The [ 22 ]  IARs purchase and sell the same securities owned by the client. Trading activity of IARs and employees is reviewed and monitored under the Code of Ethics to help reasonably prevent this conflict of interest in trading between IFP and its clients. IFP and its IARs have the availability to maintain investment positions in their personal portfolios that are recommended to clients. In fact, IFP and its IARs have the choice to take positions or execute transactions for their personal accounts which are materially different than the positions or transactions recommended for clients. Employees and IARs are expected to purchase or sell a security for their personal accounts only after trading of that same security has been executed in customer accounts, trade on a different day than executing trades for a client account or aggregate trading system that applies the average price across all trades aggregated. Clients and prospective clients can request a copy of IFP’s Code of Ethics by contacting the firm at the address noted on the cover of this brochure. Clients and prospective clients may also find a copy of the Code of Ethics on the Web Site at https://ifpartners.com/wp-content/uploads/2023/03/Code-of-Ethics.pdf. _____________________________________________________________________________________________________________________ ITEM 12. BROKERAGE PRACTICES IFP’s direct real estate advisory services relate to real estate assets held outside traditional brokerage custodians and do not involve the execution of securities transactions, the selection of broker-dealers, trade aggregation, or trade allocation. While clients may engage real estate brokers, agents, or intermediaries in connection with property acquisitions or dispositions, such engagements are client-directed, occur pursuant to separate agreements, and are not subject to securities brokerage practices or best execution standards under the Investment Advisers Act. USE OF DESIGNATED OPERATING PARTNER As part of IFP’s direct real estate advisory services, clients access certain real estate investment opportunities through a designated third-party operating partner, currently including Time Equities, Inc. and/or The Becker Organization (each, an “Operating Partner”). The Operating Partner is responsible for sourcing, acquiring, managing, and disposing of the applicable real estate investments pursuant to a separate agreement between the client (or the client’s investment vehicle) and the Operating Partner. While clients are required to utilize a designated Operating Partner for purposes of this service, clients retain full discretion to select their own real estate brokers, lenders, title and escrow agents, property managers, legal counsel, accountants, and other third-party service providers in connection with any transaction or property. The use of a designated Operating Partner limits the client’s ability to engage alternative operators and may reduce the client’s ability to negotiate fees or terms with other providers. This arrangement creates a potential conflict of interest because IFP has an incentive to recommend or utilize Operating Partners that facilitate consistent underwriting standards, operational efficiency, and reporting. IFP addresses this conflict through disclosure and by providing advisory services on a non-discretionary basis, with clients retaining final decision-making authority. The Operating Partner may charge fees and expenses, including acquisition fees, asset or property management fees, financing or refinancing fees, construction or development management fees, disposition fees, and performance-based compensation (such as a promote or carried interest), pursuant to separate agreements. These fees are in addition to IFP’s advisory fee and will reduce the client’s overall investment returns. IFP does not receive commissions, referral fees, or other transaction-based compensation from the Operating Partner in connection with these investments. Neither Operating Partner is an affiliate of IFP, and IFP does not control the operations or decision-making of the Operating Partner. IFP periodically reviews its designated Operating Partners based on factors such as experience, financial condition, execution capabilities, and reporting practices; however, there can be no assurance that any Operating Partner will perform as expected other condition for placing orders in this way is that the IAR does have any non-public information. [ 23 ]  CLIENT SELECTION OF OTHER SERVICE PROVIDERS Except with respect to the designated operating partner, clients retain full discretion to select and engage all other third- party service providers in connection with their real estate investments. Such providers may include, without limitation, real estate brokers, lenders, title and escrow agents, property managers, legal and tax advisors, appraisers, engineers, environmental consultants, and contractors. These third parties are engaged pursuant to separate agreements between the client (or the client’s investment vehicle) and the applicable provider. IFP does not act as a broker, lender, escrow agent, or property manager, does not control the services provided by such third parties, and does not receive commissions, referral fees, or other transaction-based compensation in connection with their engagement. While IFP may assist clients in evaluating or coordinating with third-party service providers at the client’s request, IFP does not guarantee the performance, pricing, or outcomes of any third-party services. IFP’s role with respect to third-party service providers is advisory only, and clients retain final authority over the selection of providers and the approval of transaction terms. NO REFERRAL COMPENSATION OR FEE SHARING IFP does not receive commissions, referral fees, rebates, revenue sharing, or other transaction-based compensation in connection with the selection or engagement of any real estate broker, lender, title or escrow provider, inspector, appraiser, engineer, environmental consultant, property manager, operating partner, or other third-party engaged by a client. Any fees or expenses charged by third-party service providers are determined pursuant to separate agreements between the client and the applicable provider and are in addition to IFP’s advisory fee. Such third-party fees and expenses will reduce the client’s overall investment returns. ADVISORY ROLE IN PROVIDER SELECTION AND TRANSACTION TERMS When assisting clients in evaluating third-party service providers or transaction terms, IFP’s role is advisory only. Clients retain final authority over the selection of service providers and the approval of transaction terms, including pricing, fees, financing arrangements, and contractual provisions. IFP does not guarantee that clients will obtain the lowest fees, most favorable pricing, or best available terms in any particular transaction, and does not control the services provided by third parties. CONFLICTS OF INTEREST RELATED TO PROVIDER SELECTION AND ASSET VALUATION IFP’s advisory fee is generally based on the value of real estate assets under advisement, which creates a potential conflict of interest because IFP has an incentive to recommend or support transactions, asset valuations, or structures that increase the advisory fee base. In addition, IFP’s involvement in evaluating or coordinating with third-party service providers may create a perceived conflict of interest if such involvement facilitates implementation efficiency or administrative consistency. IFP seeks to mitigate these conflicts by providing advice on a non-discretionary basis, disclosing all material conflicts of interest, using independent third-party appraisals or valuation sources where appropriate, having fee break points, and requiring that clients retain ultimate decision-making authority with respect to all investments, service provider selections, and transaction terms. ACCOUNTS ESTABLISHED THROUGH IFP SECURITIES, LLC If clients wish to implement their IAR’s advice they are free to select any broker they wish. If they wish to have the IAR implement the advice in their capacity as a RR, then IFP’s affiliated broker-dealer, IFP Securities, LLC, will provide brokerage services for the accounts held at Pershing, LLC. Clients do not generally have the option to direct securities brokerage transactions to other broker-dealers or other account custodians. Likewise, transaction execution decisions for IFP’s Qualified Custodians are determined by such custodians. If a TPAM is afforded discretion over a client’s account, they may exercise brokerage execution/routing decisions. In any cases, such decisions are subject to the duty to seek “Best Execution.” IFP IARs are RRs of IFP Securities and are required to use the services of IFP Securities when [ 24 ]  acting in their capacity as RR. IFP Securities has a wide range of approved securities products for which it performs due diligence prior to selection. For non-listed products, IFP Securities RRs are required to only use products approved by IFP Securities. Otherwise, most listed securities are presumed to be approved by IFP Securities, unless they fall into certain special categories, which are covered by IFP’s Restricted List, IFP policy and, in the case of brokerage accounts “held/carried by” Pershing, IFP’s Membership Agreement with FINRA. Commissions charged for the securities products can be higher or lower than commissions clients can obtain if transactions were implemented through another broker- dealer. In accounts where IFP Securities acts as broker-dealer for transactions, IFP Securities or its Client will pay a ticket charge and/or commission for each transaction. IFP Securities and Pershing may split the ticket charge to the clearing firm, Pershing LLC, and keep the remaining portion of the ticket charge. IFP Securities also marks up certain other brokerage-related charges and fees that are assessed to all client advisory accounts at Pershing. The charges and fees that are marked up include, but are not limited to, paper delivery surcharge, fees for client statement and confirmation, clearance and execution fees, outgoing account transfer fees, mandatory reorganization fees, checking account fees, inactive account fees, wire fees, legal transfer fees, bond redemption fees, termination fees, and IRA annual custodial maintenance fees. IFP participates in Pershing’s FUNDVEST® ticket charge program. This program offers no-load mutual funds to be purchased for clients with no transaction fees. IARs who absorb ticket charges or utilize asset-based pricing with clients have access to utilize these NTF Funds. Clients can choose to participate in Pershing’s Loan Advance program. In this program, Pershing will qualify a client who would benefit from having an alternative for accessing credit for financial needs in the form of a non-purpose loan. IFP receives revenue for client participation in this program. Even though these payments are not shared with a client’s IAR, the receipt of these additional payments creates a conflict of interest because of the increased compensation to IFP. Clients can choose to loan securities to Pershing by participating in the Fully Paid Lending Program. Clients will maintain full ownership of the securities on loan and can recall the loan at any time. Clients will relinquish their right to exercise voting rights while securities are on loan. Loaned securities will not have SIPC coverage. However, SIPC coverage applies to the cash collateral received for the loaned securities. Clients receive a lending fee based on the relative value of the securities loaned and are subject to change. IFP receives revenue from these fees and even though these payments are not shared with a client’s IAR, the receipt of these additional payments creates a conflict of interest because of the increased compensation to IFP. When clients establish an account through Pershing, they are required to select a bank sweep option or money market mutual fund in which the cash in their account will be held. The FDIC bank deposit sweep program is the default option for cash contributed to non-entity (individual) accounts and IFP receives more from Pershing for assets held in that sweep program than IFP does for assets placed into a money market fund. Entities are not eligible to participate in the bank deposit sweep program. The bank sweep account will have a yield that will vary based on prevailing interest rates. IFP has the ability to dictate what portion of the yield (interest rate paid) on the bank sweep accounts it will retain. IFP’s ability to adjust the yield creates a conflict of interest since the lower the portion of the yield paid to clients, the more IFP earns. IARs do not receive any portion of the bank sweep compensation paid to IFP. In addition to a bank sweep deposit option, IFP makes available a limited number of money market funds that clients have the choice to elect to have serve as the cash sweep vehicle for their brokerage account. Pursuant to IFP’s clearing agreement with Pershing, Pershing remits to IFP the amount of 12b-1 fees and shareholding servicing fees for money market mutual funds affiliated with or specified by Pershing in amounts set forth in the prospectus or other offering document for such funds. The higher the 12b-1 fees paid by the money market mutual fund, the lower the yield on cash in a client’s account. These commissions/fees create a conflict of interest as the increased revenue generated from the default money market funds is paid to IFP’s affiliated broker dealer – IFP Securities. Because IFP Securities receives and retains these amounts, IFP has an incentive to recommend a brokerage account offering sweep money market funds paying 12b- 1 fees, which in turn will negatively impact the amount they will earn on cash in their account. IARs do not receive a portion of the money market compensation paid to IFP. IFP does not make available other share classes of the sweep money market funds, including those that do not pay 12b-1 fees; however, clients can choose to purchase other [ 25 ]  money market funds, including those that do not pay 12b-1 fees, and move assets from the money market fund or bank deposit account that serves as your cash sweep vehicle into such other funds. Clients are not obligated to maintain assets in the core sweep money market fund or bank deposit sweep account. Cash in a client’s brokerage account will be placed in the sweep option he or she selects by default and remain in that sweep option until the funds are invested elsewhere or the client withdraws the cash from the account. Clients have the option of utilizing margin on their advisory accounts. A margin account is an account where clients borrow funds for the purpose of purchasing additional securities. Clients will also use a margin account to borrow money to pay for fees associated with their account or to withdraw funds. There are various, heightened risks associated with a margin account than with a “cash” account (wherein no margin credit exists).4 If clients decide to open a margin account, they should carefully consider that: (i) if they do not have available cash in their account and their account is a margin account, they are borrowing money to purchase securities, paying for fees associated with their account or withdraw funds; and (ii) they are using the securities that they own as collateral. Money borrowed in a margin account is charged an interest rate that is subject to change over time. This interest rate is in addition to other fees associated with their account. IFP retains a portion of the margin interest charged, which is a source of revenue. This compensation represents a conflict of interest as IFP has a financial benefit when clients maintain a margin debt balance. This compensation is retained by IFP and is not shared with the client’s IAR. Therefore, IFP has a financial incentive to recommend that clients maintain a margin balance. Another conflict of interest with respect to margin accounts incudes the fact that IFP and some IARs charge an AUM fee based upon the total credit in the account, and/or retain the debit in another account than the account where the assets reside subject to an AUM fee. IAR does have a conflict of interest when recommending that clients purchase or sell securities using borrowed money. This conflict occurs because a client’s advisory fee is based on the total market value of the securities in his or her account. If clients have a margin debit balance (in other words, they have borrowed and owe money to IFP’s clearing firm/platform such as Pershing, Schwab and Fidelity), their margin debit balance does not reduce the total market value of their account. In fact, if clients have borrowed money to purchase additional shares, the total market value of their account will be higher, which results in a higher advisory fee. Clients should also carefully review the margin disclosure document for additional risks involved in opening a margin account. ACCOUNTS ESTABLISHED THROUGH INSTITUTIONAL CUSTODIANS 4Investors can lose more funds than they deposit in the margin account. A decline in the value of securities that are purchased on margin may require you to provide additional funds to the firm that has made the loan to avoid the forced sale of those securities or other securities or assets in their account(s). • The firm can force the sale of securities or other assets in a client’s account(s). If the equity in the client account falls below the maintenance margin requirements, or the firm’s higher “house” requirements, the firm can sell the securities or other assets in any of the client’s accounts held at the firm to cover the margin deficiency. Clients also will be responsible for any short fall in the account after such a sale. • The firm can sell client securities or other assets without contacting the client. Some investors mistakenly believe that a firm must contact them for a margin call to be valid, and that the firm cannot liquidate securities or other assets in their accounts to meet the call unless the firm has contacted them first. This is not the case. Most firms will attempt to notify their customers of margin calls, but they are not required to do so. However, even if a firm has contacted a customer and provided a specific date by which the customer can meet a margin call, the firm can still take necessary steps to protect its financial interests, including immediately selling the securities without notice to the customer. • Clients are not entitled to choose which securities or other assets in an account(s) are liquidated or sold to meet a margin call. Because the securities are collateral for the margin loan, the firm has the right to decide which security to sell in order to protect its interests. • The firm can increase its “house” maintenance margin requirements at any time and is not required to provide a client advance written notice. These changes in firm policy often take effect immediately and may result in the issuance of a maintenance margin call. A client’s failure to satisfy the call may cause the member to liquidate or sell securities in his or her account(s). • Clients are not entitled to an extension of time on a margin call. While an extension of time to meet margin requirements may be available to customers under certain conditions, a customer does not have a right to the extension. [ 26 ]  If clients contract for IFP’s asset management services, only those custodians that have been approved by IFP shall be used. IAR uses third-party institutional custodian (“Institutional Custodians”, which are Qualified Custodians as the term is understood per the Investment Advisers Act of 1940, as amended). Such custodians are not affiliated with IFP. Clients should consider conflicts of interest when selecting a custodian. Institutional Custodians include but are not limited to Schwab, Fidelity and Pershing/Pershing Advisory Services and SEI to maintain custody of client assets and to effect trades for client accounts. Clients may request that IFP work with additional custodians, but unless such additional custodial relationships are via a custodial arrangement between the TPAM and the custodian directly, then IFP will likely decline the proposed business because working with additional custodians would essentially impair IFP’s operational and compliance efficiencies by not channeling its business through its established custodial relationships; IFP is already a multi-custodial firm, and creating more relationships strains existing resources, and the existing custodians already cover a great variety of options available in the market for such services. Thus, some level of restraint in expanding into having more custodial/brokerage relationships is helpful. Custodians provide IFP with access to client institutional trading and custody services, which are typically not available to retail commission brokerage accounts. Depending upon the Institutional Custodians, they offer more or less, when compared to other custodians, a combination of, or all of, the following: • a combination of transaction execution services and asset custody services; • capacity to execute, clear and settle trades (buy and sell securities for client accounts); • capacity to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.); • breadth of available investment products; availability of investment research and tools that assist IFP and its IARs in making investment decisions; • competitiveness of the price of services (commissions rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices; reputation, financial strength, security and stability; availability of other products and services that benefit IFP, including, but not limited to, some investments that otherwise may generally only be offered to institutional investors. Other benefits include a trading platform; receipt of duplicate client confirmations and bundled duplicate statements and/or providing data feeds containing the same information; access to a dedicated trading desk serving program participants exclusively; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; the ability to have investment advisory fees deducted directly from a client’s account; receipt of research and compliance publications and access to certain mutual funds which generally require significantly higher minimum initial investments or that are generally available only to institutional investors. Custodians have the choice to discount or waive fees they 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 IFP. As a fiduciary, IFP continually seeks to act in the client’s Best Interest. IFP’s recommendation or requirement that a client maintains his or her assets in accounts at its existing custodians is based in part on the benefit to IFP 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 the Custodians, although the motivation of using these custodians is based upon their platform, scale, size, access the products and services and market presence, which IFP believes is ultimately in the client’s Best Interest. That being said, there is a conflict of interest insofar as IFP is not generally capable with its existing relationships and resources to establish numerous custodial relationships with smaller/different custodians than the ones used by IFP. Institutional Custodians may or may not charge separately for custody services and are compensated by account owners through commissions and/or or other transaction-related or asset-based fees for securities trades that are executed through the custodian. IFP’s various custodians are all required to seek best execution in terms of how they handle and route orders. They review and publish data on such order routing and execution quality; links to their Best Execution statistics are provided herein under the subsection entitled “Best Execution”. While quality of execution at the best price is an important consideration, best execution does not necessarily mean lowest price and it is not the sole consideration. Some custodians will aggregate transactions for a client with other clients to improve the quality of execution. Allocations of the aggregated orders are made under procedures designed to treat all clients fairly. The trading process of any [ 27 ]  custodian suggested by IFP must be efficient, seamless and straight forward. Overall execution speed, custodial support services, trade correction services and statement preparation are some of the other factors to consider when utilizing a custodian. HOW IFP SELECTS BROKERS/CUSTODIANS When the IAR serves as the discretionary portfolio manager, then IARs make choices of custodian when setting up a new account, and those choices must be based upon the Best Interest of the client. When the IARs serve as the non- discretionary portfolio manager, then the IARs make recommendations, but a client decides which custodian to use. When IFPAM serves as the portfolio manager, either on a discretionary basis or non-discretionary basis, IFPAM either, as applicable, exercises discretion on the choice of custodian or recommends the choice of custodian to be made best upon what it deems to be in a client’s Best Interest. When selecting a custodian as custodian/broker to hold a client’s assets and execute transactions, IFP considers whether the terms that the custodians provide are, overall, the most advantageous to a client when compared with other providers and their services. IFP takes into account a range of considerations, including: • Combination of transaction execution services and asset custody services; • Capability to execute, clear and settle trades (buy and sell securities for your account); • Capability to facilitate transfers and payments to and from accounts; • Breadth of available investment products; • Availability of investment research and tools that assist IFP in making investment decisions; • Quality of services; • Competitiveness of the price of those services; • Reputation, financial strength security and stability; • Prior services to IFP and IFP’s clients; and • Services delivered and paid for by the Custodian. SCHWAB-SPECIFIC DISCLOSURES, INCLUDING SOME CHOICE OF CUSTODIAN CONSIDERATIONS This selection is designed to relate to Schwab, but since IFP offers a multi-custodial platform, some of the descriptions below will reflect that fact. Brokerage and Custody Costs For client accounts maintained with Schwab, Schwab typically does not charge a separate fee for custody services. Instead, Schwab is compensated through commissions or other transaction fees for trades executed within client accounts or for trades that settle through Schwab. Certain securities, such as mutual funds or exchange-traded funds (ETFs), may not incur Schwab commissions or transaction fees. Schwab may also earn compensation by retaining interest on uninvested cash balances held in client accounts through Schwab’s Cash Features Program. For some accounts, Schwab charges an asset-based fee, calculated as a percentage of the total assets in the account, in place of traditional transaction-based commissions. In addition to commissions and asset-based fees, Schwab may charge clients a flat dollar fee, known as a “prime broker” or “trade-away” fee, for each trade executed by a third-party asset manager (TPAM) at a broker-dealer other than Schwab, when those trades settle in the client’s Schwab account. These fees are separate from any commissions or fees charged by the executing broker-dealer. To help minimize trading costs for clients, IFP encourages clients and their Investment Advisor Representatives (IARs) to execute trades through Schwab (or another custodian approved by IFP). Executing trades away from the primary custodian may result in higher overall transaction costs due to additional fees and could impact the quality of trade execution. IFP seeks to ensure that all trading activity aligns with clients’ Best Interests while minimizing unnecessary expenses and maintaining the integrity of execution quality. [ 28 ]  Products and Services Available to IFP From Schwab Schwab Adviser ServicesTM serves independent investment advisory firms like IFP. They provide IFP clients with access to their institutional brokerage services (trading, custody, reporting and related services), many of which are not available to Schwab retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through IFP. Schwab also makes available various support services. Some of those services help IFP manage and grow its business. Schwab’s support services are generally available on an unsolicited business (IFP does not have to request them) and at no cost to IFP. The following material provides a more detailed description of Schwab support services. Services that benefit clients. Schwab institutional brokerage services include access to a broad range of investment products, execution of securities transactions and custody of client assets. The investment products made available through Schwab include some of which clients might not otherwise have access to or that would require a significantly higher minimum initial investment by IFP clients. Schwab’s services described in this paragraph generally benefit clients and their accounts. Service that do not directly benefit clients. Schwab also makes available other products and services that benefit IFP but do not directly benefit clients and/or their accounts. These products and services assist IFP in managing and administering clients’ accounts and operating the firm. They include investment research, both Schwab’s own and that of third parties. IFP uses this research to service all or a substantial number of clients’ accounts, including accounts not maintained in Schwab. In addition to investment research, Schwab also makes available software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of IFP fees from other clients’ accounts • Assist with back-office functions, recordkeeping, and client reporting IFP does not open accounts for clients, although IFP may assist clients in doing so. To the extent that a client’s account is maintained at Schwab (or any other IFP’s other custodians for that matter), and most trades may occur through Schwab or such other designated custodian, such custodians have the ability to use other brokers to execute trades for a client’s account. Client Brokerage and Custody Costs For IFP client’s accounts that Schwab maintains, Schwab generally does not charge the client separately for custody services, but is compensated by charging clients commissions or other fees on trades that it executes or that settle into their Schwab account. Certain trades (for example, mutual funds and ETFs) do not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in client accounts in Schwab’s Cash Features Program. For some accounts, Schwab charges clients a percentage of the dollar amount of the assets in the account in lieu of commissions. Services that generally benefit only IFP. Schwab also offers other services intended to help IFP manage and further develop the business enterprise. Their services include: • Educational conference and events; • Consulting on technology and business needs; • Consulting on legal and compliance-related needs; • Publications and conferences on practice management and business succession; • Access to employee benefits providers, human capital consultants and insurance providers; and • Marketing consulting and support. In 2022, IFP signed a contract with Schwab whereby they agreed to provide IFP up to $10,000 in benefit insofar as they would cover eligible expenses, which are various legal services, compliance services, technology/research services and [ 29 ]  marketing and consulting services. IFP intends to use the benefit to cover some of the costs of its annual sales and due diligence conference for investment advisory personnel and supervised persons. This is being included as a conflict of interest. It serves as an incentive to use Schwab over other custodians. At the same time, IFP included a disclosure that IFP obtains financial benefit when IFP or its personnel invite product providers, such as a mutual fund company, insurance company and private placement sponsor, to a meal, educational or entertainment events, and they pay the bills for such events. Schwab provides some of these services itself. In other cases, it will arrange for third party vendors to provide the services to IFP. Schwab also discounts or waives its fees for some of these services or pays all or part of the third party fees. Schwab 5 may also provide IFP with other benefits, such as occasional business entertainment for IFP personnel. IFP’s interest in Schwab’s services, as well as the service of other Custodians. The availability of these services from Schwab6 benefits IFP because IFP does not have to produce or purchase them. IFP doesn’t have to pay for Schwab’s ancillary services. Schwab has also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on IFP’s behalf. The fact that IFP receives these benefits from Schwab is an incentive to recommend/request the use of Schwab rather than making such a decision based exclusively on client interest in receiving the best value in custody services and the most favorable execution of their transactions. This is a conflict of interest. IFP believes, however, that taken in the aggregate, whichever custodian is used, the selection of the custodians, whether Schwab or otherwise, as custodian and broker is driven by the Best Interest of the clients. IFP’s selection is primarily supported by the scope, quality, and price of custodian’s services and not service that benefit only IFP. RESEARCH AND OTHER BENEFITS The custodians used by IFP make available other products and services that benefit IFP but do not directly benefit clients or their accounts. These products and services assist IFP and a client’s IAR in managing and administering accounts. These include, but are not limited to, investment research, access to client account data (such as duplicate trade confirmations and account statements), facilitation of trade execution, allocation of aggregated trade orders for multiple client accounts, pricing and other market data, facilitation of payment of IFP fees from client accounts, assistance with back-office functions, recordkeeping, and client reporting. Since IARs may receive unsolicited or unrequested products and services, IFP receives “soft dollars” in relation to the established practices and resources of its clearing platforms. IFP receives research and other services from its clearing platforms (Pershing, Schwab, Fidelity and SEI), which are benefits associated with utilizing their platforms generally, and based upon review of such relationships, IFP believes such benefits comply with the safe harbor contemplated in Section 28(e) of the Securities Exchange Act of 1934, as amended. Such ancillary benefits associated with certain platforms do not impact individual order routing decisions by IFP as IARs since IARs and IFP do not route orders as a trading firm does, but rather IFP is subject to the order routing decision of the Qualified Custodians. Once IFP’s IARs decide to open a client account at a particular Qualified Custodian, any subsequent order routing decisions are made by the Qualified Custodians. However, IFP and its IARs may elect to use a particular Qualified Custodian for certain benefits offered by such platforms. While such research, systems and processes are not a function of order routing decisions or commissions being paid for transactions, but rather are platform benefits provided by custodians to their institutional customers such as us, these benefits may not be allocated equally among all of clients or their Accounts. IFP may also receive services, which can include investment profiles, sales literature, advertising and other materials. IFP platform custodians may also provide education and financial support at IFP conferences designed to educate IARs on the services available to support clients. 5Other custodians and/or product providers also provide comparable benefits for meals and entertainment or financial support for IFP’s conference with IARs 6The availability of services from other custodians likewise benefit IFP. [ 30 ]  Products and services beyond trade execution that broker-dealers commonly make available to advisors as an integral part of their institutional trading and custody platforms. These products and services may be proprietary to the brokerage firm or provided by third parties. They typically include pricing and other market data, research, software and software discounts available to correspondents of the institutional trading and custody platforms. Such software may not, however, be for administrative and reporting purposes. Although often made available on an unsolicited basis and not tied to the amount of trading the IAR does or the commissions its clients pay, the availability of these services and particularly the extent to which the IAR uses them should be disclosed as appropriate in discussing factors the IAR considers in selecting or suggesting brokers and determining the reasonableness of their commissions. Transition Assistance Benefits IFP provides various benefits and payments to IARs that are new to the IFP platform to assist the IAR with the costs (including foregone revenues during account transition) associated with transitioning his or her business to the IFP platform. The proceeds of such Transition Assistance payments are intended to be used for a variety of purposes, including, but not necessarily limited to, providing working capital to assist in funding the IAR’s business, satisfying any outstanding debt owed to the IAR’s prior firm, offsetting certain fees payable to IFP as a result of the IAR’s transition to IFP’s platform, technology set-up fees, marketing and mailing costs, licensure fees, moving expenses, office space expenses and staffing support. The amount of the Transition Assistance payments can be significant in relation to the overall revenue earned or compensation received by the IAR at his/her prior firm. Such payments are generally based on the size of the IAR’s business established at his/her prior firm and/or assets under management on the IFP platform. This creates a conflict of interest as IARs that choose to join IFP may have been influenced by such benefits/payments. Additionally, Qualified Custodians and Clearing Firms will provide IFP and/or IAR with additional revenue or expense reimbursement to aid in the transfer costs associated with moving from another firm to IFP or from one Clearing Firm, Custodian to another within the IFP platforms. 7 In most cases, this additional compensation is passed on to the IAR who, in turn, uses it to assist with expenses or to reimburse Client’s for costs incurred during the transfer. This creates a conflict of interest because of the benefit received by IFP or the IAR. IFP strives to act in the client’s Best Interest and, where conflicts of interest appear to exist, IFP seeks to eliminate and/ or mitigate them, or, at a minimum, disclose them if determined to otherwise be in compliance with applicable industry standards. IFP’s recommendation that clients maintain their assets in accounts at certain broker-dealers and custodians can be based in part on the benefit to IFP of the availability of some of the foregoing products and services and not solely on the nature, cost or quality of custody and brokerage services provided by such broker-dealers and custodians. This creates a conflict of interest as other broker-dealer or custodians not recommended by IFP may be less expensive to clients. Clients are under no obligation to act on IFP’s recommendations. Best Execution IFP takes its responsibility for Best Execution seriously. The totality of the arrangement and services provided by a broker-dealer must be examined to determine “Best Execution.” Accordingly, while IFP does consider competitive rates, it does not necessarily obtain the lowest possible commission rates for your account transactions. Therefore, the overall services provided by the unaffiliated broker-dealers and custodians providing execution services, either themselves or through their dealer network, are evaluated to determine Best Execution. IFP does not receive any compensation or incentive for referring clients to certain broker-dealers for brokerage trades. IFP will arrange for the execution of securities brokerage transactions through IFP Qualified Custodians, including their broker-dealer(s), that IFP reasonably believe will provide Best Execution. IFP does not handle orders as such, 7Pershing is IFP’s sole clearing firm for affiliated broker/dealer, which serves as custodian for broker/dealer-only accounts, but also serves as the Qualified Custodian for investment advisory accounts of IFP. IFP’s custodians generally pay IFP client account fees for closing accounts at other custodian in order to open accounts at IFP’s custodians. IFP understands such transition benefits are not unusual in the industry, and exist among with top US clearing/custodial platforms, but IFP is, nevertheless, disclosing such payments as a conflict-of-interest that incentivizes account transfer. That being said, the customer and the IAR are not obligated to transfer accounts as an IAR leaves one firm and joins IFP, and neither is the customer obligated to rollover assets from one firm to IFP simply because an IAR joins IFP. Regulation Best Interest governs such rollover/transfer recommendations and DOL Prohibited Transaction Exemption (“PTE”) 2020-02 and PTE 84-24 govern rollover recommendations for retirement accounts. [ 31 ]  but places orders with its various custodians, and they handle and route such orders in pursuit of Best Execution. In seeking Best Execution, the determinative factor is not the lowest possible commission cost, although that is clearly an important factor, but the holistic analysis of Best Execution entails evaluating whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services and the Client’s needs and objectives, including the value of research provided, execution capability, execution speed, commission rates and responsiveness. • https://www.fidelity.com/trading/execution-quality/overview • https://www.schwab.com/execution-quality • https://www.orderroutingdisclosure.com/ (Pershing Site – Put in Broker/Dealer Name as “IFP Securities”) • https://seic.com/help-clients/sei-investments-distribution-co-rule-605-and-606-reports As a general policy, IFP does not accept client instruction to use a broker/dealer other than the Qualified Custodian platforms, and part of the reason is that Best Execution may be sacrificed. Operational and reporting efficiency is another reason. In any event, if IFP were to accept “direct brokerage” orders, then IFP may not be able to obtain the most favorable costs or execution, and clients may pay higher fees or transaction costs. Clients may also lose any benefits that IFP has been able to obtain for other clients such as volume discounts, order aggregation or block trades. If clients direct IFP to use a particular broker-dealer, clients will have the sole responsibility for negotiating the commission rate and other transaction costs with the broker-dealer and/or custodian. When an account is being managed by a TPAM, IFP is not able to change the costs of execution charged by the custodian that holds the account or the quality of the execution services provided by the clearing firm used by the TPAM. Also, if the TPAM trades away from IFP custodians, using IFP custodians as prime brokers, clients will incur additional fees and trading costs with the other firms, and will also incur costs to transfer those positions into IFP’s custodians. 8 Such a practice should be avoided in all accounts because of the additional costs (absent some very compelling reason to trade away, which is in the “Best Interest” of a client for unbundled pricing accounts, although such a demonstration of Best Interest is generally unlikely, particularly for bundled/Wrap Fee accounts). Clients should address concerns or questions regarding the costs or quality of execution services to the TPAM and the Qualified Custodians and/or broker/dealers they use. Clients should consider that, when an account is being managed by a TPAM, that clients could pay higher commissions or trade execution charges through them than through other broker/dealers and/or custodians. TRADE ERRORS On occasion, an error could be made in your account, which, for example, would be if and when a security were to be erroneously purchased in your account instead of being sold. Purchase amount would be another common example of a trade error. In these occasions, IFP seeks to engage in corrective activities in your account so that it is reflected as if no error occurred. Depending on the circumstances, corrective steps will be taken, including but not limited to, cancelling the trade, adjusting an allocation, and/or crediting clients’ account. When the correction of a trade error results in a loss, IFP works with the relevant custodian to make your account whole. In the event a trading error results in a profit, the profit is retained by the qualified custodian, or in placed into a netting account for IFP with the qualified custodian. Please contact IFP at (813) 341-0960 with any questions regarding netting accounts. CONFLICTS OF INTEREST In addition to other disclosures about conflicts-of-interest in this document, IFP offers the following disclosure about the types of conflicts between IFP, a client’s IAR and the client: • When IFP’s personnel serve in the capacity as a RR or an insurance agent, IARs have a conflict of interest when they solicit, offer and sell securities and insurance products for which clients would pay a commission, while also soliciting, offering and selling investment advisory services and managing the assets in client accounts and charging a separate investment advisory fee. IFP addresses this conflict of interest by requiring the IAR to disclose to clients at the time a brokerage account is opened through IFP Securities the nature of the transaction or relationship, his or her role as an IFP Securities RR, and any compensation, including commissions that are paid by the client and/ or received by the FP. Moreover, IFP’s IARs, beyond mere disclosure, should, if such dual compensation were to be 8Such trade away costs are impermissible if they occur for a Wrap Fee account. [ 32 ]  proposed, justify how such dual compensation is consistent with their fiduciary duty towards clients. As a general policy, IFP prohibits an IAR from charging a commission for the same assets for which the IAR receives an AUM fee. Clients are encouraged to discuss with their IAR how each transaction, rollover recommendation, account allocation, implied hold recommendation and compensation approach is in their Best Interest. In situations where your IAR is managing/advising your account in exchange for an AUM fee, in most cases, IARs should not charge a commission because such a dual compensation structure is not generally considered to be in the Best Interest of the client. IFP, if such dual compensation is detected, will seek to investigate and take corrective action, if necessary. Changes in a client’s financial situation and investment objectives, which are not recorded and accounted for, may ostensibly create incentives to manage/advise account in ways contrary to a client’s current situation. An example of this is if a client’s liquidity needs increase, surplus resources decrease or time horizon becomes shorter, it would appear to be a conflict of interest for an IAR to have clients invested in longer-term products, securities with a longer-term value proposition, packaged products such a fee-based annuities and/or complex products that have greater risks and require more analysis and work to advise or rollover, and when such work and needed analysis serves as a justification for a higher AUM fee or a reason that some assets were not liquidated, and this is particularly the case if such assets could have been liquidated and placed in assets not subject to an AUM fee (e.g., assets that would either not be subject to billing or that might be excluded from billing). If an IAR knew of those changes and did not adjust a client’s account, then the conflict of interest would be known, and would not be acceptable by any standard. However, if such changes were not known, an IAR could not reasonably be expected to change the management/ advisory style. In that respect, it is the client’s responsibility to promptly notify IFP if there is a change in his or her financial situation or investment objectives. • Commissions charged for assets under ongoing account advisory/management services are not generally an appropriate compensation approach. If for some reason, a client or his or her IAR determine certain commission- based products/assets are in his or her Best Interest, the client is not obligated to use IFP Securities or its affiliated insurance agency, or agencies under contract with IFP, for securities transactions or insurance products. • Account Rollover/transfer recommendations presents a conflict of interest because IARs have an economic incentive to recommend clients to rollover their retirement plan or IRA outside of IFP into an IFP advisory program account, including into a new IRA. • Clients are under no obligation to engage the services of an IAR, TPAM or any other industry service provider recommended by IFP. However, once a client enters into an arrangement with an IAR of IFP and/or a TPAM, his or her retention of discretion over implementation decisions are based upon the terms of the contract, and should understand the termination of such a contract will be specified in the body of the contract. Otherwise, a client may accept or reject recommendation from IFP or its IARs, unless he or she contractually vest limited investment discretion with his or her IAR. • Some of IFP’s IARs engage in referring clients of IFP to other service providers such as accountants. Fees are not allowed to be shared, unless a bona fide solicitor agreement is in place. In these cases, a conflict of interest exists if the IAR is receiving any fees as a solicitor and the firm receiving such referral enters into an agreement and manages or advises client accounts inappropriately, despite IFP lack of knowledge of how another firm might manage/advise the same client account. Another conflict of interest would be if there is a tacit expectation or understanding if IFP/ IAR refers a client to another investment adviser and/or IAR, then there would be a referral back from those entities or individuals to IFP. IFP policy disallows such “tied” or “tacit” agreements. • Securities and insurance products sold in exchange for a commission also have conflicts of interest when the product sold has a higher commission or fee than another product (e.g., private placements and variable annuities have higher fees than many other registered securities products. Some indexed or market-linked fixed annuities also have relatively higher fees). • A client’s IAR has an incentive to convert assets purchased in a brokerage/commission-based environment to an investment advisory account/fee so that they can start earning fees on such the value of the respective account. Such conversions are subject to a fiduciary/Best Interest analysis. Also, in that sense, there would be a period where, essentially, double compensation appears to exist for the same assets, and, as indicated, such conversions are subject to a fiduciary/Best Interest analysis. • Because IFP’s advisory fees and those of the other TPAMs within the IFP’s advisory program are based on assets under management/AUM, IFP and those TPAMs have a conflict of interest in reflecting or realizing a higher value of [ 33 ]  the securities held in Client accounts since a higher valuation produces higher advisory fees. To ensure that Client assets are accurately valued, for purposes of calculating fees, securities listed on any national securities exchange shall be valued, as of the valuation date, at the closing price on the principal exchange on which they are traded. Any other securities or investments shall be valued in a manner determined in good faith to reflect fair market value. Any such valuation should not be considered a guarantee of any kind with respect to the value of the assets. IFP’s custodians, in their sole discretion, may use the services of an independent valuation agent, as well as other independent sources with respect to the computation of market value of securities. The data contained in those reports has not been verified by IFP. As an IFP policy, private placements that are not subject to periodic/updated valuation assessment should not be subject to an AUM fee.9 • When IFP provides a client with a recommendation as an investment adviser or as a broker-dealer, IFP must act in the client’s Best Interest and not put IFP’s interest ahead of the client. At the same time, the way IFP makes money creates some conflicts with client interests. Clients should understand and ask IFP about these conflicts because they can affect the recommendations and investment advice clients receive. • The foregoing notwithstanding policy prohibitions against charging a commission and an AUM fee, an example of a conflict, as noted above, is that IFP Advisors, IFP Securities and IFP Insurance Group are under common ownership. A client’s IAR may suggest that he or she implement investment advice by purchasing securities products through a commission-based IFP Securities, LLC account. If the client chooses to purchase these products through IFP Securities, then IFP and the client’s IAR will receive a commission based on the specific product purchased. A conflict will exist between the interests of IFP, the client’s IAR and the client’s interests because the FP will earn compensation for each arrangement. A commission for the commission-based account, an advisory fee for managed account and a fee for financial planning services when applicable. • Clients are free to implement investment advice through any broker-dealer or product sponsor they choose. However, a client should understand that, if he or she authorizes an IFP IAR to engage in securities transactions on his or her behalf, his or her IAR must place all purchases and sales of securities products through IFP Securities or other IFP- approved institutions. • • • • • • Not only do clients want to know how much they will pay in fees, but they should also understand how their IAR is incentivized. The IAR has an incentive in the fee charged to clients as they receive a percentage of the fee with the remaining amount of the fee retained by IFP. IFP receives an incentive based upon the number of accounts opened with Pershing, which could impact the recommendation to open an HSA account, and could impact the likelihood, when opening an HSA account, to use Pershing rather than another custodian. IFP’s receipt of fees based upon margin balances maintained for clients held with Pershing. IFP receives a portion of the fees paid by the client for collateral/non-purpose loans provided by Pershing. IFP does not offer a money market sweep account with Pershing that do not have 12b-1 fees. IFP receives more money from clients when they open a margin account if they are charged an AUM fee because such fees are generally applied to the total credit in the account, and does not consider the debit, particularly if the debit is held in another account. • An IAR will either earn a commission for recommending a product or service if they are acting in a broker capacity or they may earn a fee in the form of a one-time fee or an ongoing fee if they are acting in an advisory capacity. Depending on facts and circumstances, either are appropriate (both may be appropriate in differing circumstances, but generally are not appropriate at the same time, for the same assets), but both revenue streams are generally not appropriate at the same time, for the same assets, and generally are against IFP policy in those cases. As indicated herein, if an asset was originally purchased in a brokerage transaction, and is later converted into an investment advisory account, such conversions are subject to a fiduciary/Best Interest analysis. 9For such billing AUM fee on private placements, IFP ‘s policy is that IFP may bill on private placements that do not charge a commission and that have periodic valuations (e.g., not merely a beginning and end valuation), except that private placements may be placed under an AUM fee without a periodic valuation during the accumulation and capital raise so long as such issuers compute a NAV with regular updates in the holding phase of such capital. [ 34 ]  • IFP and a client’s IAR can receive additional compensation from third-party firms such a product providers or service providers. If clients are interested in learning more, please review IFP’s Revenue Sharing Disclosure at https:// ifpartners.com/wp-content/uploads/2023/03/Revenue_Sharing_Disclosure.pdf, or clients may request a hardcopy of it by contacting their IAR or IFP Compliance at (813) 341-0960. Revenue Sharing: • Revenue sharing is a form of a conflict of interest. IFP has entered various arrangements with some companies where revenue sharing occurs. Although IFP endeavors at all times to put the interest of its clients ahead of its own or those of its officers, directors, or representatives (“affiliated persons”), these arrangements could affect the judgment of IFP or its FPs when recommending investment products. Because these situations present a conflict of interest that may affect the judgment of IFP financial professionals, IFP believes it is important that clients are aware of IFP’s revenue sharing arrangements when clients and their financial professionals evaluate investment options. • IFP has established revenue sharing arrangements with a select group of companies that offer a broad spectrum of products. These companies participate in activities that are designed to help facilitate the distribution of their products. Companies participating will have greater access to IFP’s financial professionals through marketing activities, training, and other educational presentations so that IFP’s financial professionals can better serve their clients. • These payments can originate from the company’s distributor, its investment adviser, and/or other related entities. Certain companies will make this payment from investment assets, while others will not. While the revenue sharing arrangements with each company will vary, IFP typically receives a flat fee, payment based on sales, or payment based on assets under management. Such fees oftentimes are structured as due diligence fees and other product provider revenue streams, non-cash compensation/event-sponsorship and account transfer expense reimbursement. Based upon its review, IFP has concluded that no such revenue sharing runs afoul of the Soft Dollar Safe Harbor or applicable regulations governing non-cash compensation. Nevertheless, they broadly fall into the category of conflicts of interest. • • • • IFP and/or its IARs receive cash or non-cash compensation from product manufacturers and vendors for educational events, client meetings and other meetings because the amount of such benefits could influence the investment decisions made. IFP’s program to provide Forgivable Notes to transfer their business to IFP presents a conflict of interest as it incentivizes IAR’s to maintain client relationships with IFP for the duration of the Note and/or to choose IFP over another firm. IAR may have outside business interests (“OBAs”) unrelated to IFP. For example, in situations where a client’s IAR serves in capacities such as an insurance agent, accountant, real estate agent, consultant or other businesses unaffiliated with IFP, then there is conflict of interest between the IAR and the client, which does not involve IFP as an enterprise. Such conflicts of interest might also exist insofar as the IAR may earn more money from focusing relatively greater attention on such other activities than on managing and advising the account with IFP. If a client’s IAR does not work full-time as an IAR of IFP, including in situations where the IAR has OBAs, the IAR has a conflict of interest in terms of splitting time and attention across various personal business interests outside of IFP and the client’s account with IFP. • Some IARs have received a one-time grant of IFP Group, LLC private stock. IFP Group is the holding company for IFP and IFP Securities. IARs who received this private stock do not serve as officers of IFP. However, they would have a % of ownership and have the ability to participate in IFP’s overall profits. IARs are also eligible to participate in the grant program due to their affiliation as RRs of IFP Securities, LLC and/or IARs for IFP. This arrangement between certain IARs and IFP is a conflict of interest in that it can incentivize decisions to be made in the interest of the firm versus the interest of the client. the amount of client assets they service; Our IARs are compensated based on: • • product sales commissions; • • • the time and complexity required to meet a client’s needs; the revenue IFP earns from the IAR’s advisory services or recommendations; and/or the product sold (e.g., differential compensation; 1 product pays IFP more than another product). [ 35 ]  _____________________________________________________________________________________________________________________ ITEM 13. REVIEW OF ACCOUNTS Real estate advisory client portfolios are reviewed on an ongoing basis by our asset management team. At a minimum, reviews are conducted no less than annually, focusing on property operating performance (rental income vs. projections, major expenses, occupancy/vacancy rates, etc.) and compliance with the client’s investment plan. We also perform a comprehensive annual review for each property, which includes obtaining an independent valuation update (appraisal) and assessing the progress toward the client’s goals for that asset. These annual reviews coincide with our annual performance reporting and fee valuation update. Reviews may be triggered more frequently by significant events, such as a notable market change, an unsolicited purchase offer for a property, a refinancing opportunity, or any problem (for example, a major tenant default or an economic shock in the property’s locale). In such cases, we will analyze the impact on the portfolio and consult with the client on any recommended adjustments. The reviews are conducted jointly by the client’s IAR and our internal asset management team. We maintain internal oversight to ensure that each real estate asset is monitored for performance and risk. Clients are provided with written reports on their real estate portfolio. At least annually, we deliver a detailed Real Estate Portfolio Report showing each property’s current appraised value, performance metrics (income, cash flow, ROI), and any material updates. As part of the account review process, clients are responsible for promptly notifying IFP of any material changes to their financial circumstances, investment objectives, or other information relevant to the management and review of their accounts. Client participation in Family Office Services is entirely discretionary, and clients are under no obligation to engage IFP for such services in connection with the review or management of their accounts. We typically also provide quarterly summaries or updates, which may be in the form of account statements or reports detailing income collected and expenses paid on each property for that quarter, along with year-to-date figures. Additionally, clients receive monthly or quarterly statements from any property managers or operating partners, and copies of those are available directly from the providers. We encourage clients to carefully review all statements and reports. In addition to our reports, clients should rely on records such as property deeds, closing statements, and property management reports as the official records of their real estate holdings. We assist in organizing and maintaining these records as needed. _____________________________________________________________________________________________________________________ ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION IFP receives economic benefit from Schwab in the form of the support for products and services it makes available to use and other independent investment advisers whose clients maintain their accounts at Schwab. Clients do not pay more for assets maintained at Schwab as a result of these arrangements. However, IFP benefits from the arrangement because the cost of these services would otherwise be borne directly by IFP. Prospective clients should consider these conflicts when selecting a custodian. Schwab also agreed to provide IFP up to $10,000 in benefit to be applied for various categories of expenses incurred by IFP, including legal services, compliance services, technology/research services and marketing and consulting services. IFP intends to use the benefit to cover some of the costs of its annual sales and due diligence conference for IFP investment advisory personnel and supervised persons. This is being included as a conflict of interest. It serves as an incentive to use Schwab over other custodians. OTHER COMPENSATION IFP obtains financial benefit when IFP or its personnel invite product providers, such as a mutual fund company, insurance company and private placement sponsor, to a meal, educational or entertainment events, and they pay the bills for such events. [ 36 ]  Some IARs will solicit, offer and sell securities and/or insurance products to clients for commissions in their separate capacities as RRs of IFP Securities or acting as independent insurance agents for IFP Insurance Group, IFP’s affiliated insurance agency. This represents a conflict of interest since IFP and the IAR receive fees and/or commissions if clients choose to implement the recommendations of his or her IAR in his or her separate capacity as a RR or as an insurance agent. In situations where an IAR is associated with an insurance agency unaffiliated with IFP, then the conflict of interest is solely between the client and his or her IAR, which does not involve IFP as an enterprise. In all cases, however, subject to any limited power of attorney (trading discretion) that clients provide to their IAR, they are under no obligation to implement recommendations through IFP or their IAR and are free to choose any broker/dealer or insurance agency that they wish to implement non-discretionary investment advisory recommendations. In situations where clients have granted their IAR limited power of attorney, they may terminate that power and implement recommendations as they deem appropriate. Certain TPAMs, product sponsors or brokerage and/or Custodians will provide IFP or the IAR with economic benefits as a result of their total sales of investment products, but not based upon the volume of sales in in particular product or type of product. A client’s purchase of investments or insurance products, including sponsorship of meetings, marketing support, entertainment/educational meetings, training events, industry conferences and reimbursement of non-lavish travel expenses. Any such event must be for educational purposes and the location of the event must have a reasonable nexus to the issuer of securities. IFP reviews proposals for such events as part of its supervisory policies and procedures for reasonableness and for compliance with applicable industry standards, rules and regulations, but, nonetheless, IFP is disclosing such matters because they have a bearing on compensation and also on what is known as “non-cash compensation”. Such forms of compensation represent a conflict of interest. In some instances, IARs will also receive additional compensation for utilizing a document “E-Delivery” systems, which provides efficiency to the provider. Although IFP is able to negotiate competitive pricing from Pershing that it believes is beneficial to a client, IFP’s clearing relationship with Pershing provides IFP with certain economic benefits by using IFP Securities as the broker-dealer for its advisory program accounts rather than an unaffiliated broker-dealer. For example, as previously described, IFP adds a “Mark-Up” to the transaction costs and increases/marks-up certain other client brokerage-related account charges and fees, rather than passing such charges and fees to the client at cost. The charges and fees that are marked-up include, but are not limited to, paper delivery surcharge fees for client statements and confirmations, clearance and execution fees, outgoing account transfer fees, mandatory reorganization fees, checking account fees, inactive account fees, wire fees, legal transfers fees, bond redemption fees, termination fees, and IRA annual custodial maintenance fees. As disclosed above in Item 12, Brokerage Practices, in the subsection entitled “Transition Assistance Benefits”, some IARs receive transition benefits. Those benefits are paid by IFP, and some of them may be partially subsidized by the Qualified Custodians (e.g., covering account closing fees at other firms). IFP also offers some IARs “Forgivable Notes”, although considering the particularly high “pay-out” (the % of the fees collected by IFP that are paid to the IARs) for fees that IFP affords its IARs, such transition benefits are limited and perhaps smaller than firms with lower pay-outs to their IARs. In any event, the Forgivable Note is a combined amount, used to defray costs of IARs joining IFP. This assistance can include, but is not limited to, technology services, administrative support, marketing costs or reimbursement of fees associated with moving accounts. The Forgivable Notes present a conflict of interest as it incentivizes IARs to maintain their relationship with IFP for the duration of the Note and/or to choose IFP over another firm. Some IARs have received a one-time grant of IFP Group, LLC private stock. IFP Group is the holding company for IFP and IFP Securities. IARs who received this private stock do not serve as officers of IFP. However, they would have a % of ownership and have the ability to participate in IFP’s overall profits. IARs are also eligible to participate in grant program due to their affiliation as RRs of IFP Securities, LLC. and/or IARs for IFP. This arrangement between certain IARs and IFP is a conflict of interest in that it can incentivize decisions to be made in the interest of the firm versus the interest of the client IFP does not provide or receive referral fees in connection with Family Office Services unless disclosed in writing. [ 37 ]  _____________________________________________________________________________________________________________________ ITEM 15. CUSTODY In general, neither IFP nor its IARs hold or maintain actual custody of client assets. There is a circumstance where one IFP advisor serves as the trustee for his/her accounts and as a result, IFP does in fact have custody over those specific assets. In accordance with Rule 206(4)-2 of the Investment Advisor Act of 1940, all cash and securities are maintained with a qualified custodian, clients receive account statements directly from the custodian at least quarterly, and all clients receive written notification of the name of the custodian and contact information. This information is found on the statements provided by the custodian. Third-party Qualified Custodians hold and maintain assets, and those custodians provide account statements directly to clients at their address of record at least quarterly. IFP urges clients to compare the account statements they receive from the account custodian with any performance report or statements IFP, IFP’s performance reporting service providers, or other reports that their IARs may create for them. Clients can contact their IAR with any questions, and if any discrepancies appear, they are encouraged to contact IFP’s Operations Department and/or Compliance Department, requesting to speak with a Principal/Supervisor. Under government regulations, IFP is deemed to have custody of client assets if, for example, a client authorizes the Qualified Custodians that IFP uses to deduct advisory fees directly from a client account, or if a client grants IFP authority to move money to another person’s account. The Qualified Custodians maintain actual custody of assets. As stated above, clients will receive actual account statements directly from the Qualified Custodian at least quarterly. They will be sent to the email (if opting-in to electronic delivery) or postal mailing address provided to the Qualified Custodian. Our firm maintains a limited number of client accounts that are structured as Delivery Versus Payment (“DVP”) accounts, typically in coordination with a trust company that serves as the client’s custodian. Under the DVP arrangement, securities are delivered to the custodian only upon payment, and vice versa, to reduce settlement risk. In these cases, the trust company retains custody of client assets and is responsible for safekeeping and recordkeeping. Our firm does not take physical custody of client funds or securities and does not have direct access to the assets held in the DVP accounts. We typically submit trade instructions to the client’s executing broker or directly to the trust company, in accordance with client authorization. Because DVP accounts often involve separate service providers (e.g., trust companies, brokers, and our advisory firm), clients should review the custodial agreement with the trust company to understand applicable fees, procedures, and responsibilities for asset movement, transaction processing, and reporting. In the context of our real estate advisory services, IFP does not hold actual custody of your real estate properties or related assets. Titles to real property are held by you (the client) or entities you control, and any cash for property expenses or reserves is typically kept in bank or qualified custodial accounts under client’s name. _____________________________________________________________________________________________________________________ ITEM 16. INVESTMENT DISCRETION Family Office Services are primarily non-discretionary, except as separately agreed in writing. IFP does not have discretionary authority to purchase or sell real estate on the client’s behalf. IFP will obtain the client’s consent and approval for each transaction. IFP’s real estate advisory agreements are on a non-discretionary basis – meaning the client makes the final investment decisions. IFP will present recommendations and help execute the client’s decisions, but the client must sign off on property acquisitions, sales, financings, dispositions, and other material actions. In regard to ancillary accounts, upon receiving written authorization from a client, IFP and his or her IAR have the ability to execute securities transactions on a discretionary basis. If a client wants his or her IAR to have the discretion to transact business in the ancillary account without contacting him or her, then the client must agree and authorize discretion as part of the investment advisory agreement signed by the client. When discretionary authority is granted, it is limited to the type and amount of securities to be bought or sold, but not the broker or dealer used, nor the commission rates paid when executing transactions. IARs do not have access to client funds and/or securities with the exception of having advisory fees deducted by the account custodian from the account and paid to IFP. [ 38 ]  If clients authorize discretionary authority, transactions will be executed in their account without discussing the transaction in advance and without any need to approve or clear that transaction. If clients decide to limit the scope of the IAR’s authorization to be “non-discretionary,” then the IAR will be required to contact the client prior to implementing changes in the account. Therefore, a client will be contacted and required to accept or reject the IAR’s investment recommendations, including, but not limited to, security being recommended, the number of shares or units, whether to buy or sell. In that case, it is important that a client promptly respond to these requests in order for the IAR to promptly execute transactions and/or implement strategic adjustments to the portfolio. _____________________________________________________________________________________________________________________ ITEM 17. VOTING CLIENT SECURITIES IFP’s policy prohibits providing proxy voting services. Clients are instructed to read through the information provided with the proxy voting documents and to decide based on the information provided. Upon request, IARs may provide limited clarifications of the issues presented in the proxy voting materials based on IARs understanding of issues presented in the proxy voting materials. However, the client has the ultimate responsibility for making proxy voting decisions. TPAMs have their own policies regarding proxy voting. Clients are advised to review the policies of his or her TPAM to determine their proxy voting policy. _____________________________________________________________________________________________________________________ ITEM 18. FINANCIAL INFORMATION IFP Advisors does not require or solicit prepayment of fees beyond $1,200 per client, six months or more in advance, for any services, including the real estate platform. Therefore, we are not required to include an audited balance sheet in this brochure. Additionally, IFP has no financial condition that we believe is reasonably likely to impair our ability to meet our contractual commitments to clients. The firm has not been the subject of a bankruptcy petition at any time in the past ten years. PAYCHECK PROTECTION PROGRAM The Coronavirus Aid, Relief, and Economic Security Act enacted March 27, 2020 (“CARES Act”) provided multiple potential benefits to small businesses. One of the benefits provided was the Paycheck Protection Program (“PPP”). The intent of the program was to provide loans for qualifying small businesses to help cover their costs associated with payroll, benefits, interest, rent and leases, and utilities during the Coronavirus COVID-19 Pandemic. The PPP loan also provided loan forgiveness provisions based on a variety of factors. In April of 2020, IFP Advisors LLC applied for and obtained a PPP loan in the amount of $1,032,000. While IFP did not regard the funds as necessary to perform its ongoing business operations, IFP’s participation in the PPP was driven by the uncertainty of the then current economic conditions. IFP deposited PPP loan proceeds into its operating account and used the proceeds to cover eligible payroll costs. In June of 2021, under the PPP’s loan forgiveness provisions, the balance of IFP’s PPP loan was forgiven. For more information on the Paycheck Protection Program, please visit https://www.sba.gov/funding-programs/loans/ covid-19-relief-options/paycheck-protection-program. EMPLOYEE RETENTION CREDIT IFP applied for the Employee Retention Credit and expects to receive approximately $1.3 million (approximately $1 million net of fees such as legal fees). IFP retained legal counsel to evaluate and submit the application on behalf of IFP. Since this is something out of the ordinary, IFP has received confirmation that its Parent Company is eligible for a credit of approximately $1,301,000 duly vetted with all the necessary calculations. IFP is disclosing its receipt of the Employee Retention Credit (ERC) on Form ADV Part 2A due to its relevance under required disclosures. Specifically, this disclosure is being made to address potential financial impact, any legal or regulatory issues, and any conflicts of interest associated with the ERC. IFP believes it is important to provide transparency regarding this matter to ensure clients are fully informed about any factors that may affect the firm’s financial condition or regulatory obligations. [ 39 ]